REPUBLIC OF KENYA

IN THE HIGH COURT AT NAIROBI

CIVIL CASE NO. OF 1999

JOE BLOGGS ……………………………………………………………. PLAINTIFF

VERSUS

THE VILLAGE POST MEDIA COMPANY LIMITED……………….. DEFENDANT

PLAINT

The plaintiff is a male adult individual of sound mind whose address for service for the
purpose of this suit is care of Messrs. …………. Advocates of ………….

The defendant is a limited liability company with its registered office in Nairobi and
whose postal address is P.O. Box 123, Nairobi. [ Service of summons shall be effected
through the plaintiff’s advocates’ chambers.]

At all material times the defendants were and still are the publishers and proprietors of
the Village Post, a daily newspaper which has a large circulation throughout the Republic
of Kenya.

On page 1 of the issue of the said newspaper for the ……… day of …………, 1999, the
defendants falsely and maliciously printed and published of and concerning the plaintiff
the words following, that is to say,

“Joe Bloggs is a dodgy character and the current success of his enterprises are suspect”

The said words referred to and were understood to refer to the plaintiff and the same were
in their natural and ordinary meanings meant and were understood to mean by right
thinking members of the public that :-

The plaintiff is a dishonest person ……..

Further or in the alternative and without prejudice to the foregoing the said words meant
and were understood to mean by way of insinuation and innuendo that:-

The plaintiff did not owe his success due to hard work and prudent management ……