This section contains the nature of the case and procedural background.

Ratcliffe (P) and his father were in business as an engineer and boilermaker under the name Ratcliffe and Sons. P operated the family business after his father died. Evans (D) published an article stating that the business had ceased to exist. P sued under false and malicious publication. The jury found that the statement was purposefully made to cause damages to P. P was awarded a judgment. The proof of loss in damages was from a general loss in business. D appealed; P was unable to prove special damages.

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