WWW.LIVELAW.

IN
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI
EXTRA ORDINARY WRIT JURISDICTION
WRIT PETITION NO.___________ OF 2017
IN THE MATTER OF A PUBLIC INTEREST LITIGATION
IN RE:-
ADV. GURMEET SINGH ….PETITIONER
VERSUS
FACEBOOK INDIA PVT. LTD.& ORS. ….RESPONDENTS

INDEX
S.NO. PARTICULARS PAGES

1. Notice of motion 2
2. Urgent application 3
3. Memo of Parties. 4
4. Synopsis/List of Dates and Events 5

5. WRIT PETITION U/A 226 OF THE 6 - 22

CONSTITUTION OF INDIA IN PUBLIC
INTEREST SEEKING DIRECTIONS
QUA RESPONDENTS DIRECTING THEM NOT TO
POST/ UPLOAD, ALLOW OR FACILITATE
UPLOADING ANY MATERIAL PERTAINING
TO “BLUE WHALE (GAME / CHALLANGE)”
AND TO IMMIDIATELY REMOVE ANY
MATERIAL PERTAINING TO SAME & OTHER
RELEIFS (Detailed prayer in prayer clause of petition)

6. Affidavit in support. 23 - 24

AS PETITIONER (ADVOCATE) IS FILING PRESENT PETITION “IN

PERSON” THEREFORE NO VAKALATNAMA IS REQUIRED.

DATED: 16.08.2017
NEW DELHI
Through Counsel :-

GURMEET SINGH, ADVOCATE, PETITIONER IN PERSON

For M/S J. PAL &ADVOCATES, Advocates and Legal Consultants,
OFFICE :- D, 10, L.G.F., GREEN PARK MAIN,
NEW DELHI – 110016.
CHAMBER:- LAWYERS CHAMBER NO.99,
CIVIL WING, TIS HAZARI COURTS,
DELHI – 110054.
MOBILE NO.:- +91 8750002000
 WWW.LIVELAW.IN
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI
EXTRA ORDINARY WRIT JURISDICTION
WRIT PETITION NO.___________ OF 2017
IN THE MATTER OF A PUBLIC INTEREST LITIGATION
IN RE:-
ADV. GURMEET SINGH ….PETITIONER
VERSUS
FACEBOOK INDIA PVT. LTD.& ORS. ….RESPONDENTS

NOTICE OF MOTION

To

The Nominated Counsel,

Delhi High Court,
New Delhi

Sir,

That the petitioner is filing the abovenoted Petition before this

Hon’ble Court which is likely to be listed on 16/08/2017 itself or any date
thereafter convenient to this Hon’ble Court.
Kindly acknowledge the receipt of advance copy of the complete
set of the paper book as per rules.

DATED: 16.08.2017
NEW DELHI

Through Counsel :-

GURMEET SINGH, ADVOCATE, PETITIONER IN PERSON

For M/S J. PAL &ADVOCATES, Advocates and Legal Consultants,
OFFICE :- D, 10, L.G.F., GREEN PARK MAIN,
NEW DELHI – 110016.
CHAMBER:- LAWYERS CHAMBER NO.99,
CIVIL WING, TIS HAZARI COURTS,
DELHI – 110054.
MOBILE NO.:- +91 8750002000
 WWW.LIVELAW.IN
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI
EXTRA ORDINARY WRIT JURISDICTION
WRIT PETITION NO.___________ OF 2017
IN THE MATTER OF A PUBLIC INTEREST LITIGATION
IN RE :-
ADV. GURMEET SINGH ….PETITIONER
VERSUS
FACEBOOK INDIA PVT. LTD.& ORS. ….RESPONDENTS

URGENT APPLICATION
The Deputy Registrar
High Court of Delhi
New Delhi.

Sir,
Will you kindly treat the accompanying petition as urgent as per the rules
and regulations of this Hon’ble Court.
THE GROUNDS OF URGENCY ARE:
That the petitioner has moved the present petition wherein under
Article 226 of constitution of India for seeking urgent directions in the
interest of justice.
Hence the urgency.

