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UILS INTRA DEPARTMENT MOOT COURT COMPETITION’19

IN THE DISTRICT COURT OF JUDICATURE AT NARNIA

MEMORIAL ON BEHALF OF THE PLAINTIFF

SANGWAN SPORTS™………………………………………..PLAINTIFF
(A Private company)
VS.

STATE OF NARNIA……………………………………………DEFENDANTS

Most Respectfully Submitted before the Court of Civil Judge,Narnia


District Courts.

MEMORANDUM ON BEHALF OF PLAINTIFF

DRAWN AND FILED BY THE COUNSELS FOR THE PLAINTIFF

TEAM CODE: 03

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TABLE OF CONTENTS

S. PARTICULARS PAGE
NO. NO.

1. LIST OF ABBREVIATIONS

2. TABLE OF CASES

3. INDEX OF AUTHORITIES

4. STATEMENT OF JURISDICTION

5. STATEMENT OF FACTS

6. ISSUES RAISED

7. SUMMARY OF ARGUMENTS

8. ARGUMENTS ADVANCED
ISSUE I: WHETHER CRICKLORD ACADEMY IS LIABLE FOR
BREACH OF CONTRACT
ISSUE II:WHETHER SANGWAN SPORTS CAN BE MADE LIABLE
FOR DEFAMATION
ISSUE III: WHETHER SANGAN SPORTS IS ENTITLED TO THEIR
CLAIM UNDER CLAUSE (H) OF THE CONTRACT?

9. PRAYER

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LIST OF ABBREVIATIONS

ABBREVIATIONS EXPANSION
& And
AIR All India Reporter
ALL Allahabad
Anr Another
Co Company
Ed Edition
Hon’ble Honorable
Ltd Limited
Ors Others
SC Supreme court
SCC Supreme Court cases
Versus
Vs
IPC Indian Penal Code
CrPC Code of Criminal Procedure
No Number
Cri Criminal

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TABLE OF CASES

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INDEX OF AUTHORITIES

A. BOOKS & TREATISES


1. Prof. T. Bhattocharya, The Indian Penal Code, (4th edition), Central Law
Agency, (2004).
2. S.N. Mishra, The Code Of Criminal Procedure,(19th edition),Central Law
Publications,(2014).
3. K.D. Gaur, Textbook on Indian Penal Code, (5th edition), Universal Law Publishing,
(2016).
4. R.K BANGIA, Textbook on Indian Contract Act,1872.

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STATEMENT OF JURISDICTION
The plaintiff knocks the door of this hon’ble court and invokes its original civil jurisdiction
under the following sections of the CPC, 1908:
9. Courts to try all civil suits unless barred – The Courts shall (subject to the provisions
herein contained) have jurisdiction to try all suits of a civil nature excepting suits of which
their cognizance is either expressly or impliedly barred.
15. Court in which suits to be instituted – Every suit shall be instituted in the Court of
the lowest grade competent to try it.
20. Other suits to be instituted where defendants reside or cause of action arises –
Subject to the limitations aforesaid, every suit shall be instituted in Court within the local
limits of whose jurisdiction.
(a) The defendants or each of the defendants, at the time of the commencement of the suit
actually or voluntarily resides, or carries on business, or personally works for gain, provided
that in such case either the leave of court is given, or the defendants who do not reside, or
carry on business, or personally work for gain, as aforesaid, acquiesce in such institution; or
(b) Any of the defendants, where there are more than one, at the time of the commencement
of the suit actually or voluntarily resides, or carries on business, or personally works for gain,
provided that in such case either the leave of court is given, or the defendants who do not
reside, or carry on business, or personally work for gain, as aforesaid, acquiesce in such
institution; or
(c) The cause of action wholly or partly arises.

