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Tolley v J S Fry & Sons Ltd

1931 · [1931] AC 333

Posted By lanbuk.com

Please note: The dictum quoted is Greer LJ's (Court of Appeal).

Facts

A famous amateur golfer's caricature was used in an advert for chocolate without his consent.

Issue

Could the advert carry the meaning that he had compromised his amateur status for money?

Held

Yes; it was capable of that and was libellous.

Principle

Innuendo: words or images not defamatory on their face can be defamatory because of the inference readers draw.

Why it matters

Leading innuendo case.

Cited in these chapters

Cite this page

Tolley v J S Fry & Sons Ltd [1931] AC 333 (Lanbuk) <https://www.lanbuk.com/llb/torts/cases/tolley-v-fry> 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.