Mandelboim v. Dadon — Supreme Court transferred related defamation case to Tel Aviv

Case
Michal Mandelboim, Illy Pe’ery & The Hottest Place—Independent Journalism Ltd. v. Ravit Dadon
Court
Supreme Court of Israel (Israel)
Judge
גילה כנפי-שטייניץ (Judicial Selection Committee, chaired by Justice Minister Gideon Sa'ar, 2022)
Date Decided
September 7, 2026
Citation
H.D. 51675-06-26
Topics
Venue Transfer; Defamation; Judicial Efficiency; Related Proceedings

Background

Ravit Dadon, a sexuality instructor and therapist who had served as chair of ALMA, the Israeli Association for Sexuality and Intimacy, brought a defamation action in the Kfar Saba Magistrates’ Court. Her claim arose from an investigative article published on the website operated by the third applicant. The article reported testimony and allegations of abuses of trust and emotional, sexual, and financial harm in therapeutic settings, attributed to sexuality therapists and instructors, including ALMA founders and officeholders.

Three other defamation actions concerning the same article and the same principal defendants were already pending in the Tel Aviv–Jaffa Magistrates’ Court. Its president had assigned those cases to a single judge, leaving that judge to decide later whether to consolidate them. The applicants sought transfer of Dadon’s later-filed action to that court. Dadon opposed transfer, arguing that the conduct attributed to her involved a personal relationship outside a therapeutic setting and that her new action was at a different procedural stage from the Tel Aviv cases.

The Court’s Holding

Justice Gila Canfy-Steinitz granted the application under section 78 of the Courts Law [Consolidated Version], 5744-1984. Although a plaintiff’s choice of a court with jurisdiction carries weight, systemic judicial-efficiency considerations favored transfer. All four actions arose from the same article; the journalist and website operator were central defendants in each; all plaintiffs were sexuality practitioners associated with ALMA; and the cases were expected to present substantially overlapping factual and legal questions and require common witnesses.

The Court also noted that Dadon was represented by the same lawyers representing two plaintiffs in the Tel Aviv proceedings and that the short distance between the two courts substantially reduced any inconvenience caused by transfer. It ordered the Kfar Saba action transferred to the Tel Aviv–Jaffa Magistrates’ Court and assigned to the judge handling the other three cases. The Court expressly declined to decide whether the four actions should be consolidated or how they should otherwise proceed, leaving those matters to the trial court.

Key Takeaways

  • Systemwide judicial efficiency may outweigh a plaintiff’s choice among courts that have jurisdiction.
  • Claims arising from the same publication may warrant transfer when they involve overlapping parties, issues, and witnesses.
  • Transferring related cases to one judge does not itself consolidate them; the trial court retains discretion over their procedural management.

Why It Matters

The decision illustrates the Supreme Court’s use of venue-transfer authority to coordinate parallel defamation litigation and reduce duplicated evidence, judicial effort, and the risk of inconsistent rulings. It also draws a clear distinction between assigning related actions to one judge and formally consolidating them.

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