Snuffer Vs. London Express Newspaper Ltd. (1994) 1 All E.R. 495. In this case plaintiff was a member of a party consisting of more than 2,000 member and most of them were living abroad.
Defendant published a defamatory statement in reference to this party. Plaintiff who was in England with 24 other members sued the defendant because some of his friends considered the article as referring to the plaintiff court rejected the contention of the plaintiff, because most of the members were living abroad and the statement could not be understand as referring to the plaintiff.