High Court rules one-star reviews alleging dishonesty could carry defamatory meaning, but dismisses related corporate claim by the law firm
One-star online reviews posted by a former employee accusing a solicitor of dishonesty were capable of being defamatory at common law, the High Court of England and Wales has ruled, although a related claim brought by the law firm itself did not succeed.
In TWH Legal Services Ltd v Niazi, Deputy High Court Judge Guy Vassall-Adams KC determined preliminary issues concerning three reviews published following the defendant’s departure from Croydon-based practice TWH Legal Services Ltd.
The court found that the publications conveyed a central allegation that the solicitor had dishonestly obtained will banks from a retired practitioner after promising payment which was not honoured. The judge held that this allegation was capable of bearing a defamatory meaning in relation to the solicitor personally.
The defendant had worked briefly at the firm in late 2022 before leaving in disputed circumstances. Between April and September 2024 she posted three one-star reviews on legal review platforms alleging dishonesty, fraud, incompetence and regulatory concerns. The solicitor and the firm brought libel proceedings arguing that readers would understand the reviews to mean both that the solicitor had acted dishonestly and that prospective clients should avoid instructing the practice.
Rejecting submissions that the publications would be dismissed as the complaints of a disgruntled former employee, the judge held that a reasonable reader would be likely to attach some credibility to comments from someone with direct experience of working at the firm, even while recognising the possibility of a personal grievance.
The court also concluded that the reviews contained a mixture of factual allegations and expressions of opinion, with statements such as “dishonest” and “fraudster” treated as opinions supported by identifiable factual assertions set out within the reviews.
However, the firm’s corporate libel claim failed. The judge found that the pleaded case did not establish that the publications conveyed a defamatory imputation about the company itself. In particular, one review criticised the solicitor personally rather than the practice, and the argument that readers would infer they should avoid instructing the firm was not sufficiently supported by the meanings advanced in the pleadings.
The court also highlighted weaknesses in the way the claim had been framed, including reliance on a composite meaning across multiple publications rather than identifying separate meanings for each review. The judgment emphasised the importance of precise pleading where both individual solicitors and firms seek to rely on the same allegedly defamatory statements.
The claimant solicitor, Ms Radcliffe, had previously been suspended from practice for 12 months by the Solicitors Disciplinary Tribunal in 2024 following multiple breaches of the SRA Accounts Rules.