PPT v Independent Television News: High Court refuses injunction despite suicide risk finding

The High Court has dismissed an anonymised claimant's attempt to block publication of a joint ITV News and Guardian investigation, holding that a finding of grave risk to life did not impose a duty on the court to restrain private publishers. In PPT v Independent Television News Ltd & Anor [2026] EWHC 2818 (KB), Nicklin J rejected claims under Articles 2, 3 and 8 of the European Convention on Human Rights following an expedited Part 8 trial.

The claimant, a well-known public figure, sought a final injunction preventing publication of allegations about his conduct towards young women. The defendants' investigation began in 2022 and became a joint exercise in 2023, involving more than 100 interviews. The claimant denies them, and the court did not decide whether they are true.

The judge accepted the evidence of the single joint expert, whose reports were unchallenged. The claimant has a serious and longstanding psychiatric vulnerability, and the defendants' initial communications had precipitated an acute deterioration. A decision permitting publication, its anticipation and publication itself would each very substantially increase the risk of suicide, giving rise to a real and immediate risk to life. Community safeguards were insufficient, while inpatient treatment significantly reduced but could not eliminate the risk, which remained capable of therapeutic modification. The claimant is currently detained under the Mental Health Act 1983.

Those findings did not establish the operational duty under Article 2. Relying on Rabone, Morahan and Maguire, the judge held that a real and immediate risk is necessary but not sufficient, because the duty depends on State responsibility for the particular risk. That responsibility had been assumed by the psychiatric hospital, not by the court. D & F v Persons Unknown concerned offenders already in State care. Extending the duty to require restraint of lawful private publication would create a new principle of Convention law, contrary to R (Ullah) v Special Adjudicator, and reasoning from the gravity of the risk and the court's power to remove the trigger was circular.

The Article 3 claim failed because publication by private media organisations is not State treatment.

There was also no juridical basis for relief. Section 37(1) of the Senior Courts Act 1981 is not a free-standing cause of action, and following Abbasi v Newcastle upon Tyne Hospitals NHS Foundation Trust the claimant had pleaded no domestic claim such as misuse of private information, breach of confidence or harassment. The judge suggested the reasoning in RXG v Ministry of Justice might require reconsideration, and held that the inherent power considered in PMC v Cwm Taf Morgannwg University Health Board extends only to a court's own proceedings.

Even if an obligation existed, it would not require an injunction. Treatment and risk management were the reasonable response, deferral was not clinically neutral, and a proposed restraint pending reassessment after 18 months had no clinical basis.

On Article 8, the claim failed for want of a juridical basis, but the judge also weighed the competing rights. The interference with the claimant's psychological integrity would be exceptionally grave and carried very substantial weight. Against that stood the defendants' and their sources' Article 10 rights, the public interest in the journalism, and a comprehensive restraint of uncertain duration. The claimant's child's interests could not be decisive without individualised evidence.

Only a short part of the trial was heard in private. The claimant's anonymity, and that of three other individuals, continues pending any appeal and will lapse automatically on first publication identifying him.

Sara Mansoori KC appeared for the claimant and Gavin Millar KC for the defendants.