To,
Shri Yashwant Singh
CEO & Editor: Bhadas4Media
Re: Notice on behalf of Mr. Alok Agrawal, CEO- Zee Media Corporation Limited, for defaming his reputation by uploading and displaying false, frivolous and derogatory story in his name on your website bhadas4media.com
1. That our client is a law abiding citizens of India and has great reputation in the society. He has an excellent academic record having studied in prominent institutes such as University of Pennsylvania – The Wharton School, Indian Institute of Management- Bangalore and Indian Institute of technology- Kanpur.
2. That our client has a distinguished professional career and he has worked as a part of the senior management in prominent companies such as Cheil Worldwide- India, Bates and Grey Worldwide- India and is currently working as Chief Executive Officer with Zee Media Corporation Limited.
That from the above it would be appreciated that our client is a man of high social standing and repute and he commands immense respect and reputation in the society at State, National and International level.
4. That our client has come across a story titled “ Zee Media ke Alok Agrawal ne vidhwa ka makaan hadapne ke liye char sau beesi ki” on your website, the link of which is
http://bhadas4media.com/article-comment/17784-2014-02-11-13-10-15.html
5. In the said story it has been alleged that our client is involved in a property dispute in respect of a property bearing no. 15/E-17 Sector-61 (Shivalik) and has also been named in FIR filed by some Smt. Pushplata Seth on 1.06.2013. The FIR lodged is alleged to be in the name of one Alok Agrawal and the said “Alok Agrawal” is stated to be the CEO of Zee News.
6. That it is pertinent to note that our client has no connection whatsoever with the said property in dispute and the said FIR. It is categorically stated that the person named Alok Agrawal in the FIR is some different Alok Agrawal and not our client. That reckless allegations have been made in the said story against our client without carrying out any kind of verification regarding the identity of the person named in the said FIR. It is pertinent to point out that the minimum journalistic ethics which require that before publishing any story involving allegations against some person of repute, his version should be taken and prominently published in the said story, have not been adhered to in the present case. This clearly goes to show that there has been a deliberate and mischievous attempt on your part to malign and tarnish the image and reputation of my client and that of the channel – Zee News.
7. That by publishing the said story on your website which is false, incorrect, malicious, you have defamed and damaged the reputation of our client. . That the said act has been done with an intention to tarnish the image and reputation of our client and to damage his social standing and goodwill in the society.
8. That the said publication of story made on your website is without just cause or excuse and have been made malafide solely with the objective to destroy the good fame and reputation of our client.
9. That the aforesaid publication has badly lowered down and harmed the image and reputation of our client and has also damaged the good fame for which our client has suffered irreparable loss and injury and have also caused great pain and distress besides mental agony to our client.
10. Please note that your act of misrepresenting to the general public about association of our client with the said FIR and levying reckless allegations against our client without verifying the true factual position in this regard with the sole purpose to sensationalize the said news is with ulterior moves and clearly establishes your malafide and such acts on your part also amount to criminal offences under Indian Penal Code (IPC) and IT Act 2000 as amended. The said act has been done with the sole motive of defaming and damaging the reputation, image and goodwill of our client and also that of the channel – Zee News.
Under the circumstances, you are hereby called upon to:
i. Immediately remove the said story from the website bhadas4media.com
ii. Immediately publish prominently that our client has no role in the said FIR and
iii. Immediately publish a public apology prominently on your website
iv. Pay damages of Rs. 1 Crore within 7 days of the receipt of this notice
Please note that our client is extremely determined to take this matter forward for its logical conclusion without any further notice to you, should you choose to ignore the legitimate concerns and demands of our client in this notice.
We look forward to hearing from you immediately on receipt of this notice, failing which we would be constrained to resort to initiation of appropriate legal proceedings both civil and criminal, the costs and consequences of which you would be solely responsible for.
Yours Sincerely
DAYA NAND ARYA
Advocate
For Dharmender Arya & Associates
[email protected]
