Dhristadyumn Khera की तरफ से DAINIK BHASKAR, NOIDA को Legal Notice


Date: 27th February, 2020


Mr. Vibhor Sharma

Editor-in -Chief

Dainik Bhaskar

DB Corp Limited (Digital Business)

FC 10 & 11, Film City, Sector-16A, Noida, UP – 201301

Mr. Tarun Sisodia

Principal Correspondent,


DB Corp Limited (Digital Business)

FC 10 & 11, Film City, Sector-16A, Noida, UP – 201301

Mr. Rakesh Bhalla

Subject: LEGAL NOTICE against wrongful reporting, misrepresentation of facts, copyright infringement and plagiarism on part of the aforementioned through article titled “Germany, Iran mein naukri kar bharat laute buzurg ko dikhi alag-alag khamiyan uthai, 80 fisadi hui thik.” dated 17.02.2020 published in Page 4 of the “Monday Positive” by DainikBhaskar on Mr. Rakesh Bhalla (Hereinafter referred to as “Newspaper Article”) a Hindi daily newspaper published in Delhi.

Dear Sir/Madam,

Under the instructions and on behalf of our client Mr. Dhrstadyumn Khera, we do hereby serve you with the present Legal Notice, in following terms:

  1. Undisputed factual matrix leading to issuance of the present Legal Notice:

1.1 That pursuant to the publication of the Newspaper Article dated 17.02.2020 in Hindi Newspaper DainikBhaskar, our client came to know about the blatant violations carried out by your offices and in particular by the journalist i.e. Noticee No. 2 without the consent of our client

1.2 That the said article contained a photograph that was clicked by our client for his group There Is No Earth B during one of their clean-up drives on 08.02.2020 at Central Ridge Reserve Forest New Delhi.

1.3 That our client being an environmentally conscious person is one of the organizing members of the group There Is No Earth B.

1.4 That our client through his regular activities along with his group There Is No Earth B has highlighted the dangers of Climate Change, plastics and created awareness in schools, colleges etc.

1.5 That our client has been regularly organizing and contributing to the clean-up drives organized by his group There Is No Earth B in New Delhi and in others parts of India, every Sunday since 23.06.18 without any influence from Noticee no. 3. That there are several photographs/videos available to show the phenomenal work of our client and his group.

1.6 That our client’s exceptional work for the great cause of protecting the planet has inspired and motivated many common citizens from every strata of the society, including school/college students, doctors, lawyers, teachers, retired professionals, and serving defence personnels, to join in the clean-up drives organized every week by his group There Is No Earth B.

1.7 That the concerned individual “Mr. Rakesh Bhalla” has been volunteering along with the members of the group There Is No Earth B since 13.01.2019, and has been part of only 55 out of the total 180 clean-up drives organized by our client Mr. DhrstadyumnKhera and his group There Is No Earth B.

  1. Circumstances led to issuance of the present Legal Notice:

2.1 That on 08.02.2020, our client along with his group There Is No Earth B had organized the clean-up drive at the Central Ridge Reserve Forest in Central Delhi at 3.30 pm. As usual, our client had taken/clicked photographs from the clean-up drive highlighting the event on various social media forums. It is pertinent to mention that Mr. Rakesh Bhalla featured in your article joined our client and his group as a volunteer in the said clean-up drive.

2.2 That on 17.02.2020, our client Mr. DhrstadyumnKhera was shocked to find the photograph clicked by him in you, the Noticee No.1’s Hindi Newspaper in Page 4 of the “Monday Positive” section/article on Mr. Rakesh Bhalla covered by the Noticee No. 2. That our client immediately informed his group i.e. There Is No Earth B about the said publication. Thereafter, our client and his group quickly shared and highlighted the issue through their respective social media handles requesting you the Noticeesto remove the said article as well as the photograph.

2.3 That on the very same day, i.e. 17.02.2020, the Noticee No. 2 called up our client’s group i.e. There Is No Earth B representative at around 10.34 am and instead of issuing an apology, rather arrogantly asked our client Mr. DhrstadyumnKhera for his copyright on the said photograph.

2.4 That you the Noticee No. 1 have published the photograph as well as the article in Page 4 of the “Monday Positive” section/article on Mr. Rakesh Bhalla covered by the Noticee No. 2 without our client’s consent and permission or due diligence, which is a grave violation and misuse of the photograph by the Noticee No. 2 in connivance with Rakesh Bhalla for his professional gains and is against the intent and purpose for which the photographs were produced by our Client.

2.5 Undisputedly, our client has the original digital negatives of the published photograph and thus holds the copyright of the same as per the prevailing Intellectual Property Laws in India.

2.6 The article so mentioned contains in paragraph 3 the statement “yehdekhkarchaatraunse (Mr. Rakesh Bhalla) prabhavit hue aurharravivarunkesaathkoodauthanemai jut gaye”, which is in direct contradiction and is a misrepresentation of the real facts as stated in section 1.7.

  1. Henceforth, the Noticees are hereby being put to notice in the following terms:

3.1 Since, despite repeated requests to remove the said photograph or issue a printed as well as digital apology (through DainakBhaskar’s official Twitter account) in you the Noticee No.1’s newspaper giving due credits to our client Mr. DhrstadyumnKhera and his group There Is No Earth B, no positive response has been received from t you all the Noticees and the deliberate silence to ignore our client’s genuine request to remove the photograph clearly establishes the mischievous attempt to gain publicity on the credible work of our client.

3.2 That the above action from your end is a premeditated attempt to poach on the extraordinary work of our Client and his group and gain false credibility for the work of our Client. Furthermore, the article published and covered on 17.02.2020, by you the Noticees, clearly establishes the false narrative/stories and misrepresentation of facts which are against the very principles of journalism which require fact-checking, reporting true and genuine information, identifying sources, and more significantly correcting mistakes.

3.3 As such, you the Noticees have not adhered to any of the above and by merely building up false stories and publishing the same in blatant violation of journalistic principles of honesty, fairness and credibility, you have violated the provisions of Indian Copyright Act as well as Intellectual Property Laws which are binding upon you to remove the photograph. That mere mention of asking for copyright of the said photograph so clicked by our client by Noticee No.2, further establishes the malafide and connivance in taking professional credit for the hard work of our client Mr. DhrstadyumnKhera and his group There Is No Earth B.

3.4 Under the aforementioned circumstances, we hereby through the present Legal Notice call upon you to remove the photograph from your social media handle within a period of 15 days and issue an unconditional written apology through the newspaper or the digital handle with due credits to our client and his group There Is No Earth B or pay Rs. 3,00,000/- (Rupees Three Lakhs Only) as damages within 30 days from the date of receipt of this notice, along with interest at the rate of 18% p.a. from 17.02.2020, failing which our Client has given us a clear mandate to initiate all legal remedies available to us against you all aforementioned, in appropriate Court of Law, and initiate a formal complaint against the newspaper and the culprit journalist in the Press Information Bureau of India.

  1. You are also liable to pay a sum of Rs.1,00,000/- (Rs. One Lakh only) as necessary costs and expenses towards the present legal notice.

Copy of this legal notice is also kept at our office for further ready reference and reliance, if it so required in future.



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