LEGAL PRINCIPLE: EVIDENCE LAW — Defamation — Libel — Corporate Claimant — Necessity of Proof of Financial Loss
PRINCIPLE STATEMENT
A limited liability company cannot be injured in its feelings as it has no feelings; it can only be injured in its pocket. Its reputation can be injured by a libel, but that injury must sound in money. The injury need not be confined to loss of income; its goodwill may be injured.
RATIO DECIDENDI (SOURCE)
Per Ogundare, JSC, in Edem & Anor v. Orpheo Nigeria Limited & Anor (2003) NLC-1711999(SC) at pp. 3–4; Paras D–A.
"It is settled law that a limited liability company such as the 1st plaintiff cannot be injured in its feelings as it has no feelings; it can only be injured in its pocket. Its reputation can be injured by a libel, but that injury must sound in money. The injury need not necessarily be confined to loss of income. Its goodwill may be injured."
EXPLANATION / SCOPE
A corporate libel claimant need not prove specific financial loss. The principle applies to defamation law. The corporation’s reputation and goodwill are protected. The rule recognises that corporations can be injured in their trading character. The court may award damages without proof of special damage. The principle is well-established.