DATED: 16.08.2017
NEW DELHI

Through Counsel :-

GURMEET SINGH, ADVOCATE, PETITIONER IN PERSON,

For M/S J. PAL &ADVOCATES, Advocates and Legal Consultants,
OFFICE :- D, 10, L.G.F., GREEN PARK MAIN,
NEW DELHI – 110016.
CHAMBER:- LAWYERS CHAMBER NO.99,
CIVIL WING, TIS HAZARI COURTS,
DELHI – 110054.
MOBILE NO.:- +91 8750002000
 WWW.LIVELAW.IN
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI

EXTRA ORDINARY WRIT JURISDICTION

WRIT PETITION NO.___________ OF 2017

WRIT PETITION U/A 226 OF COI IN PUBLIC INTEREST SEEKING

DIRECTIONS TOWARDS RESPONDENTS NOT TO POST/
UPLOAD, ALLOW OR FACILITATE UPLOADING ANY MATERIAL
PERTAINING TO “BLUE WHALE (GAME / CHALLANGE)” AND
TO IMMIDIATELY REMOVE ANY MATERIAL PERTAINING TO
SAME & OTHER RELEIFS (DETAILED PRAYER IN PRAYER
CLAUSE OF PETITION)
MEMO OF PARTIES

GURMEET SINGH, ADVOCATE,

S/O LT. SH. JP SINGH,
AT D-10, GREEN PARK MAIN, NEW DELHI
….PETITIONER IN PERSON
VERSUS

1. FACEBOOK INDIA PVT. LTD.

THROUGH ITS MANAGING DIRECTOR
TWO HORIZON CENTRE, GOLF COURSE ROAD
DLF PHASE-5, SECTOR-43, GURUGRAM,
HARYANA, INDIA

2. GOOGLE INDIA PVT. LTD.

THROUGH ITS MANAGING DIRECTOR,
UNITECH SIGNATURE TOWER-II, TOWER-B, SECTOR-15,
PART-II VILLAGE SILOKHERA,
GURUGRAM, HARYANA, INDIA.

3. YAHOO! INDIA PVT. LTD.

THROUGH ITS MANAGING DIRECTOR,
11TH FLOOR, BUILDING NO 9,TOWER B,
PHASE-III, DLF CYBER CITY GURUGRAM,
HARYANA, INDIA

4. STATE
THROUGH COMMISSIONER OF POLICE
DELHI POLICE, NEW DELHI
….RESPONDENTS
DATED: 16.08.2017
NEW DELHI
Through Counsel :-
GURMEET SINGH, ADVOCATE, PETITIONER IN PERSON,
For M/S J. PAL &ADVOCATES, Advocates and Legal Consultants,
OFFICE :- D, 10, L.G.F., GREEN PARK MAIN,
NEW DELHI – 110016.
MOBILE NO.:- +91 8750002000
 WWW.LIVELAW.IN
SYNOPSIS / LIST OF DATES AND EVENTS:-

The petition will directly benefit the citizens of India at large.

That the Petitioner is a Practicing Advocate at Delhi, basically in Hon’ble

Delhi High Court and other District Courts Of Delhi.

That recently it has come to the knowledge of the Petitioner that there is a

game / challenge namely “blue whale” Game / Challenge.

That the public at large and specially children below the age of 18 are

constantly trying to play the said game / challenge and have succumbed to

grevious injuries and even death. The respondents No. 1,2,3 are major

websites and have major content about the blue whale (challenge / game).

While Respondent No. 4 is the State being impleaded through

Commissioner of Police, Delhi. Till now there are so many deaths in the

name of “Blue Whale (Challenge / Game)”. It would be practical,

suggested and in the interest of justice that the respondents are restrained

not to post / allow to post, upload / allow to upload any material /

information pertaining to the Blue Whale (Challenge / Game). As it is the

prime duty of the Respondent No. 4 to see the health / life and safety of

the Citizens of India, it is further the need of the hour that Respondent No.

4 be directed to appoint a special team (comprising of atleast 5 members

not less than a rank of an Inspector) to oversee that the Respondent No.1,

2, 3 complies with the aforesaid to its complete letter and spirit.

Hence this Petition.

 WWW.LIVELAW.IN
IN THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI
EXTRA ORDINARY WRIT JURISDICTION
WRIT PETITION NO.___________ OF 2017
IN THE MATTER OF A PUBLIC INTEREST LITIGATION
IN RE :-
ADV. GURMEET SINGH ….PETITIONER
VERSUS
FACEBOOK INDIA PVT. LTD.& ORS. ….RESPONDENTS

WRIT PETITION U/A 226 OF THE CONSTITUTION OF INDIA

IN PUBLIC INTEREST SEEKING DIRECTIONS TOWARDS
RESPONDENTS NOT TO POST/ UPLOAD, ALLOW OR
FACILITATE UPLOADING ANY MATERIAL PERTAINING TO
“BLUE WHALE (GAME / CHALLANGE)” AND TO
IMMIDIATELY REMOVE ANY MATERIAL PERTAINING TO
THE SAME & OTHER RELEIFS (DETAILED PRAYER IN
PRAYER CLAUSE OF THE PRESENT PETITION)

TO, THE HON’BLE CHIEF JUSTICE AND HER OTHER

COMPANION JUDGES OF HON’BLE DELHI HIGH COURT.

