Facts
Newsvendors sold copies of a newspaper that contained a . They did not know, and had no reason to know, that it contained a libel.
Issue
Is a mere distributor of a libel liable?
Held
The newsvendors were not liable.
Principle
A distributor who did not know of the libel, had no reason to suspect it, and was not in not knowing, has the defence of .
Why it matters
The origin of the innocent dissemination defence, later applied in Vizetelly v Mudie's Select Library.
Cited in these chapters
Cite this page
Emmens v Pottle (1885) 16 QBD 354 (Lanbuk) <https://www.lanbuk.com/llb/torts/cases/emmens-v-pottle> accessed 31 October 2026
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This summary is a Lanbuk study aid based on the generally known facts and reports of the case. It is not legal advice.