“This lady is extremely dishonest and dodgy AVOID !!!!! Worked for this lady for several weeks about 7 and she incompetent on a level you wouldn’t believe. She kept promising to pay wages and didn’t pay a penny. In the end I walked out and took my files with me and clients that wanted me to take their files with me. Elaine Liddle claimed the clients were hers even though she had never met any of them. I had already transferred client money over to her firm from another solicitors I had worked at and Elaine refused to transfer client money unless the file was transferred back to her firm so that she could make money on them. 99% of the client insisted for their late relatives money and files to be transferred out of this lady’s firm. She also scammed Elizabeth Radcliffe out of her Rowe Radcliffe Will banks by making her hand over the wills and sign a document promising to pay Elizabeth commission on any probate work generated from the Will banks however Elaine has not done this and was lucky that Elizabeth didn’t sue her. This lady also lives in Reading but doesn’t tell clients around Coulsdon area that she lives in Reading. In terms of requesting original wills from her I left the original Will or Patricia Hussey in a drawer at Airport House however when formally requesting it from Elaine she claimed she doesn’t have it. She just lied and in my opinion is a malicious natured person. I’ve never known a solicitor like her in my whole life. I was also told she was sacked from her last job for incompetency. She also has dyscalculia and can’t do maths. While working for her I saw her get one clients papers and mistakenly put it in another.”
“My opinion she is a rubbish dishonest dodgy Malicious lady whose ex husband was a convicted criminal for drug driving. My opinion She is a bare faced liar and Is a fraudster she stole the Will banks off Elizabeth Radcliffe. She doesn’t know the law so makes it up ! A devious and sly character. Don’t use her”
“****DO NOT USE THIS WOMAN ELAINE LIDDLE**** It’s my opinion that she is a DECEITFUL MALICIOUS NASTY PIECE OF WORK A CROOK AND A TOTAL FRAUDSTER AND A BARE FACED LIAR WHO IS TOTALLY INCOMPETENT !!! DO NOT TRUST HER TO DEAL WITH CLIENT MONEY AT ALL !! HOW SHE EVEN QUALIFIED AS A SOLICITOR IS A MYSTERY. Very surprised that she hasn’t been STRUCK OFF yet by the SRA with the number of complaints she has had regarding holding onto client money and so many other issues. She also doesn’t live in the Coulsdon area at all but lives in Reading. She doesn’t like Coulsdon and Croydon clients to know that she lives in Reading and doesn’t tell clients . She just has a room in Airport House Purley rented so one assistant called Amanda can be there and it then seems the firm is Coulsdon Croydon based. We only know of 2 employees at this firm Elaine Liddle and her assistant Amanda. Her firm B&L Solicitors has been trading for less than 2 years and in my opinion the foundations of it was based on THEFT of Elizabeth Radcliifes Will banks. Without the stolen Will banks this firm could not exist. She was meant to pay Elizabeth money for probate work secured but to date hasn’t paid a penny. Please look up her address on companies house. I have attached screenshots from companies house. She deceived the owner of Rowe Radcliffe Solicitors out of her client Will banks . Elizabeth Radcliffe who was a solicitor in Coulsdon for 40 years had the Rowe Radcliffe Will bank and then from 2019 she had the Percy Holt and Nowers Will bank as she took over PHN. Elaine forced and pressured Elizabeth to sign a sale document for the 2 Will banks promising orally to pay Elizabeth money for the Will banks but once she got the signature on the document and the physical wills , Elaine did not pay a penny to Elizabeth and clearly had no intentions to. Elaine then went onto to set up her own business ,B & L Solicitors , having defrauded Elizabeth Radcliffe out of her Will banks. She was meant to pay for probate work secured by to date hasn’t paid anything. It’s my opinion Elaine has no shame at all lying to people so please AVOID. Don’t get fooled by this ladies charm and friendliness. I would also recommend don’t let her hold your wills or money and you will find she might recommend you to another law firm Streeter Marshalls but that’s because she has gone and done some deal with that firm with the stolen Will banks that she defrauded Elizabeth Radcliffe out of. She even said that she was going to store all the clients wills in her garage in Reading. This is without any clients knowing of course. Her firm is a one man band consisting of just HER and an assistant called Amanda. Virtually all the services on Elaine’s website she cannot do but has to encourage and pressure clients to go off to Streeter Marshall. She is a lady in her 70s who qualified as a solicitor in her very late 50s and in my opinion I have never seen or known anyone so malicious devious and incompetent and dishonest and unprofessional as this lady. Despicable disgraceful and such dishonest behaviour !!!!! One of Elaine’s previous firms of employment said they sacked her due to how incompetent she was. Elaine Liddle also communicated how her ex husband was a convicted criminal and how he did drink and drug driving. Please see attached text messages from Elaine Liddle. I’ve never known before for a solicitor to have been married to a convicted criminal. She kept talking about “magic mushrooms” when I didn’t even know what they were. Elaine was familiar with “magic mushrooms” as she says her ex husband used to take the drugs. She also said that her only child hasn’t spoken to her for over 15 years. As sad as that is not sure why she would advertise that to someone she doesn’t know very well maybe she wanted victim sympathy. Having dealt with Elaine Liddle and witnessed her deceitful and malicious behaviour I feel sympathy for her only child that chooses not to speak to her. DO YOURSELF A FAVOUR AND AVOID HER !!!”