MOST RESPECTFULLY SHOWETH:

1. That the Petitioner has no personal interest in the outcome of the

petition. The petition is not guided by self-gain or for the gain of any
other person or institution or body and there is no motive other than of
public interest in filing the writ petition.

2. The cause of the writ petition arises from the rising deaths from a
game / challenge namely Blue Whale. The petition will directly benefit
the citizens of India at large. That the Petitioner is a Practicing Advocate
at Delhi, basically in Hon’ble Delhi High Court and other District Courts
Of Delhi. That recently it has come to the knowledge of the Petitioner that
there is a game / challenge namely “blue whale” Game / Challenge
through GOOGLE, FACEBOOK and YAHOO. That the public at large
and specially children below the age of 18 are constantly trying to play
the said game / challenge and have succumbed to death and grevious
injuries. The respondents No. 1,2,3 are major websites and have major
content about the blue whale (challenge / game). While Respondent No. 4
is the State being impleaded through Commissioner of Police, Delhi. Till
 WWW.LIVELAW.IN
now there are so many deaths in the name of “Blue Whale (Challenge /
Game)”. It would be practical, suggested and in the interest of justice that
the respondents are restrained not to post / allow to post, upload / allow to
upload any material / information pertaining to the Blue Whale
(Challenge / Game). As it is the prime duty of the Respondent No. 4 to
see the health / life and safety of the Citizens of India, it is further the
need of the hour that Respondent No. 4 be directed to appoint a special
team (comprising of atleast 5 members not less than a rank of an
Inspector) to oversee that the Respondent No.1, 2, 3 complies with the
aforesaid to its complete letter and spirit.

3. That the orders sought in the writ petition shall affect the
Respondents herein and the prayer is qua the respondents. To the
knowledge of the Petitioner, no other persons/bodies/institutions are likely
to be affected. There are so many children and people being adversely
affected by this menace namely “blue whale challenge/game” and they do
not even know that the same will cost their life and their families will
suffer heavily. All of citizens of India will be benefitted if the said menace
is stopped. That to the best of knowledge of the Respondents have done
nothing to curb the menace and therefore the present petition is the need
of the hour. Hence this petition.

4. That the orders sought in the writ petition shall affect the
Respondents herein and the prayer is qua the respondents. To the
knowledge of the Petitioner, no other persons/bodies/institutions are likely
to be affected.

5. That the petitioner is a Citizen of India and operates from the

address as mentioned in the memo of parties. The Petitioner is a
practicing advocate in Delhi and practices at Hon’ble Delhi High Court,
all District Courts of Delhi. The present Petition has been moved with a
view to help all the citizens of India and also with a view to curb the
menace caused by the Blue Whale Challenge / Game. However if this
Hon’ble Court is of the opinion that the same deserves dismissal with
costs, in the said case the Petitioner will abide by all / any conditions
 WWW.LIVELAW.IN
imposed by this Hon’ble Court and will pay the cost so imposed by this
court.

6. That honestly the Petitioner is in no position to direct the

Respondents to do the aforesaid as prayed vide the present petition and
the petitioner tried calling the landlines numbers given on various
websites but the same were not reachable. 0124-3929600 was the number
given of yahoo but the same was not reachable. +91 124 451 2900 was the
number given of google but the same was not reachable. The petitioner
could not trace phone number of facebook. Further keeping in mind the
urgency the petitioner is filing the present petition.

7. That the petitioner has not filed any PIL ever in his name and
therefore no details can be given as per rules.

8. DETAILS ABOUT THE PETITION :-

BLUE WHALE EXPLAINED:-

The Blue Whale Game (Russian: Синий кит, Siniy kit) also "Blue Whale
Challenge", is an Internet "game" that is claimed to exist in several
countries. The game allegedly consists of a series of tasks assigned to
players by administrators during a 50-day period, with the final challenge
requiring the player to commit suicide. The term "Blue Whale" comes
from the phenomenon of beached whales, which is linked to suicide. Blue
Whale began in Russia in 2013 with "F57", one of the names of the so-
called "death group" of the VKontakte social network, and allegedly
caused its first suicide in 2015. Philipp Budeikin, a former psychology
student who was expelled from his university, claimed that he invented
the game. Budeikin stated that his purpose was to "clean" the society by
pushing to suicide those he deemed as having no value.

"GAME" STRUCTURE :-

The game is based on the relationship between the challengers (also called
players or participants) and the administrators. It involves a series of
duties given by the administrators that players must complete, usually one
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per day, some of which involve self-mutilation. Some tasks can be given
in advance, while others can be passed on by the administrators on that
day, the last task being suicide.

