49. The correct approach was succinctly summarised by Lord Phillips MR in Gillick v Brook Advisory Centres [2001] EWCA Civ 1263 (adopting part of the judgment of Eady J below):“[T]he court should give the article the natural and ordinary meaning which it would have conveyed to the ordinary reasonable reader reading the article once. Hypothetical reasonable readers should not be treated as either naive or unduly suspicious. They should be treated as being capable of reading between the lines and engaging in some loose thinking, but not as being avid for scandal. The court should avoid an over-elaborate analysis of the article, because an ordinary reader would not analyse the article as a lawyer or accountant would analyse documents or accounts. Judges should have regard to the impression the article has made upon them themselves in considering what impact it would have made on the hypothetical reasonable reader. The court should certainly not take a too literal approach to its task.” 50. What an ordinary person, not avid for scandal, would read into the words complained of must be a matter of impression. Such a person would not infer guilt merely because an investigation was on foot (per Lord Reid in Lewis v. Daily Telegraph Ltd [1964] AC 234 at p. 260). Guidance in relation to TV broadcasts 51. In the specific context of words spoken in the context of a television programme, it is important to pay particular regard to the guidance given by Sir Thomas Bingham MR in Skuse v Granada Television Limited [1996] EMLR 278 at 285-7 (which concerned Granada’s television programme “World in Action”): “(1) The court should give to the material complained of the natural and ordinary meaning which it would have conveyed to the ordinary reasonable viewer watching the programme once in 1985. (2) The hypothetical reasonable reader [or viewer] is not naive but he is not unduly suspicious. He can read between the lines. He can read in an implication more readily than a lawyer, and may indulge in a certain amount of loose thinking. But he must be treated as being a man who is not avid for scandal and someone who does not, and should not, select one bad meaning where other non-defamatory meanings are available (per Neill LJ, Hartt v Newspaper Publishing PLC, unreported, 26 October 1989 (Court of Appeal (Civil Division) Transcript No. 1015): our addition in square brackets). (3) While limiting its attention to what the defendant has actually said or written, the court should be cautious of an overelaborate analysis of the material in issue. We were reminded of Diplock LJ's cautionary words in Slim v Daily Telegraph Ltd [1968] 2 QB 157 at 171 [to avoid a minute linguistic analysis of every phrase and a protracted exercise in logical positivism]. 12