\t\u091c\u0928\u0924\u093e \u091f\u0940\u0935\u0940 \u0915\u0940 \u0924\u0930\u092b \u0938\u0947 \u092d\u0921\u093c\u093e\u09384\u092e\u0940\u0921\u093f\u092f\u093e \u0915\u094b \u090f\u0915 \u0932\u0940\u0917\u0932 \u0928\u094b\u091f\u093f\u0938 \u092d\u0947\u091c\u093e \u0917\u092f\u093e \u0939\u0948. \u0910\u0938\u093e \u091c\u0928\u0924\u093e \u091f\u0940\u0935\u0940 \u0938\u0947 \u091c\u0941\u0921\u093c\u0940 \u0915\u0941\u091b \u0916\u092c\u0930\u094b\u0902 \u0915\u0947 \u092d\u0921\u093c\u093e\u09384\u092e\u0940\u0921\u093f\u092f\u093e \u092a\u0930 \u092a\u094d\u0930\u0915\u093e\u0936\u0928 \u0915\u0947 \u0915\u093e\u0930\u0923 \u0915\u093f\u092f\u093e \u0917\u092f\u093e \u0939\u0948. \u091c\u0928\u0924\u093e \u091f\u0940\u0935\u0940 \u0926\u094d\u0935\u093e\u0930\u093e \u092a\u094d\u0930\u0947\u0937\u093f\u0924 \u0932\u0940\u0917\u0932 \u0928\u094b\u091f\u093f\u0938 \u092e\u0947\u0902 \u0915\u0939\u093e \u0917\u092f\u093e \u0939\u0948 \u0915\u093f \u0907\u0928 \u0916\u092c\u0930\u094b\u0902 \u0915\u0947 \u0915\u093e\u0930\u0923 \u091c\u0928\u0924\u093e \u091f\u0940\u0935\u0940 \u0914\u0930 \u0907\u0938\u0915\u0947 \u092e\u0948\u0928\u0947\u091c\u092e\u0947\u0902\u091f \u0915\u093e \u0915\u093e\u092b\u0940 \u0928\u0941\u0915\u0938\u093e\u0928 \u0939\u094b \u0917\u092f\u093e \u0939\u0948. \u0932\u0940\u0917\u0932 \u0928\u094b\u091f\u093f\u0938 \u0915\u0940 \u092a\u0942\u0930\u0940 \u0915\u093e\u092a\u0940 \u0907\u0938 \u0924\u0930\u0939 \u0939\u0948-<\/p>\n
\tMANOJ KUMAR AHUJA CHAMBER:- 42, LAWYER’S CHAMBERS<\/p>\n
\tAdvocate Supreme Court Of India<\/p>\n
\tWESTREN WING.<\/p>\n
\tEnrolment .No. D-1108\/03. <\/p>\n
\tTIS HAZARI COURTS<\/p>\n
\tSCBA Membership NO:244\/A\/647<\/p>\n
\tDELHI-110054<\/p>\n
\tMOB:- +91- 9891445098<\/p>\n
\t <\/p>\n
\tREGD. A.D<\/p>\n
\tTO,<\/p>\n
\tDATED:-07\/12\/2011<\/p>\n
\tSh.Yashwant Singh<\/p>\n
\tC.E.O & Editor<\/p>\n
\tBhadas4media.com<\/p>\n
\tNew Delhi.<\/p>\n
\tSub: – Notice of demand for Rs. 25,00, 000\/- quantified, so far, towards damages and compensation for loss of profit, erosion of goodwill and reputation and also expenses incurred and further expected to be incurred in mitigating the effect of the defamatory publications published on www.bhadas4media.com.<\/p>\n
\tDear Sir,<\/p>\n
\tI, the undersigned, under instructions from, and on behalf of my Client, Gurbinder Singh, Vice President M\/S JANTA T.V( News & Current affairs Hindi T.V. Channel) having its registered office at 40, D.L.F Industrial Area, Kirti Nagar, New Delhi 110015 do hereby serve you, the C.E.O AND Editor of domain name www.bhadas4media.com (“the website”) with the following Demand Notice:<\/p>\n
\tThat my client is a national Hindi channel which has continuously been aired since 3.6.2011.
\tThat the said media venture of Janta TV been recent and in a nascent stage, my client had been investing monies, time and energy in attempting to attract investors and further building reputation and good will in the market and amongst the viewers.
