MR JUSTICE WARBY Approved Judgment 68. Monroe v Hopkins [2017] EWHC 433 (QB) In Sobrinho at [46]-[50] Dingemans J identified a number of other uncontroversial propositions about the Serious Harm requirement: “46. …. Serious” is an ordinary word in common usage. Section 1 requires the claimant to prove as a fact, on the balance of probabilities, that the statement complained of has caused or will probably cause serious harm to the claimant’s reputation. … 47. Secondly it is open to the claimant to call evidence in support of his case on serious harm and it is open to the defendant to call evidence to demonstrate that no serious harm has occurred or is likely to do so. However a Court determining the issue of serious harm is, as in all cases, entitled to draw inferences based on the admitted evidence. Mass media publications of very serious defamatory allegations are likely to render the need for evidence of serious harm unnecessary. This does not mean that the issue of serious harm is a “numbers game”. Reported cases have shown that very serious harm to a reputation can be caused by the publication of a defamatory statement to one person. 48. Thirdly there are obvious difficulties in getting witnesses to say that they read the words and thought badly of the claimant, compare Ames v The Spamhouse Project [2015] EWHC 127 (QB) at paragraph 55. This is because the claimant will have an understandable desire not to spread the contents of the article complained of by asking persons if they have read it and what they think of the claimant, and because persons who think badly of the claimant are not likely to co-operate in providing evidence. 49. Fourthly, where there are publications about the same subject matter which are not the subject of complaint … there can be difficult points of causation which arise… 50. Fifthly, as Bingham LJ stated in Slipper v BBC [1991] QB 283 at 300, the law would part company with the realities of life if it held that the damage caused by publication of a libel began and ended with publication to the original publishee. Defamatory statements are objectionable not least because of their propensity “to percolate through underground channels and contaminate hidden springs” through what has sometimes been called “the grapevine effect”. However it must also be noted that Bingham LJ continued and said “Usually, in fairness to a defendant, such effects must be discounted or ignored for lack of proof” before going on to deal with further publications which had been proved to be natural, provable and perhaps even intentional results of the publication sued upon.”