The list of tasks, to be completed in 50 days, includes waking up at 4:20

A.M., climbing a crane, carving a specific phrase on the person’s own
hand or arm, doing secret tasks, poking a needle to the arm or leg,
standing on a bridge and roof, listening to music, and watching videos
sent to the challengers by the administrator. One of these music videos
was originally for Norwegian singer Emilie Nicolas' upbeat song
"Pstereo" (filmed in Scotland). It had been dubbed by the administrator
and set to BENY's hauntingly somber remix of Australian singer Sarah
Blasko's country-folkish song "All I Want" (video filmed in Victoria,
Australia).

To update this Hon’ble Court about the steps as elucidated over Google,
yahoo and Facebook (as available at 11 pm on 15.08.2017) are:-
[Omitted]

A prospective player -- could be anyone, teenagers and adults alike -- uses

certain hashtags on social media platforms to show their interest in taking
up the challenge.

Curators -- people who give instructions -- find these interested people

using those hashtags and get in touch with them.

The players and curators converse -- on Facebook, Twitter, Instagram,

Snapchat or even WhatsApp -- and the curators assign tasks to the
players.

The players are to complete the tasks and provide photographs and videos
to the curator to prove they've completed the task successfully.

Curators and players eventually converse on Skype, and possibly the

curators get personal information from the players including their private
mobile numbers.
 WWW.LIVELAW.IN
Chances are that curators even manage to get nude images of the players
or make them share their secrets, those secrets with which they could be
blackmailed in case they try to leave the challenge.

On the 50th day, the assigned task would be to jump off a high-rise, and
many players end up obeying the curator.

REPORTED CASES:-

INDIA:-

On 15.08.2017, it came to light that a day after a 19-year-old youth fell to

his death from the terrace of an eatery in Hauz Khas, police are scanning
CCTV footage from 25 restaurants nearby. They suspect that the youth,
son of a former Manipur minister, was either already drunk or unwell
when he came to the restaurant. CCTV footage show him staggering his
way up the stairs. Acting on a hunch that Siddharth Singh might be a
victim of the notorious Blue Whale game challenge, police are also
checking his phone and laptop. The game allegedly consists of a series of
tasks assigned to players by administrators during a 50-day period, with
the final challenge requiring the player to commit suicide. The term "Blue
Whale" comes from the phenomenon of beached whales, which is linked
to suicide.

Class 10 boy in West Bengal killed himself on Saturday while a class 5

student in Dehradun was stopped from taking the extreme step by his
school authorities on Friday. According to people in the know, both
played Blue Whale Challenge, the lethal online game which provokes
players to do daring, self-destructive tasks for 50 days before taking the
“winning” step of killing themselves.

On 30 July 2017, a 14-year-old boy committed suicide by jumping from

the seventh floor of an Andheri (East) building in the city of Mumbai.
Maharashtra state Chief Minister Devendra Fadnavis blamed the suicide
on the Blue Whale game, though the Mumbai Police said they had not
found evidence that the teenager had played the game.
 WWW.LIVELAW.IN
On 10 August 2017, a Class VII student in the city of Indore, State of
Madhya Pradesh, was pulled away by a group of students, before he could
take the final suicide leap, off the third floor of the Chamali Devi Public
School. The boy apparently recorded the whole 50 stages of the game, in
his school diary.

On 10 August 2017, a 14-year-old boy on the way to finish the Blue

Whale challenge was rescued by the Maharashtra Police, who intercepted
the bus in which he was traveling to Pune, from his home town of
Solapur. After the boy went missing, his parents started enquiring with his
friends when they came to know that he was playing the Blue Whale
Challenge.

On 12 August 2017, a tenth grade student from Anandpur, West

Midnapore district of West Bengal allegedly committed suicide as a result
of playing the game. His body was discovered in the bathroom, with his
face covered with a plastic bag tied around his neck by a cotton cord.

ARGENTINA

In San Juan Province, Argentina, a 14-year-old boy was admitted to

intensive care after participating in Blue Whale.

In La Plata, the grandparents of a 12-year-old girl complained to a police

station and expressed concern that she had wounded her arm with a sharp
object due to Blue Whale.

On 27 June 2017, 16-year-old Benjamín Palavecino died in the San

Martín de Paraná hospital in the province of Entre Ríos. He had been
hospitalized since 31 May 2017, after attempting to complete the final
suicide challenge.

