"Pink slime" pay-out – businessman awarded damages for London Post corruption allegations

Background

The claimant, Ovik Mktrchyan, a businessman and entrepreneur, claimed to have significant professional, corporate, property, personal and family ties to the UK, and to have developed projects in the UK, Latvia, Switzerland, Belgium and Uzbekistan. According to his uncontested witness statement, the government of Uzbekistan has repeatedly and officially approved and supported his projects in Uzbekistan, given his professional reputation in business and successful track record of delivering projects in that country.

The first defendant, 2Trom Media Group Ltd, a company registered in England and Wales, was said to own and operate the London Post website and its affiliated social media accounts. The second defendant, Viktor Tokarev, was its sole director.

The claim concerned an article published on the London Post on 19 October 2024 with the headline "Corruption Networks of Uzbekistan: From Washington to Tashkent".

Procedural issues

The claim was issued on 22 April 2025 and served on 12 June 2025. The defendants did not respond to the claim. On 16 February 2026 Master Davison made a judicial determination, on the claimant's application dated 15 December 2025: (a) entering judgment in default of acknowledgment of service against both defendants; and (b) directing a hearing to determine remedies, including the assessment of damages, injunctive relief and the award of costs.

At the hearing, Mr Justice Fordham was satisfied that the defendants had been validly served and ruled that it was appropriate to determine remedies in their absence. The factual basis for the judgment consisted of the unchallenged particulars of claim and uncontested witness statement evidence, and the judge considered the factual picture up until the date of the hearing, focusing on publication, impacts and implications within the UK.

Meaning

The claimant’s case was that reasonable readers of the article would take it to mean that:

1. the claimant was the key player in an Uzbekistan corruption network, which embezzled state funds using offshore accounts and laundered money to gain political favours; and
2. the claimant used the purchase of a controlling stake in Asia Alliance Bank in 2022 by his company, Gor Investment Ltd, as a front for him to embezzle state funds and corruptly to seize control of state assets in Uzbekistan.

The judge did not find anything extravagant or impossible in the claimant's pleaded meaning, and so he adopted it for the purpose of deciding remedies, using the rationale in Brett Wilson. ^[2]

Serious harm and harm-related conduct

The allegations accused the claimant of organised, serious and sustained criminality and corruption. They were presented as being factual and truthful, and the claimant was not approached before the article was published and given no opportunity to comment. The judge found that the article was published to thousands of people in the UK, in circumstances where there were previously very few articles about him published in England and Wales, or in English online, and there were no articles critical of the claimant on any website or social media platform as prominent as the London Post. UK readers would have only learned of the imputations about the claimant from the defamatory article.

Based on the pleadings and evidence, publication of the allegations caused the claimant very significant distress and caused him to fear for his life and for the lives of his family members. The judge also deemed it appropriate to infer that the claimant's companies and family members were refused banking services because of harm caused to the claimant's reputation arising from the article.

Credibility of the London Post

A serious feature of the case is the way that the London Post's ostensible credibility was used to spread disinformation, seemingly as part of a wider campaign that initially began via Russian-language websites and social media platforms, before increasing in scale and intensity during the second half of 2024. The article was the first iteration of the campaign to be prominently published in English via an ostensibly credible and high-profile publication.

The London Post claimed on its website to be regulated by the Independent Press Standards Organisation and to abide by IPSO's Editors' Code of Practice, giving readers further reason to believe that it is a credible and professional publisher. Yet neither the London Post nor 2Trom appeared in the list of approved IPSO members on IPSO's webpage.

The article sat outside the London Post's usual content – predominantly local news articles about events in London, the majority of which appeared to be republications of council, local-government and corporate press releases. Yet that did not stop the article from apparently being picked up by financial institutions as part of their regulatory and compliance checks and being treated as a serious piece of journalism.

This is typical of so-called "pink slime" operations. In an article that was referred to by the court, City AM explained that "pink slime" journalism is being used as a tool to influence everything from AI summaries of search results to banking algorithms that decide whether somebody is eligible for credit. As noted in the judgment, City AM and two other major UK news publishers have recently questioned the credibility of the London Post and its owners, although not until months after the article was published.

Ruling

In the circumstances, where the relevant factual points were "raised squarely" by the claimant, in his properly served pleaded case and witness-statement evidence (which were entirely uncontested by the defendants), the judge found the key points to be established by the claimant on the balance of probabilities. The judge also noted that the key inferences were "proper and appropriate inferences" in light of the other evidence.

As to remedies:

• The judge awarded the claimant general and aggravated damages of £105,000 in total. He considered the sum to be necessary and proportionate in the pursuit of the three aims of "vindication, reputational compensation, and compensation for harm to feelings". He noted that the gravity of the allegations was high, given the allegations of "very serious corruption" in the context of sovereign state assets. He found that the publication would have been read thousands of times in the UK, and that its contents "went to the heart of his professional life", appearing as "factual matters in a legitimate news story from a legitimate news operation" – harm aggravated by the ignoring of reasonable requests to cease posting and to remove the posts.
• The judge also granted a final injunction mandating the defendants to cease publication of the article and prohibiting them from publishing words of the same or similar meaning.
• The judge ordered a summary of the judgment to be posted on the London Post within seven days and to remain in the top three stories for three months and searchable for 12 months.
• The judge summarily assessed costs, granting the claimant's pleaded costs in full and on an indemnity basis in the sum of £117,663.38, finding the specialist solicitors' rates and hours spent to be reasonable in the circumstances.

Comment

The claimant has faced serious consequences and has been forced to take action in multiple jurisdictions to counter the campaign of disinformation.

It is interesting that this case was brought not long before the provisions concerning "strategic lawsuits against public participation" (known as SLAPPs) in the Economic Crime and Corporate Transparency Act 2023 came into force on 18 June 2025, and it serves to highlight what may well be an unintended consequence of those provisions.

Section 195 of the Act states that a claim is a "SLAPP claim" if:

• the claimant's behaviour in relation to the matters complained of in the claim has, or is intended to have, the effect of restraining the defendant’s exercise of the right to freedom of speech;
• any of the information that is or would be disclosed by the exercise of that right has to do with economic crime;
• any part of that disclosure is or would be made for a purpose related to the public interest in combating economic crime; and
• any of the behaviour of the claimant in relation to the matters complained of in the claim is intended to cause the defendant (i) harassment, alarm or distress, (ii) expense or (iii) any other harm or inconvenience, beyond that ordinarily encountered in the course of properly conducted litigation.

It is not difficult to see how, in a case like this one, the new provisions leave open the possibility for a nefarious defendant to make life even more miserable for the claimant by making an application to have the claim struck out as a SLAPP (not least due to the apparent breadth of the definition in the Act). The claimant would then have to incur the time and cost of fighting that application, putting further distance between legitimate defamation claimants and the vindication that they seek. As matters stand, the law provides no real disincentive for making unfounded anti-SLAPP applications, and the allegation that a claimant is bringing a SLAPP claim might mean that a reputation is traduced even further, even if the application ultimately proves baseless.

The increasing "pink slime" phenomenon demonstrates why fairness and balance in the law of defamation – providing appropriate safeguards for freedom of speech, while retaining rights for those who find themselves the victims of unlawful reputational harm – remains as important as ever.

Article written for Entertainment Law Review.