legal notice for posting of defamatory content : 10 April 2012, To, Mr. Yashwant Singh, CEO and Editor, Bhadas4Media.com, New Delhi. Sub: Legal Notice for cease and desist from publishing of defamatory articles or blogs about Sh. Nirmaljit Singh Narula on Bhadas4Media.com, Sir, Under the instructions of my client, Sh. Nirmaljit Singh Narula, S/o Sh. S.S. Narula, resident of E – 66, Greater Kailash – 1, New Delhi(hereinafter referred to as “our client”); I thereby shall serve upon you the following legal notice-
Our client is highly revered spiritual guide, renowned worldwide for his spiritual discourses as “Nirmal Baba” and has lacs of followers in India and abroad. Our client recently learnt that you have posted extremely defamatory and illegal contents/articles against our client on your own website of Bhadas4Media.com titled “Fraud Nirmal Baba” at the following links –
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http://bhadas4media.com/article-comment/3127-fraud-nirmal-baba3.html
http://bhadas4media.com/print/3611-fraud-nirmal-baba9.html
http://bhadas4media.com/print/3665-fraud-nirmal-baba-15.html
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http://bhadas4media.com/article-comment/3127-fraud-nirmal-baba3.html
http://bhadas4media.com/print/3611-fraud-nirmal-baba9.html
http://bhadas4media.com/print/3665-fraud-nirmal-baba-15.html
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and various other defamatory links related to our client. The content in these articles published on your website is grossly defamatory, false, without prejudice, and offensive in nature. Please note that publishing such defamatory content or statements about any person is a criminal offence in India and attracts both civil and criminal liabilities under Section 66A of the Information Technology Act, 2000 as well as under Section 499 of the Indian Penal Code.
Please note that on 30th March, 2012 an exparte ad interim restraint order against Hubpages was passed by the Hon’ble High Court of Delhi restraining the hubpages.com from publishing defamatory articles against our client in CS(OS) 871/2012 (Order Attached).
We hereby call upon you to cease and desist from publishing the defamatory content published by you on the website Bhadas4Media.com within 36 hours of receipt of this notice in compliance with the IT (Intermediaries Guidelines) Rules, 2011 and Section 79 of the IT Act, 2000, failing which my client will be constrained to take legal action against you for which you will be solely liable responsible for all acts and consequences following there from.
For any correspondence on this matter, please contact the undersigned.
Yours truly,
Karnika Seth
Please note that on 30th March, 2012 an exparte ad interim restraint order against Hubpages was passed by the Hon’ble High Court of Delhi restraining the hubpages.com from publishing defamatory articles against our client in CS(OS) 871/2012 (Order Attached).
We hereby call upon you to cease and desist from publishing the defamatory content published by you on the website Bhadas4Media.com within 36 hours of receipt of this notice in compliance with the IT (Intermediaries Guidelines) Rules, 2011 and Section 79 of the IT Act, 2000, failing which my client will be constrained to take legal action against you for which you will be solely liable responsible for all acts and consequences following there from.
For any correspondence on this matter, please contact the undersigned.
Yours truly,
Karnika Seth
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