Regd AD/ Speed Post
Mr. Mirnal Bharti, Advocate,
B-9, Shekhar Apartments, Mayur Vihar,
Sub: Reply to your legal notice on behalf of my client Mr. Yashwant Singh, Bhadas 4 Media.
Ref: Legal notice dated 14/11/2018 issued by you on behalf of TV18 Broadcast Limited (“TV18”).
My client named above has forwarded the copy of your above legal notice, under the instructions and on behalf of my client named above, I am issuing the following reply to your legal notice:
At the onset, it is clear that vide your notice on behalf of your client, you are brandishing the threat of legal intimidation of my client just because he has dared to publish the rot happening in a famous TV channel owned by an industrial house enjoying political clout.an Please take note that my client is a news blog and has simply published the facts after due verification which is already posted by the victim on social media. Your client has chosen not to rebut or clarify the issue instead comminate and fulminate my client of legal action for his upright professional duty. Please note that an independent and courageous media is a pillar of democracy as the people have a right to know the true facts. Bhadhas 4 Media enjoys such credibility and duly recognized by all for this.
Para wise reply to your legal notice:
1. Para calls for no reply.
2. Para calls for no reply however it is stated for the sake of your information that my client is a Hindi news blog for the news related to media houses. My client enjoys a very good viewership and has been accredited by number of awards in the field of publication of news items related to atrocities on the media personnel working in various newspapers, news channels.
3. The news item under question has been published after the inputs from the victim herself. Needless to point out that she has already posted the entire facts in details on social media.
4.It is clarified and submitted that the said news item has been published after the inputs from the victim herself and after due verification from the sources of my client.
5. The new item has been published after the inputs from the victim herself hence is true.
6. Para calls for no reply being irrelevant.
7. Para under reply is denied as Ms. Alvi has denied your assertions and she has further stated that no show cause or memo with regard to her bad performance was ever given, the assertion now made in your notice is clearly an afterthought and concocted to cover up the illegal acts of your client. Ms. Alvi has specifically denied the same and stated that the training programme is a part of the routine of the staff and undertaken by all. She was put off air in May, 2018 itself immediately after she lodged the complaint of sexual harassment against her supervisor and finally terminated illegally now.
8. Para under reply is contrary to records as Ms Alvi has stated that she was put off the air just because she dared to complain against the supervisor and finally she was terminated illegally.
9. The para is denied as false and concocted, Ms. Alvi has specifically stated about the report of the said committee which was conducted as an eye wash.
10. The filing of FIR is a matter of record. It is apparent that just because Ms. Alvi filed the police complaint she was being targetted and harassed. The entire story has been concocted thereafter to ease out Ms. Alvi from the organization by the management of the TV channel.
11. Para of the notice is illegal on the face of it as Ms Alvi was not issued any show cause on her performance neither an inquiry was conducted against her at any stage which is illegal on the face it. You may ask your client to display the acknowledged copies of the said documents by Ms Alvi so as to prove the assertions made in your notice.
12. Para under reply is denied being false, bogus and concocted. My client has duly verified entire facts after the inputs from the victim and it is clear that no inquiry on bad performance of the victim Ms Alvi was ever conducted and you have issued the marching orders against her just because she dared to raise the issue of sexual harassment at the workplace which is a Constitutional right guaranteed to her.
My client has simply published the news item which is even otherwise visible on the social media as the victim has herself written in details about the misdeeds of your organization. My client has no intention of degrading your client or to ridicule and contempt against him as being claimed by you. My client being a widely read news blog is under duty obligation to appraise the people about the new items in its original form without fear or bias.
13. Para under reply is denied being false and bogus. My client has performed his professional duties of publishing the news item without expressing any qualifying opinion on the same. Your claim that the news item is libelous and resulted in lowering the estimation of your client as an employer is baseless and unfounded. Your claim that the insinuations are also likely to cause substantial losses of revenue to your client is unfounded as the entire facts have been duly posted by the victim on social media and available to the public at large. My client has simply published the same after verifying the facts at its own level which by no stretch of imagination can be termed as libelous. You may ask your client to display the acknowledged copies of the said documents by Ms Alvi so as to prove the assertions made in your notice.
14. Your assertion that the said article amounts to civil and criminal defamation is again unfounded and misreading of law as my client is performing its professional duties of publishing the news items. Your threat in this regard is in bad taste and not accepted by my client.
Hope this clarifies the issues as raised. You are therefore requested to withdraw the notice under reply immediately under intimation to my client.
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