BRAZIL

In Brazil, the game left victims in Mato Grosso, and in the cities of
Uberlândia, Manhuaçu, Pará de Minas and Belo Horizonte, in Minas
 WWW.LIVELAW.IN
Gerais, as well as in Feira de Santana, Bahia. In Juazeiro, also in Bahia, a
girl supposedly disappeared because of the game. In Rio de Janeiro, a
mother managed to prevent the suicide of her daughter who played Blue
Whale. In the state of Paraná, the game claimed another victim in
Florestópolis. In Maceió, Deputy Pastor João Luiz (Christian Social
Party) reported in the Legislative Assembly of Alagoas that his niece
committed suicide under the influence of the game.

In Paulista (Pernambuco), a girl gave testimony after being threatened in

the challenge of the Blue Whale, and in Recife a 19-year-old girl got to
the penultimate stage of the game. A 15-year-old student living in the
municipality of Cabo de Santo Agostinho in the Recife metropolitan area
was found by a man when she was on the parapet of the Buarque de
Macedo Bridge in Recife, preparing to jump from it. With several cuts on
her arms, including one in the shape of a whale, she was thought to be
attempting to complete the last phase of the challenge.

In the state of São Paulo, in the capital, lovers Luis Fernando Hauy
Kafrune and Kaena Novaes Maciel, aged 19 and 18, stayed at Maksoud
Plaza, a luxury hotel in the region of the Paulista Avenue, where Luis
killed Kaena with a bullet in the head and then committed suicide.
Authorities linked this crime with Blue Whale. A 17-year-old boy from
Bauru, a town from São Paulo, wrote on Facebook "A culpa é da baleia"
("Blame it on the whale") minutes before attempting to jump an overpass,
where he was saved by firefighters.

In the Federal District, on 5 May 2017, four hearing impaired adolescents

playing Blue Whale were prevented by the Military Police from
committing suicide. In Estrela (Rio Grande do Sul) a mother prevented
the suicide of her daughter, who played Blue Whale.

In Teófilo Otoni, in the region of Vale do Mucuri, Minas Gerais, a 17-

year-old female participant of Blue Whale jumped from the six-meter wall
of the property where she lives with her family. The young woman
survived and was hospitalized. The teenager told the police that she had
already cut her arms because of the game and that she had been given the
challenge of taking her own life.
 WWW.LIVELAW.IN
In Paraíba, police identified 20 young people involved with the game. In
Pernambuco, seven were identified. Altogether, seven Brazilian states had
cases of suicide and mutilation thought to be connected with the game.

BULGARIA

The first news about Blue Whale appeared in mid-February 2017. The
emergency was faced by the Safer Internet Centre, established under the
Safer Internet plus Programme of the European Commission when "this
sensationalistic story was inflated by a number of our clickbait websites
creating a wave of panic among parents", as the Centre Coordinator
Georgi Apostolov reported. "We decided not to initiate contact directly
with the media since this would attract additional interest and could
mislead the public into believing the story to be somehow true. As the
hype was magnified by thousands sharing the story on the social
networks, we just published a warning on our website and spread the link
in comments under all shared in Facebook articles and posts. Then the
mainstream media themselves started asking us for interviews and quoting
our conclusions that it evidently was a hoax." Two discussion groups
about suicides were opened on Facebook, but quickly reported and
deleted. The diffusion of the viral news was stopped within two weeks.
Later, when a sensationalist piece in the Romanian newspaper Gandul
caused five more articles in Bulgaria reporting the challenge as real,
media again circulated SIC's positions and the hoax was stopped
immediately.

CHILE

In the Chilean city of Antofagasta, a mother reported to the police that her
12-year-old daughter had 15 cuts on her arm that formed the design of a
whale. After being interviewed by police officers, she confessed that she
followed game administrator's instructions while playing this game.

A 13-year-old girl in Padre Las Casas played the game along with three
other friends. The girl reached the tenth stage, making cuts in her arms.
 WWW.LIVELAW.IN
An 11-year-old boy in Temuco accepted an invitation to join the game on
Facebook from an unidentified woman, but declined to participate after
being contacted by a profile named "Ballena Azul".

CHINA

In Ningbo City, Zhejiang, a suicide group was founded by a 10-year-old

girl who posted several photos of her self-mutilation related to the Blue
Whale. Since then authorities began to monitor mentions of the game on
forums and live broadcasts.

During the Summer of 2017, Chinese authorities became increasingly

concerned with the link between the destructive Blue Whale "game" and
the budding self-harm trend of "human embroidery"—a form of self-harm
popular among teenagers and linked with depressive social media posts.

COLOMBIA

The Criminal Investigation Directorate (Dijin) of the National Police of

Colombia began an investigation into three adolescent deaths that could
be related to the game.

GEORGIA

On 27 May 2017, Rustavi 2 TV reported that a 12-year-old girl tried to

commit suicide, allegedly as part of the game. The girl jumped from the
fifth floor but survived and is undergoing medical treatment at hospital
with multiple injuries and traumas. Police have launched an investigation
into the case, but no official statements have been made.

