Content Regulation / Censorship, Defamation / Reputation, National Security, Political Expression, Press Freedom
Le Ministère Public v. Uwimana Nkusi
Rwanda
Closed Mixed Outcome
Global Freedom of Expression is an academic initiative and therefore, we encourage you to share and republish excerpts of our content so long as they are not used for commercial purposes and you respect the following policy:
Attribution, copyright, and license information for media used by Global Freedom of Expression is available on our Credits page.
The Independent Press Standards Organisation (IPSO), the regulator for the UK print and digital news industry, determined that a national newspaper breached its duty of accuracy in reporting by publishing a significantly inaccurate headline. The case concerned an article which claimed that “one in 12” people in London was an “illegal immigrant,” a figure derived from another publication’s report. The Committee found that the newspaper failed to take due care because the population data and migrant estimates within its own article did not mathematically support the “one in 12” claim. It determined the inaccuracy was significant due to the topic’s social and political implications. Nevertheless, the regulator found that the newspaper’s prompt removal of the article and publication of a correction satisfied the standards of remedial action.
The complainant, John Booth, filed a complaint with the Independent Press Standards Organisation (IPSO) against the Daily Mail newspaper. The complaint alleged a breach of the Editors’ Code of Practice concerning an article published on January 23, 2025, titled “Revealed, how one in 12 living in London is an illegal migrant.” The article reported that a study commissioned by Thames Water found the “irregular” population of London could be between 390,355 and 585,533, which it equated to “one in 12” people.
Booth argued that this claim was inaccurate and misleading. Based on London’s population of 8.8 million, the figures in the article actually equated to between one in 15 and one in 22 Londoners, not one in 12. He also contended that the article insufficiently explained and critiqued the study’s methodology, which he described as “wildly inaccurate.” [para 6]
The Daily Mail stated that its article was based on a front-page story from another national newspaper which contained the same “one in 12” figure. The Daily Mail argued it had attributed the story to this source. However, upon being notified of the complaint by IPSO on January 28, 2025, the Daily Mail acknowledged the inaccuracy and, on January 31, 2025, took remedial action. It published identical corrections in print and online, clarifying the errors, and removed the online article. The original newspaper that published the first story also issued a correction around the same time, stating that: “The figure of 7,044,667 is the estimated population of the Thames Water London Water Resource Zone, excluding irregular migrants, not geographical London which is about 9 million. ‘Up to 1 in 12 illegal migrants’ in a previous version was incorrect…..” [para 14]
The legal basis for the complaint was Clause 1 (Accuracy) of the Editors’ Code of Practice. The specific provisions invoked were:
The IPSO Committee delivered the ruling. The main issue was whether the Daily Mail breached Clause 1 of the Editors’ Code of Practice by publishing inaccurate information and, if so, whether its subsequent correction was adequate.
The complainant, Booth, argued that the Daily Mail failed in its duty to verify the “one in 12” claim, especially as the data within its own article demonstrated the headline’s inaccuracy. He also argued that the published corrections were “almost invisible” and themselves inaccurate for repeating the original false claim. The Daily Mail argued that it was reasonable to rely on the prominent coverage of another national newspaper and that it had carefully attributed the story. It maintained that by correcting and removing the article promptly upon realizing the error, it had fulfilled its obligations under the Code.
In its analysis, the Committee first addressed the breach of Clause 1(i). It acknowledged that the Daily Mail was entitled to report on another newspaper’s story. However, it held that “It was still required, however, to take care over the accuracy of its own article, and to correct any significantly inaccurate information it published”. [para 18] The Committee found that, given the article’s repeated references to “London,” a reader would reasonably assume the “one in 12” figure was based on London’s known population of approximately 8.8 million. Since the highest cited estimate of 585,533 illegal immigrants did not equate to “one in 12” of that population, the headline and the article’s central premise were inaccurate. The Committee concluded that the newspaper’s failure to recognize this discrepancy during its editorial process constituted a failure to take due care, resulting in a breach of Clause 1(i).
Regarding Clause 1(ii), the Committee found the inaccuracy was “significant” because it related to “an important matter of both social and political concern” and was featured prominently in the headline. [para 22] A correction was therefore required. The Committee then assessed the corrective action. It found that publishing corrections in print and online and removing the article within three days of being notified by IPSO was “prompt.” The Committee further noted that placing the corrections in the newspaper’s standard “Corrections and Clarifications” column represented “due prominence,” as this was where a reader would expect to find them. The Committee also rejected the complainant’s argument that the corrections were inaccurate for repeating the “one in 12” claim, stating that “for a significant inaccuracy to be duly corrected, a correction will often need to set out the original inaccurate information. Doing so does not raise a further inaccuracy, provided the correction makes clear that the information was inaccurate – as was the case here.” [para 26] Consequently, the Committee found no breach of Clause 1(ii).
On the complainant’s final point about the article’s failure to critique the study’s methodology, the Committee held that newspapers are free to report the information they see fit. It stated that as the article had described the methodology, omitting a critique of its accuracy did not, in itself, make the article misleading. [para 28]
In conclusion, the complaint was partly upheld. The Committee found a breach of Clause 1(i) for a failure of accuracy but no breach of Clause 1(ii) regarding the correction. No remedial action beyond the correction already published was required.
Decision Direction indicates whether the decision expands or contracts expression based on an analysis of the case.
The decision has a mixed outcome regarding freedom of expression. While IPSO’s decision did not restrict the Daily Mail’s right to express opinions or report on immigration issues, it reinforced the press’s obligation to ensure factual accuracy on matters of significant public interest. By requiring care and correction rather than imposing censorship, the decision effectively balanced freedom of expression with the public’s right to accurate information.
Global Perspective demonstrates how the court’s decision was influenced by standards from one or many regions.
Case significance refers to how influential the case is and how its significance changes over time.
Let us know if you notice errors or if the case analysis needs revision.