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STATEMENT OF FACTS

 Sangwan Sports™ is a private company which is a leading name in production of


various cricket equipment in Hogwarts Republic. Being in business for more than 30
years successfully makes it a very well reputed company.It has been supplying cricket
goods to various cricket academies and associations. It even supplied cricket goods to
BCCI in 2018 for IPL league matches. The company uses Dumbledore wood (a
special quality wood) for making bats & wickets with a special technique which
makes the company stand apart in this field.
 On 20th September, 2019 Sangwan Sports™ entered into a contract with Cricklord
Academy for supplying 200 kits at the price of Rs. 6,00,000/- to the academy by 25th
October, 2019. Cricklord Academy paid an earnest amount of Rs. 1,00,000/- in
furtherance of the contract that was prepared by the representatives of both the parties
and duly signed by both the parties where Clause (g) of the contract mentioned that in
case of non-delivery of kits by the company, on the above mentioned date of the
contract, Cricklord Academy will be entitled to get double the earnest amount paid by
them. Clause (h) stated that if the academy did not pay the full sum on the delivery
date i.e. 25th October, 2019 then Sangwan Sports™ will be entitled to the double of
sum decided for the payment of 200 kits. Clause (i) mentioned that 1/4th of the kits
must be delivered within the initial 15 days of the contract wherein the quality of the
kits shall be checked & the remaining kits shall be delivered altogether on 25th
October, 2019.
 On 5th October, 2019 Sangwan Sports™ delivered 50 kits to the academy. After
which on 7th October, the company got a notice from the academy stating that the
material used in manufacturing of the bats & wickets was not upto the mark and
quality standards that were decided. In reply to the notice, Sangwan Sports™ stated
that they will look into the matter and manufacture the 50 bats & wickets once again
ensuring that the quality is up to the mark
 In furtherance of the same, quality check inspector was sent by the academy to the
company and manufacturing resumed on 10th October in his presence. The said 50
bats and wickets which were found to be of poor quality by the academy were
manufactured again and delivered to the academy on 13th October 2019.
 On the fateful day of 21st October, 2019 a fire broke out in the Head Office and
manufacturing unit of Sangwan Sports™ at around 7:00 pm, burning everything to
ashes. The fire also resulted in the death of 10 employees and 30 others were injured.
The matter became a national headline and was covered by all the leading newspapers
for the next 2-3 days.
 On 23rd October, 2019 Cricklord Academy got to know about the incident from
newspapers and with the matches scheduled in coming days, assumed that the
contract between them and Sangwan Sports™ had become impossible to perform on
the part of the company and thus gave the contract of the remaining kits to Ardhaan
Sports Goods Corporation.

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 Immediately after which, Sangwan Sports™ upon information from its agents in the
business circle, about the academy’s deal with Ardhaan Sports tried to contact
Cricklord Academy but all the attempts to establish a communication with them went
in vain. On 27th October 2019 a press conference was organized by the CEO & Board
of Directors of Sangwan Sports™ after they realized that the Academy had turned
hostile towards them.
 In the press conference which was attended by leading media houses, wherein the
CEO maintained that, “It is very saddening how some associations instead of standing
with us in our hard times betrayed us & backed out from the very contract that bound
us. We, from now onwards shall be more vigilant, keeping in mind the associations,
we shall never cater to in future, considering their track record in failure to perform
their contracts. It is notified upon our partners that associations like these are based on
tenets of betrayal and opportunism. We will be filing a law suit against one of such
associations very soon.”
 The very next day Sangwan Sports™ filed a law suit against Cricklord academy for
breach of contract contending that only their manufacturing unit had caught fire and
they being thorough professionals had already manufactured and stored 130 kits in
their go down in Zirakpur and wanted to deliver the same to the academy. The
company sought payment of compensation as per clause (h) of the contract.
 On 30th October, 2019 a cross suit for defamation against Sangwan Sports™ was
filed by the Academy contending that the statement given by the CEO in the press
conference damaged their reputation & due to the influence of their CEO’s market
presence, other production companies are hesitant to do business with them, further
affecting the tournament’s public image

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ISSUES RAISED

ISSUE I:

WHETHER CRICKLORD ACADEMY IS LIABLE FOR BREACH OF CONTRACT?

ISSUE II:

WHETHER SANGWAN SPORTS CAN BE MADE LIABLE FOR DEFAMATION?

