43. Conventionally, the question of whether words are defamatory is approached in two stages, by first identifying the single meaning which the words would convey to an ordinary reasonable reader (or listener) and then determining whether that meaning is defamatory (per Warby J in Rufus v. Elliot, supra at [17] and see PD53 4.1). 44. I direct myself in accordance with the guidance of Sir Anthony Clarke MR in Jeynes v News Magazines Limited [2008] EWCA Civ 130, [14] (citing authorities such as Skuse v Granada Television Limited [1996] EMLR 278): “(1) The governing principle is reasonableness. (2) The hypothetical reasonable reader is not naïve 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 nondefamatory meanings are available. (3) Over-elaborate analysis is best avoided. (4) The intention of the publisher is irrelevant. (5) The article must be read as a whole, and any “bane and antidote” taken together. (6) The hypothetical reader is taken to be representative of those who would read the publication in question. (7) In delimiting the range of permissible defamatory meanings, the court should rule out any meaning which, “can only emerge as the produce of some strained, or forced, or utterly unreasonable interpretation …” (8) It follows that “it is not enough to say that by some person or another the words might be understood in a defamatory sense.” 45. There has been some useful elucidation of these principles. 46. Principle (2) is descriptive of the hypothetical reasonable reader, rather than as a prescription of how such a reader should attribute meanings to words complained of as defamatory (per Tugendhat J in McAlpine v. Bercow [2013] EWHC 1342 (QB) paras 63 to 66, approved by Sharp LJ in Rufus v. Elliot [2015] EWCA Civ 121 at [11]). As Tugendhat J explained in McAlpine v. Bercow: “If there are two possible meanings, one less derogatory than the other, whether it is the more or the less derogatory meaning that the court should adopt is to be determined by reference to what the hypothetical reasonable reader would understand in all the circumstances. It would be unreasonable for a reader to be avid for scandal, and always to adopt a bad meaning where a non-defamatory meaning was available. But always to adopt 10