Lords Hansard text for 17 Jan 201317 Jan 2013 (pt 0001): "President Obama did precisely the same thing that I am about to say that we did to the Malaysia and Singapore. In that Act, we kept the double-action ability rule in place but only for libel proceedings. The effect is that the Defamation Bill, when it becomes law, will provide the British standard; anybody coming from another country and seeking to use the defamation law coercively will have, under the double-action ability rule, to satisfy the standard anyway of the Defamation Act, including the Defamation Act being read with the constitutional and conventional right to free speech. So there will already be very strong reasons in public policy why such a person will not get very far if they seek abusively to bring libel proceedings in those circumstances.
I mention President Obama because, before we had this Bill, when the common law was notoriously chilling on free speech, the noble Lord, Lord Singh, may remember that the Congress of the United States did something pretty rude to us and provided that English libel judgments were unenforceable in the United States on similar grounds. That is my way of trying to explain that we already have defensive mechanisms in our system that would be enforceable to deal with the kind of abuse with which the noble Lord, Lord Singh, is rightly concerned." 'via Blog this'