Tom Bower on the grounds of the story being "substantially true". The action was heard in July 2009 and Desmond lost the case. An unauthorised biography by Bower of Richard Desmond, titled "Rough Trader", was written and printed in 2006, but still awaits publication. In 2011 Bower published a biography of the Formula One executive Bernie Ecclestone titled "No Angel: The Secret Life of Bernie Ecclestone." Ecclestone cooperated with Bower in the writing of the book, facilitating introductions to people for Bower. Over lunch Ecclestone told Bower "You write what you like, provided it's more or less the truth, because I'm no
Criminal libel The common law offences of seditious libel, defamatory libel, and obscene libel were abolished in England and Wales and Northern Ireland on 12 January 2010 when section 73 of the Coroners and Justice Act 2009 came into force, blasphemous libel having already been abolished in England and Wales on 8 July 2008 by the Criminal Justice and Immigration Act 2008. The Racial and Religious Hatred Act 2006 created instead the offence of inciting hatred against a person on the grounds of their race or religion. Samoa's Crimes Act 2013 dropped reference to criminal libel, which had been on the statute