\tThat ever since the said media venture having been conceptualized, planned and thereafter finalized for execution, my client had started to approach potential investors for it is common knowledge that in such ventures and businesses delayed investments would spell doom for the launch and future prospects of the channel. In fact my client owing its steady viewership growth, business and goodwill so generated since 3.6.2011, i.e., the date of the launch of Janta TV, had managed to attract a number of investors. Further, in this period, a number of investors were in the pipeline, including many who had taken the requisite decisions to invest which were only to be implemented\/executed. Thus, despite only few months of being on air and considering the pace at which my client had been generating viewership and investors, manifested an enormous growth potential of my client in a short span of time.
\tThat your website, bearing domain name ‘www.bhadas4media.com’ is one of the well known and frequented portals in the media industry. Further, the said domain name serves as a source of diverting and directing the weary internet surfer to desired sites on the basis of the information, opinion and links it displays on the said site. You are well aware of the huge number of clicks which your website receives directly or even indirectly when an internet surfer is directed to your domain name either through a search engine or through online linking. Therefore it is manifest that any content published on your site has a wide impact over diverse sections and persons who gather information and opinions over the internet. This especially, in respect of the media industry.
\tThat to the utter shock to my Client one of the investors brought to the knowledge of My Client that you, on 26th September had published an article on www.bhadas4media.com, a domain name registered in your name, an article replete with false, fabricated, unverified, malicious and defamatory content in respect of My Client and his channel. You had no occasion or reason to publish such article but to bring disrepute to My Client and further tarnish the business reputation and adversely affect the viewership of his channel for reasons or for persons best known to you.
\tThat apart from the said story having serious affect of defaming My client on a bare and overall reading of the same, almost every sentence of the said story published on your website consisted of unverified, false and defamatory imputations. More pertinently, amongst others, such imputations and false malicious and misleading information included:-<\/p>\n
\tThat My client had been acting as a PR agency without facts;
\tThat the channel had no news sense;
\tThat the condition of My clients channel is in complete mess;
\tThat the condition of the infrastructure of My Clients channel is such that no person would like to seek or continue with employment therewith;
\tEven My Clients name was published as “Gurvinder Singh” instead of “Gurbinder Singh”;
\tThat My Client harasses his employees as to trivial and petty issues as cell phones;
\tThat My Client has a bias towards female employees. Such imputation was included by you in the said story with the intention of holding out manifestly crude and suggestive connotations.<\/p>\n
\tThat you out of sheer malice and manifest intention to bring disrepute and erode the business repute and good will of my client, on 26th September, 2011, the link being https:\/\/www.bhadas4media.com\/edhar-udhar\/13150———.html, published a defamatory article captioned as “ …..” wherein the story so published by you and the imputations therein were, amongst other malicious aspects,:-<\/p>\n
\t Fabricated by you;
\t False, mischievous and actuated by malice;
\t Nothing but a mere figment of your malicious imagination;
\t Without prejudice, based wholly on unverified information;
\t Mired in such inherently improbable allegations that only a reckless person would have put forth in some publication.
\t Ex facie defamatory and has the effect of bringing down the business esteem of my Client.
\t In the most direct manner, in the estimation of others, lowers the Business character and reputation of my client.<\/p>\n
\tthat you by your aforesaid acts and omissions, by way of the aforesaid visible representations on your website namely www.bhadas4media.com, have indulged in publishing false information thereon with a view to defame and malign my Clients personal and business reputation. As a consequence thereof my client has suffered a loss of business, viewership, Clientage as well as potential clientage. Few of our clients have withdrawn their investments while few investors who had been negotiating with my client and were at the stage of formally finalising the deals, on the basis of my clients business & viewership and growth indications in the market, have suddenly withdrawn all offers and a number of negotiations have been abandoned at their final stages. All of them have relied upon the aforementioned defamatory publication on your said website. A number of them have been direct in even citing and expressing their concerns and apprehensions that your publication as aforementioned have good reason to doubt my clients present business and therefore withdraw all offers & business plans and<\/p>\n
\tI therefore, on behalf of my Client, do hereby call upon you to pay a sum of Rupees Twenty Five Lakhs together with interest thereon at the rate of 18% within 15 days from the receipt of the instant demand notice towards the amounts as quantified towards loss of business viewership, compensation and damages from the Company to my Client for your intentional acts and omissions in defaming my client and thereby occasioning the erosion of my clients goodwill and reputation.
\tIt is also made clear that further past, present and future losses as are direct, consequential and incidental to your aforesaid defamatory publication are being assessed, computed and quantified and My Client shall raise an appropriate demand towards the same at a later date.
\tFurther, I call upon you to remove the aforesaid story defaming my client from your website www.bhadas4media.com and publish an unconditional apology both on your said website and in a leading newspaper circulated in Delhi NCR region under intimation to my client for publishing the same.
