Global Freedom of Expression

Yaqzan v. Nazzal

On Appeal Contracts Expression

Key Details

  • Mode of Expression
    Press / Newspapers
  • Date of Decision
    February 24, 2014
  • Outcome
    Monetary Damages / Fines
  • Region & Country
    Lebanon, Middle East and North Africa
  • Judicial Body
    First Instance Court
  • Type of Law
    Administrative Law, Civil Law
  • Themes
    Defamation / Reputation
  • Tags
    Censorship, Corruption, Public Officials, Slander, Civil Defamation

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Case Analysis

Case Summary and Outcome

The Court of Publications of Lebanon found a journalist for Al-Akhabar newspaper guilty of libel and disseminating false news. The journalist published an investigative report, detailing the release of two suspected drug dealers as part of the judicial corruption in Lebanon. The Court sentenced the journalist and Al-Akhbar newspaper to pay $26,605 in damages.


Facts

In May 30, 2013, Lebanese journalist, Mohammed Nazzal, published an investigative report in Al-Akhbar daily newspaper, revealing corruption in the country’s justice system. The report particularly detailed the case of two American drug dealers who were arrested in Lebanon but were later released by two judges, despite the country’s strict laws on drug-related crimes. Nazzal pointed out that while many Lebanese nationals remain in prison without trial on similar charges, the two suspected drug dealers were unjustifiably set free after an intervention by the U.S. embassy and the father of one of the suspects, a wealthy Lebanese businessman.

The publication resulted in the resignation of one of the presiding judges. The second judge, Randa Yaqzan, was later demoted.

Despite the demotion, Judge Yaqzan brought a defamation lawsuit in the Court of Publications against Nazzal.  Under Lebanon’s Press and Publication Law, journalists may face fines of up to $67,000 and jail terms of up to three years for defamation, libel or disseminating false information.

 


Decision Overview

The Court of Publications found Nazzal guilty of libel and disseminating false news. It found that his report lacked “any serious proof” of judicial corruption and it contained false news, which is punishable under articles 2, 3, 22, and 26 of Lebanon’s Code of Criminal Procedure and Law on Publications. [1]

The Court held that Nazzal “exceeded his role as a journalist tasked with enlightening public opinion and raising awareness.” [2] It ruled that Nazzal based on his “personal analysis and exaggerated conclusions,” damaged the honor and dignity of the judge. [3]

Ultimately, the Court sentenced Nazzal and Al Akhbar newspaper to pay a total fine of $26,605. [4]

[1] Al-Akhbar, Lebanon’s Court of Publications Strikes Again, (Feb. 25, 2014), http://english.al-akhbar.com/node/18775.

[2] Al-Akhbar, Lebanon’s Court of Publications Strikes Again, (Feb. 25, 2014), http://english.al-akhbar.com/node/18775.

[3] Al-Akhbar, Lebanon’s Court of Publications Strikes Again, (Feb. 25, 2014), http://english.al-akhbar.com/node/18775.

[4] Global Journalists, In Lebanon, 52-Year-Old Libel Law Used to Pursue Reporters, (May 06, 2014), http://globaljournalist.org/2014/05/lebanon-52-year-old-libel-law-used-pursue-reporters/.


Decision Direction

Quick Info

Decision Direction indicates whether the decision expands or contracts expression based on an analysis of the case.

Contracts Expression

The decision contracts freedom of expression by sanctioning the freedom of journalism in disseminating matters of public concern, as well as criticizing  public officials.

Global Perspective

Quick Info

Global Perspective demonstrates how the court’s decision was influenced by standards from one or many regions.

Table of Authorities

National standards, law or jurisprudence

  • Leb.,Regulating Publication Offenses, Legislative Decree No. 104/77 (1977)
  • Leb., Press and Publication Law of 1962

Case Significance

Quick Info

Case significance refers to how influential the case is and how its significance changes over time.

This case did not set a binding or persuasive precedent either within or outside its jurisdiction. The significance of this case is undetermined at this point in time.

Official Case Documents

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