“At common law, a meaning is defamatory and therefore actionable if it satisfies two requirements. The first, known as "the consensus requirement", is that the meaning must be one that "tends to lower the claimant in the estimation of right-thinking people generally." The Judge has to determine "whether the behaviour or views that the offending statement attributes to a claimant are contrary to common, shared values of our society": Monroe v Hopkins[2017] EWHC 433 (QB) ,[2017] 4 WLR 68 [51]. The second requirement is known as the "threshold of seriousness". To be defamatory, the imputation must be one that would tend to have a "substantially adverse effect" on the way that people would treat the claimant: Thornton v Telegraph Media Group Ltd[2010] EWHC 1414 (QB) ,[2011] 1 WLR 1985 [98] (Tugendhat J).”
“i) The governing principle is reasonableness. (ii) The intention of the publisher is irrelevant. (iii) The hypothetical reasonable reader is not naïve but he is not unduly suspicious. He can read between the lines. He can read in an implication more readily than a lawyer and may indulge in a certain amount of loose thinking but he must be treated as being a man who is not avid for scandal and someone who does not, and should not, select one bad meaning where other non-defamatory meanings are available. A reader who always adopts a bad meaning where a less serious or non-defamatory meaning is available is not reasonable: s/he is avid for scandal. But always to adopt the less derogatory meaning would also be unreasonable: it would be naïve. (iv) Over-elaborate analysis should be avoided and the court should certainly not take a too literal approach to the task. (v) Consequently, a judge providing written reasons for conclusions on meaning should not fall into the trap of conducting too detailed an analysis of the various passages relied on by the respective parties. (vi) Any meaning that emerges as the produce of some strained, or forced, or utterly unreasonable interpretation should be rejected. (vii) It follows that it is not enough to say that by some person or another the words might be understood in a defamatory sense. (viii) The publication must be read as a whole, and any “bane and antidote” taken together. Sometimes, the context will clothe the words in a more serious defamatory meaning (for example the classic “rogues’ gallery” case). In other cases, the context will weaken (even extinguish altogether) the defamatory meaning that the words would bear if they were read in isolation (e.g. bane and antidote cases). (ix) In order to determine the natural and ordinary meaning of the statement of which the claimant complains, it is necessary to take into account the context in which it appeared and the mode of publication. (x) No evidence, beyond the publication complained of, is admissible in determining the natural and ordinary meaning. (xi) The hypothetical reader is taken to be representative of those who would read the publication in question. The court can take judicial notice of facts which are common knowledge, but should beware of reliance on impressionistic assessments of the characteristics of a publication's readership. (xii) Judges should have regard to the impression the article has made upon them themselves in considering what impact it would have made on the hypothetical reasonable reader. (xiii) In determining the single meaning, the court is free to choose the correct meaning; it is not bound by the meanings advanced by the parties (save that it cannot find a meaning that is more injurious than the claimant's pleaded meaning).” (iii) The hypothetical reasonable reader is not naïve but he is not unduly suspicious. He can read between the lines. He can read in an implication more readily than a lawyer and may indulge in a certain amount of loose thinking but he must be treated as being a man who is not avid for scandal and someone who does not, and should not, select one bad meaning where other non-defamatory meanings are available. A reader who always adopts a bad meaning where a less serious or non-defamatory meaning is available is not reasonable: s/he is avid for scandal. But always to adopt the less derogatory meaning would also be unreasonable: it would be naïve. (iv) Over-elaborate analysis should be avoided and the court should certainly not take a too literal approach to the task. (v) Consequently, a judge providing written reasons for conclusions on meaning should not fall into the trap of conducting too detailed an analysis of the various passages relied on by the respective parties. (vi) Any meaning that emerges as the produce of some strained, or forced, or utterly unreasonable interpretation should be rejected. (vii) It