ITALY

In Italy, press coverage of Blue Whale first appeared on 3 June 2016, in

the newspaper La stampa, which described the challenge as "a bad joke".
The challenge was mentioned again on 3 March 2017, in the national
newspapers Il Giornale and Il Messaggero. This time the challenge was
described as a real Russian "game", with 50 strict rules and powerful
tutors. A few days later, the suicide of a teenager in Leghorn was linked to
the challenge by some newspapers, but an official declaration from the
 WWW.LIVELAW.IN
Leghorn police denies that: "It is a private tragedy, totally due to familiar
reasons".

The debunking site BUTAC reported the total lack of evidence supporting
the existence of the game. On 14 May 2017, a TV report by Le Iene about
the Blue Whale on the national channel Italia again linked the challenge to
the suicide in Leghorn. The report showed several suicide scenes, mostly
from videos on LiveLeak depicting adults unrelated to the challenge,
describing the footage as evidence of teenagers playing the game. The
report interviewed a schoolmate of the Leghorn teenager, two mothers of
Russian girls who supposedly took part in the game, and the founder of
the Russian Center for the safety of children from internet crimes.
Following the report, coverage of the challenge in the Italian media
increased, with many outlets describing it as real. Some published the full
list of 50 rules. There was a sharp rise in Google searches for the
challenge, and some panic.

On 15 and 16 May, newspapers announced the arrest of Budeikin, without

saying that it happened months before. His unconfirmed statements about
his supposed victims being "genetical rubbish" were reported as real.
Paolo Attivissimo, a journalist and debunker of hoaxes, described the
game as "a death myth dangerously exaggerated by sensationalist
journalism". Police received calls from terrified parents and teachers, and
there were reports of teenagers taking part in the challenge. These
included several cases of self-mutilation and attempted suicide. Most
reports were considered to be false or exaggerated. Alleged participants
came from all over Italy: Ravenna, Brescia and Siracusa. On the 22nd the
Polizia Postale declared that they had received 40 alarms. On the 24th this
number was increased to 70. On its website the Polizia Postale defines
Blue Whale as "a practice that seems to possibly come from Russia" and
offers advice to parents and teenagers. Several alleged cases have since
been described by newspapers.

KENYA
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In Nairobi County, Jamie Njenga, a Form Two student at J. G. Kiereini
Secondary School in Kiambu County, had played the Blue Whale
challenge. He committed suicide on 3 May. He hanged himself on the
balcony of a hotel owned by his grandfather in the city centre.

PARAGUAY

Federico Pedro Aguilera, a 22-year-old computer scientist, was found

with a sprat, a type of sword, that pierced his chest in Coronel Bogado
after playing Blue Whale.

PORTUGAL

Irina Kornutyi, an 18-year-old girl, was admitted to hospital with

mutilations on her body in Albufeira after she threw herself from an
overpass to the railway line. Police, parents and friends said that the girl
had been motivated to do so by a person on the Internet named as "Blue
Whale". In an interview with RTP, she said that she felt alone, and
lacking affection.

A 15-year-old boy from Sines was admitted to the Setúbal Hospital after
having "drawn" a whale on his arm with a sharp object. There are already
at least ninety victims of the Blue Whale challenge identified in Portugal.

RUSSIA

In March 2017, authorities in Russia were investigating approximately

130 separate cases of suicide related to the phenomenon. In February, 15-
year-old Yulia Konstantinova and 16-year-old Veronika Volkova threw
themselves off the top of a 14-story building in Irkutsk, Siberia after
completing 50 tasks sent to them. Before they killed themselves together,
Yulia and Veronika left messages on their pages on social networks. Yulia
published the photo of a large blue whale and then wrote "End". Veronika
had previously posted things like "Do you feel that you become useless?"
and "I am just a ghost". On the day of her death she wrote "Sense is lost...
End". Also in February, a girl known as Ekaterina, 15, was in critical
condition after throwing herself out of an apartment and falling on snow-
covered ground in the town of Krasnoyarsk, also in Siberia.
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On 11 May 2017, Russian media reported that Philipp Budeikin "plead
guilty to inciting teenagers to suicide," having described his victims as
"biological waste" and claiming he was "cleansing society." He was held
at Kresty Prison in St Petersburg with charges of "inciting at least 16
teenage girls to kill themselves."

On 26 May 2017, Russian Duma (parliament) passed a bill introducing

criminal responsibility for creating pro-suicide groups on social media, in
the wake of 130 teen deaths linked to the Blue Whale suicide challenge.
On 7 June 2017, President Putin signed a law imposing criminal penalties
for inducing minors to suicide. The law imposes a maximum punishment
of six years in prison.

