A proposal known as the "Rome II" agreement is currently being drawn up in Brussels with the aim of making it easier for European citizens to make cross-border claims for compensation in cases such as road accidents or the sale of faulty goods.This is not good news:
However, the deal as currently framed also extends to the laws of defamation, which publishers fear could trigger an avalanche of costly lawsuits against UK newspapers and magazines all over Europe.
Glasgow media lawyer Campbell Deane believes the proposal would be a disaster if it were introduced in its current form.A spokeswoman for the Periodical Publishers' Association says:
"As a legal adviser, you would potentially have to be aware of the legal issues in not just one jurisdiction, but 25 different legal frameworks," he points out. "If a British newspaper published a story about someone who lives in France, for example, and that person claims that they have been defamed or their privacy has been invaded, they would be able to sue in France."
What’s at issue is that Brussels is harmonising rules which don’t need to be harmonised.But they do need to be harmonised - if you're in the EU. That's what it's for. Duh!
In America, the states all have different legal systems and they’ve never seen fit to harmonise the rules.
By the way, sharp-eyed readers may have noticed that I occasionally comment about Scotland. Please note that I do not live in Scotland; I have never been to Scotland; I have no idea where Scotland is. People offended by this blog should note that it is written from a satellite that is in geosynchronous orbit above 50.52N, 4.22E, and my homemade, nuclear-powered ray gun is aimed at this building.