\tFurthermore, I call upon you to cease and desist in employing the aforesaid or similar tactics to defame my client in future.<\/p>\n
\t <\/p>\n
\tI solicit the your immediate compliance to the instant demand notice, failing which my Client will be constrained to initiate all and any appropriate legal action against you for the recovery of the sums under demand herein, together with all interest, costs, damages and losses further occasioned by the aforesaid defamatory imputations published by you. Furthermore, you are asked to take notice that in the event of legal proceedings, civil or criminal, you shall be solely responsible for all risks, costs and consequences as shall be occasioned thereby. Also that you shall be liable to indemnify my Client from and against all actions, claims, demands, losses, damages, costs and expenses in respect of its failure to comply with the instant demand notice.<\/p>\n
\tYou are advised to take notice accordingly.<\/p>\n
\tYours faithfully
\t(Manoj Kumar Ahuja)
\tAdvocate<\/p>\n
\t(Hard Copy will also follow)<\/p>\n","protected":false},"excerpt":{"rendered":"
\t\u091c\u0928\u0924\u093e \u091f\u0940\u0935\u0940 \u0915\u0940 \u0924\u0930\u092b \u0938\u0947 \u092d\u0921\u093c\u093e\u09384\u092e\u0940\u0921\u093f\u092f\u093e \u0915\u094b \u090f\u0915 \u0932\u0940\u0917\u0932 \u0928\u094b\u091f\u093f\u0938 \u092d\u0947\u091c\u093e \u0917\u092f\u093e \u0939\u0948. \u0910\u0938\u093e \u091c\u0928\u0924\u093e \u091f\u0940\u0935\u0940 \u0938\u0947 \u091c\u0941\u0921\u093c\u0940 \u0915\u0941\u091b \u0916\u092c\u0930\u094b\u0902 \u0915\u0947 \u092d\u0921\u093c\u093e\u09384\u092e\u0940\u0921\u093f\u092f\u093e \u092a\u0930 \u092a\u094d\u0930\u0915\u093e\u0936\u0928 \u0915\u0947 \u0915\u093e\u0930\u0923 \u0915\u093f\u092f\u093e \u0917\u092f\u093e \u0939\u0948. \u091c\u0928\u0924\u093e \u091f\u0940\u0935\u0940 \u0926\u094d\u0935\u093e\u0930\u093e \u092a\u094d\u0930\u0947\u0937\u093f\u0924 \u0932\u0940\u0917\u0932 \u0928\u094b\u091f\u093f\u0938 \u092e\u0947\u0902 \u0915\u0939\u093e \u0917\u092f\u093e \u0939\u0948 \u0915\u093f \u0907\u0928 \u0916\u092c\u0930\u094b\u0902 \u0915\u0947 \u0915\u093e\u0930\u0923 \u091c\u0928\u0924\u093e \u091f\u0940\u0935\u0940 \u0914\u0930 \u0907\u0938\u0915\u0947 \u092e\u0948\u0928\u0947\u091c\u092e\u0947\u0902\u091f \u0915\u093e \u0915\u093e\u092b\u0940 \u0928\u0941\u0915\u0938\u093e\u0928 \u0939\u094b \u0917\u092f\u093e \u0939\u0948. \u0932\u0940\u0917\u0932 \u0928\u094b\u091f\u093f\u0938 \u0915\u0940 \u092a\u0942\u0930\u0940 \u0915\u093e\u092a\u0940 \u0907\u0938 \u0924\u0930\u0939 \u0939\u0948-<\/p>\n","protected":false},"author":2,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[22],"tags":[],"class_list":["post-928","post","type-post","status-publish","format-standard","hentry","category-print"],"aioseo_notices":[],"_links":{"self":[{"href":"https:\/\/www.bhadas4media.com\/old1\/wp-json\/wp\/v2\/posts\/928","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/www.bhadas4media.com\/old1\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/www.bhadas4media.com\/old1\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/www.bhadas4media.com\/old1\/wp-json\/wp\/v2\/users\/2"}],"replies":[{"embeddable":true,"href":"https:\/\/www.bhadas4media.com\/old1\/wp-json\/wp\/v2\/comments?post=928"}],"version-history":[{"count":0,"href":"https:\/\/www.bhadas4media.com\/old1\/wp-json\/wp\/v2\/posts\/928\/revisions"}],"wp:attachment":[{"href":"https:\/\/www.bhadas4media.com\/old1\/wp-json\/wp\/v2\/media?parent=928"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/www.bhadas4media.com\/old1\/wp-json\/wp\/v2\/categories?post=928"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/www.bhadas4media.com\/old1\/wp-json\/wp\/v2\/tags?post=928"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}