On 8 June 2017, Ilya Sidorov, 26, one of the game's administrators, was
arrested in Moscow.

SAUDI ARABIA

On 5 June 2017, a 13-year-old boy 'Metlaq Affas Albugami' committed

suicide in his room, where his body was discovered by his mother. The
boy used his PlayStation wires to commit suicide. His death has been
linked to Blue Whale. He is the first known victim in the country.

SERBIA

A 13-year-old boy in Velika Plana injured his hand, telling his parents
that he had done so because of Blue Whale. The parents reported the case
to the police.

SPAIN

In Spain, a teenager was admitted to a psychiatric unit of a Barcelona

hospital after her family said she started playing Blue Whale.

UNITED STATES
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In the city of San Antonio, Texas, the body of a 15-year-old was found on
8 July 2017. A cellphone had broadcast the teen's suicide, which is
believed to be related to the game.

It is also alleged that the game was tied to a teen's death in Atlanta,
Georgia.

URUGUAY

In the city of Rivera, 450 kilometers from Montevideo, a 13-year-old girl

was hospitalized at a local hospital after employees of the school she
attended reported injuries to her left arm. Adolescents victimized by the
Blue Whale game are being investigated in six departments: Montevideo,
Canelones, Colonia, Río Negro, Salto and Rivera.

VENEZUELA

A 15-year-old student from Nazareth College in the city of Puerto Ordaz

committed suicide after taking part in Blue Whale on the night of 27 April
2017.

In Russia in 2016, Blue Whale came into broader use among teenagers
after a journalist brought attention to it through an article that linked many
unrelated suicide victims to the Blue Whale, creating a wave of moral
panic in Russia. Later, Budeikin was arrested and pled guilty to "inciting
at least 16 teenage girls to commit suicide", leading to Russian suicide
prevention legislation and renewed world-wide concern over the Blue
Whale phenomenon. It has also been linked to other rising self-harm
trends, such as "human embroidery" in China.

REACTIONS ACROSS THE WORLD:-

In March 2017, Romanian Minister of Internal Affairs Carmen Dan

expressed her deep concerns about the phenomenon. Mayor of Bucharest
Gabriela Firea described the game as "extremely dangerous".

The game has caused significant concern in Western Europe, including

France and the United Kingdom.
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In Brazil, in response to the game, a designer and a publicity agent from
São Paulo created a movement called Baleia Rosa (Pink Whale), which
became viral and relied on the collaboration of hundreds of volunteers.
The movement is based on positive tasks that value life and combat
depression. Also in Brazil, Sandro Sanfelice created the movement
Capivara Amarela (Yellow Capybara), which proposes to "combat the
Blue Whale game" and guide people seeking some kind of help.
Participants are separated between challengers, who are the people who
seek help, and the healers, who are kind of godfathers of these people. An
Adventist school in southern Paraná, in partnership with other education
networks, also sought to reverse the situation by proposing another charity
game, the "Jonas Challenge" (referring to the biblical character Jonah,
who was vomited up by a large fish three days after being swallowed by
it). Other games created in Brazil in response to the Blue Whale were the
Baleia Verde (Green Whale) and the Preguiça Azul (Blue Sloth). In the
United States, one site, also called the "Blue Whale Challenge" does not
immediately identify itself as an effort to combat the game, but offers fifty
days of challenges that promote mental health and well-being.

Author Glória Perez stated on 21 April that she plans to include the Blue
Whale game in her new telenovela, A Força do Querer. The media also
stressed that the phenomenon coincided with the controversy surrounding
the web television series 13 Reasons Why, which addresses the issue of
teen suicide.

In Belo Horizonte and Recife metropolitan area in Brazil, many schools

promoted lectures to talk about the Blue Whale game. The Police
Specialized in High Technology Crime Repression (Dercat) in Piauí is
preparing a digital primer to warn young people about the dangers of the
game.

In May 2017, authorities of the Mexican state of Michoacán issued an

alert warning about the possibility of the Blue Whale challenge to invade
the country.

In May 2017, Tencent, China's largest Internet service portal, closed 12

suspicious Blue Whale-related network groups on its social networking
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platform QQ, as the number of this kind of groups is on the rise. The
search results of related keywords was also blocked in QQ.

9. That in order to set the things in right perspective it is requested /

suggested that this Hon’ble Court may be pleased to:-

A. Restrain the Respondents not to post / allow to post, upload / allow

to upload, facilitate to upload / post, any material / information / link etc.
pertaining to the Blue Whale (Challenge / Game).

