R (on the application of Calver) v Adjudication Panel for Wales [2012] EWHC 1172 (Admin), [2012] All ER (D) 91 (May)
The Strasbourg jurisprudence recognised the importance of freedom of expression in the political sphere and that the limits of acceptable criticism were wider in the case of politicians acting in their public capacity than they were in the case of private individuals. That recognition involved both a higher level of protection for statements in the political sphere and the expectation that if the subjects of such statements were politicians acting in their public capacity, they laid themselves open to close scrutiny of their words and deeds and were expected to possess a thicker skin and greater tolerance than ordinary members of the public.