The appellant, the Attorney-General, appealed against the amount of an assessment of
damages by a High Court judge in an action taken for libel by the respondent. The
action related to the publication of allegations of treason and subversion against the
respondent from the broadcasting and television stations as a result of a Press release
issued by a Government news agency.

The appellant had obtained damages earlier against two newspapers as a result of
publications based on the same Press release. No defence was entered and damages
were assessed at K30,000, being K10,000 compensatory and K20,000 exemplary


Section 9 (1) of the Law Reform (Miscellaneous Provisions) Act, Cap. 74,

envisages different actions against joint tortfeasors.

The plaintiff may sue a number of tortfeasors in succession and may get judgment
against them. The sums that can be recovered on such judgments cannot, however,
exceed the sum awarded in the first of such actions.


Under s. 9 (1) (b) of the Law Reform (Miscellaneous Provisions) Act, where a

plaintiff brings different actions against joint torteasors, he puts himself at risk for his
costs after the first.

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