Bruce v Odhams Press Limited    Practice – Pleading – Particulars – Libel – Plaintiff not referred to by name or description
other than nationality.
The plaintiff complained that she was libelled by a newspaper article concerning certain
aeroplane smuggling exploits of “an Englishwoman.” The plaintiff was not referred to by
name or description, but alleged that the words “an Englishwoman” referred to her. The
defendants applied for particulars of the facts from which it was to be inferred that the
plaintiff was the person referred to.