follows that it is not enough to say that by some person or another the words might be understood in a defamatory sense. (viii) The publication must be read as a whole, and any “bane and antidote” taken together. Sometimes, the context will clothe the words in a more serious defamatory meaning (for example the classic “rogues’ gallery” case). In other cases, the context will weaken (even extinguish altogether) the defamatory meaning that the words would bear if they were read in isolation (e.g. bane and antidote cases). (ix) In order to determine the natural and ordinary meaning of the statement of which the claimant complains, it is necessary to take into account the context in which it appeared and the mode of publication. (x) No evidence, beyond the publication complained of, is admissible in determining the natural and ordinary meaning. (xi) The hypothetical reader is taken to be representative of those who would read the publication in question. The court can take judicial notice of facts which are common knowledge, but should beware of reliance on impressionistic assessments of the characteristics of a publication's readership. (xii) Judges should have regard to the impression the article has made upon them themselves in considering what impact it would have made on the hypothetical reasonable reader. (xiii) In determining the single meaning, the court is free to choose the correct meaning; it is not bound by the meanings advanced by the parties (save that it cannot find a meaning that is more injurious than the claimant's pleaded meaning).”
“On occasion, a defamatory statement might seem to have been intended to be understood as a comment but is not defensible by an honest opinion defence. For instance, a publisher might state “in my view, Jones is a disgrace”, without giving any indication of what the underpinning facts are or even that there are any such facts. Alternatively, a speaker might allude to a matter which he believes to be common background knowledge—“given what we all know …”—but misreads the audience and leaves them underinformed as to any alleged factual underpinning for his remarks. The language used clearly implies that an evaluative process has been undertaken by the publisher, but the failure to present or indicate the reasoning prevents the audience from understanding adequately what the remarks are about. Hence, the personal opinion expressed stands in effect as an unexplained and unreasoned factual allegation. This situation has become known as “bare comment”
“The cases on “bare comment” do not lay down a rigid rule of law that requires a court to depart from this key principle, and artificially treat a statement of opinion as if it was a statement of fact. On the contrary. The authorities show that “bare comment” is a pointer, or guideline, or rule of thumb that reflects the key principle. The question is, would the words used strike the ordinary viewer as a statement of fact or opinion? The answer does not turn on whether any given word is an adjective, noun, or verb, or some other part of speech. This is a matter of substance, not a formal, analytical matter of grammar or linguistics. In practice, when someone uses a descriptive word without giving any detail of what he is describing, that will tend to come across as an allegation of fact. That is what the cases on “bare comment” say.”
“the statement complained of indicated, whether in general or specific terms, the basis of the opinion.”
"Condition 2 (in subsection (3)), reflects the test approved by the Supreme Court in Joseph v Spiller that “the comment must explicitly or implicitly indicate, at least in general terms, the facts on which it is based”."
“104. Such considerations are, I believe, what Mr Caldecott had in mind when submitting that a defendant's comments must have identified the subject matter of his criticism if he is to be able to advance a defence of fair comment. If so, it is a submission that I would endorse. I do not consider that Lord Nicholls was correct to require that the comment must identify the matters on which it is based with sufficient particularity to enable the reader to judge for himself whether it was well founded. The comment must, however, identify at least in general terms what it is that has led the commentator to make the comment, so that the reader can understand what the comment is about and the commentator can, if challenged, explain by giving particulars of the subject matter of his comment why he expressed the views that he did. A fair balance must be struck between allowing a critic the freedom to express himself as he will and requiring him to identify to his readers why it is that he is making the criticism.”