ABSTRACT
A man accused of murder was released on a ‘not proven’ verdict by a Scottish jury. The defendant produced a wax effigy of the man and placed it at the entrance to the Chamber of Horrors.
The court held that the effigy on its own did not amount to defamation but its juxtaposition with other tableaux in the Chamber of Horrors indicated that he was in fact guilty and thus did. Libel is defamation in permanent form and the court held that the waxwork was sufficiently permanent to be libel.
