 The judge subsequently awarded contemptuous damages of one penny in this action, leaving Reynolds with massive legal costs, estimated at £1 million.A subsequent court of appeal decision in 1998 declared that Reynolds had not received a fair hearing in his High Court action, and the case continued to be heard in the House of Lords.This case led to the recognition under British law (and later introduction into Irish law as the "defence of fair and reasonable publication"), the so-called Reynolds defence of qualified privilege for publishers against whom libel actions regarding defamatory comments made in media publications are being taken.