[2023] EMLR 6; [2022] EWHC 2891 (KB) at [103] (Steyn J); Barron v Vines [2016] EWHC 1226 (QB) at [44]–[46] (Warby J).
168 As I will explain, one of Mr Smark's submissions on the question of serious harm in relation to what Dr Collins called the "maelstrom" of adverse reaction to the primary tweet set out in detail above, was that there was no reason to suppose that it reflected any widespread change in the views held by the particular people who made "adverse" comments directed at Mr Greenwich as a result of seeing the primary tweet.
169 In Riley v Sivier, the claimant was a television presenter and the defendant was a blogger. The case concerned an online article published on a website by the defendant the meaning of which had been determined at a trial of preliminary issues. The website was strongly left-wing and vociferously supportive of the then leader of the UK Labour Party, Mr Jeremy Corbyn MP. The claimant, on the other hand, had been highly critical of the notorious anti-Semitism in the Labour Party under Mr Corbyn, and of his leadership on that issue. (As to which, see generally Neuberger J, Antisemitism: what it is. what it isn't. why it matters (Weidenfeld & Nicolson, 2019) at pages 104–118).
170 Mr Sivier, the defendant blogger, contended that, those things being so, the claimant had no reputation among the readers of his article "because they had already made up their minds about the claimant before reading [it]". See Riley v Sivier at [111].
171 The words complained of in the article were held to contain, among other things, a statement of fact that the claimant had engaged upon, supported and encouraged a campaign of online abuse and harassment of a 16-year-old girl, conduct which had also incited her followers to make death threats towards her. All but one of Mr Sivier's defences had been struck out at a preliminary hearing. The principal issue before Steyn J was whether the article had caused or was likely to cause serious harm to the claimant's reputation.
172 Justice Steyn said as follows at [114]–[115]:
The fact that the Website was, politically, strongly left-wing and vociferously supportive of the (then) leader of the Labour Party, Jeremy Corbyn MP, whereas the claimant had been highly critical of anti-Semitism in the Labour Party under Mr Corbyn, and of his leadership on that issue, probably means that a significant proportion of the readers of the Article would have regarded the claimant as someone to whom they were politically hostile. But this does not lead to the conclusion that the claimant's reputation could not be harmed in their eyes. As Warby J stated in Monroe at [71(8)]:
"… A person can have a low opinion of another and yet the other's reputation