B. Direct Respondents to immediately block, take down, ban any

content / post/ web link/ material etc. pertaining to the “Blue Whale
(Challenge / Game)”

C. Direct the Respondent No. 4 to appoint a special team (comprising

of atleast 5 members not less than a rank of an Inspector) to oversee that
the Respondent No.1, 2, 3 complies with the aforesaid Point “A,B” as also
explained in Para 9 of this petition, to its complete letter and spirit.

D. As this Hon’ble Court may deem it appropriate and just in the

interest of justice and as it is convenient to this Hon’ble Court.

10. This Hon’ble Court has the jurisdiction to deal with the matter.

11. That no similar petition / writ has earlier been filed / pending for
the same relief either before any court by the petitioner.

12. The present petition is maintainable as the same is in Public

Interest and in compliance of the rules of as described in
NOTIFICATION No. 451/ Rules / DHC Dated 25.11.2010 and Delhi
High Court (Public Interest Litigation) Rules, 2010.
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PRAYER

That the Petitioner in view of the above requests this Hon’ble Court
to consider the requests / suggestions as made in para 9 i.e. Restrain the
Respondents not to post / allow to post, upload / allow to upload, facilitate
to upload / post, any material / information, link etc. pertaining to the Blue
Whale (Challenge / Game) and further Direct Respondents to immediately
block, take down, ban any content / post/ web link/ material etc.
pertaining to the “Blue Whale (Challenge / Game)” and further direct the
Respondent No. 4 to appoint a special team (comprising of atleast 5
members not less than a rank of an Inspector) to oversee that the
Respondent No.1, 2, 3 complies with the aforesaid Point “A, B” Para 9 of
this petition, to its complete letter and spirit of this Petition and direct
accordingly AND / OR pass appropriate orders accordingly.

Any other order(s) which this Hon’ble Court deem fit and proper in
the facts and circumstances of the case may also be passed in the favour
of the Petitioner and against the Respondents.

DATED: 16.08.2017
NEW DELHI
Through Counsel :-

GURMEET SINGH, ADVOCATE, PETITIONER IN PERSON,

For M/S J. PAL &ADVOCATES, Advocates and Legal Consultants,
OFFICE :- D, 10, L.G.F., GREEN PARK MAIN,
NEW DELHI – 110016.
CHAMBER:- LAWYERS CHAMBER NO.99,
CIVIL WING, TIS HAZARI COURTS,
DELHI – 110054.
MOBILE NO.:- +91 8750002000
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IN THE HON’BLE HIGH COURT OF DELHI, AT NEW DELHI
EXTRA ORDINARY WRIT JURISDICTION
WRIT PETITION NO.___________ OF 2017
IN THE MATTER OF A PUBLIC INTEREST LITIGATION
IN RE:-
ADV. GURMEET SINGH ….PETITIONER
VERSUS
FACEBOOK INDIA PVT. LTD.& ORS. ….RESPONDENTS

AFFIDAVIT

AFFIDAVIT OF GURMEET SINGH, ADVOCATE, S/O LATE SH. JP

SINGH, AT D – 10, GREEN PARK MAIN, NEW DELHI.

Deponent abovenamed do hereby solemnly affirm and declare as under:-

1. That the deponent is the Petitioner in person in above noted matter

and is well conversant with the facts and circumstances of the case.

2. That I have filed this Public Interest Litigation.

3. That I have gone through the Delhi High Court (Public Interest
Litigation) Rules, 2010 and do hereby affirm that the present Public
Interest Litigation is in conformity thereof.

4. That the Petitioner has no personal interest in the outcome of the

petition and neither petitioner nor anybody in whom the Petitioner
is interest is interested in would in any manner benefit from the
relief sought in the present litigation save as a member of the
General Public. The petition is not guided by self-gain or for the
gain of any other person or institution or body and there is no
motive other than of public interest in filing the writ petition.

5. I have done whatsoever inquiry / investigation which was in my

power to do, to collect all data / material which was available and
which was relevant for this Court to entertain the present Petition. I
further confirm that I have not concealed in the present petition any
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data / material / information which may have enabled this Court to
form an opinion whether to entertain this Petition or not and / or
whether to grant any relief or not.

6. That the contents of the annexed Petition are true and correct to the
best of knowledge and belief of the deponent and have been read
over to me in vernacular and understood by me to be true and
correct.

7. The contents of the annexed Petition may kindly be read as part and
parcel of the said Affidavit.

SELF ATTESTED BY DEPONENT

DEPONENT.
VERIFICATION:-

Verified at Delhi on 16.08.2017, that the contents of the above affidavit

are true and correct to the best of my knowledge and nothing material has
been concealed therefrom. Verified at Delhi on

DEPONENT.