Wings Ltd v Ellis [1985] 1 AC 272 - TDA S 14(1)(a).
- only limited mens rea required.
1) knowledge of falsity required but not knowledge that the statement is made.
- TDA to be understood by public without a lawyer at their elbow.
2) a statement can be "made" even if not communicated to others.
3) s 24 defence available to person charged under s 14.
4) mens rea - offence under s 1 is an absolute offence, but offence under s 14 is not.
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