equal proportions for the total loss suffered by the plaintiff, and the total damages to which the court considered the plaintiff was entitled was for example K30,000, this would have been apportioned between the five defendants as to K6,000 each. But inevitably in cases of this land the audiences reached by each news medium will overlap to a greater or lesser degree the audience reached by another medium and, consequently, it could not in such a case be said that the damages to which the plaintiff was entitled in respect of the publication by any one medium was K6,000. Hence, if for instance four of the five defendants were successful in their defences, the damages awarded against the fifth defendant, sing the figures I have postulated above, would certainly be greater than K6,000. It was for this reason that in the Times Newspapers case [5] I considered that a compensatory award of K10,000 was appropriate. This did not mean that I considered that a proper compensatory award for the total loss suffered by the plaintiff by reason of the publication of this libel by the newspapers and the radio and television series was K40,000; for the reasons I have indicated I would regard an award of this magnitude as excessive. It is of course the duty of a court hearing a later action to take into account the damages awarded in an earlier action in respect of the same or substantially the same libel. This later court may be faced with the additional complication that an earlier court has awarded both compensatory and exemplary damages; in considering what compensation to award in the later action I was at one stage in some doubt whether it was not proper to have regard to the fact that the plaintiff had received exemplary damages in the earlier action. I am satisfied, however, that, although logic demands that account be taken of a sum of money which has in fact been received by the plaintiff, albeit that it was awarded as a punishment against the defendant and given to the plaintiff only because there was no one else to whom it could be given, to attempt to adjust subsequent awards of compensatory damages on this ground would create even