ISSUE III:

WHETHER SANGAN SPORTS IS ENTITLED TO THEIR CLAIM UNDER CLAUSE


(H) OF THE CONTRACT?

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SUMMARY OF ARGUMENTS

1. WHETHER CRICKLORD ACADEMY IS LIABLE FOR BREACH OF


CONTRACT?
Yes, The defendants are liable for breach of contract and the counsel shall submit the
argument in twofolds. Firstly, that the contract is valid as it fulfils all the essentials of a valid
contract and secondly, the defendants have breached the contract by repudiating the contract
to the third party without any information to the plaintiff.

2. WHETHER SANGWAN SPORTS CAN BE MADE LIABLE FOR DEFAMATION?


It is humbly submitted before this Hon’ble court that the plaintiff is not liable for defamation
as the defendant has not come to the court with clean hands. The statements made by the
plaintiff are not defamatory in nature as-The statement is a matter of Truth (A); the statement
made was a fair comment (B).

3. WHETHER SANGAN SPORTS IS ENTITLED TO THEIR CLAIM UNDER


CLAUSE (H) OF THE CONTRACT?

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1. WHETHER THE SANGWAN SPORTS™ IS LIABLE FOR


BREACH OF CONTRACT?

It is humbly submitted that the Defendant No.1 is liable for breach of contract in the instant
case. This submission of the Plaintiff is twofold:

1.1 THAT THE CONTRACT IS VALID.


It is submitted that SECTION 10 OF THE ICA, 1872 states “All agreements are contracts
if they are made by the free consent of the parties competent to contract, for a lawful
consideration and with lawful object, and are not hereby expressly declared to be void.”The
contract between the Plaintiff and Defendant stands valid as it meets all the essentials as
prescribed under the Act to form a contract.
1. AGREEMENT: Section 2(e) states “every promise and every set of promises forming the
consideration for each other is an agreement”.
A promise is a result of a proposal by one person and its acceptance by the other. A proposal
is defined under section 2(a) in the ICA, 1872 as follows:
“When one person signifies to another his willingness to do or to abstain from doing
anything, with a view to obtaining the assent of that other to such act or abstinence, he is said
to make a proposal.”
In the instant case, When the Plaintiff manufactures and even supplies cricket kits to
renounced authorities such as various cricket associations and also is established and reputed
since many years it can only be considered as invitation to treat and not a proposal. The
Proposal is made by Defendant and can be easily put in consideration as stated in the
statement of facts for when the academy desired to place an order of cricket kits to the
plaintiff.
Whereas, acceptance is defined under section 2(b) as:
“When the person to whom the proposal is made signifies his assent thereto, the proposal is
said to be accepted.”
The proposal is accepted by the company as on 20th September, 19 when both the parties
enter into a contract between the Plaintiff and the Defendant No.1.
Therefore, it is a valid Agreement between the parties.
2. FREE CONSENT: Consent UNDER SECTION 13 OF THE ICA, 1872 is defined as
“two or more persons are said to be consent when they agree upon the same thing in the
same sense.”
In the instant case, both the parties agree upon the same thing in the same sense i.e. The
defendants were interested in getting the supply of the same cricket kits which the plaintiff’s
agreed to supply to the academy..
One of the essentials of a valid contract mentioned in Section 10 is that the parties should
enter into the contract with their free consent. According to Section 14, consent is said to be
free when it is not caused by coercion, undue influence, fraud or misrepresentation and
mistake. In the instant case, the consent is free and is not obtained due to any fraud , coercion
or undue influence.

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COMPETENT TO CONTRACT: SECTION11OFTHEICA, 1872 states “ Every person is


competent to contract who is of the age of majority according to law to which he is subject
and who is of sound mind, and is not disqualified from contracting by any law to which he is
subject”
In the instant case both the parties are well reputed and renounced and neither the Plaintiff
nor the Defendant No.1 are of unsound mind or are disqualified by the law to contract.
Hence, the both the parties are competent to contract.
3.LAWFUL CONSIDERATION: Consideration in the ICA, 1872 is defined under Section
2(d) as:“When at the desire of the promisor, the promisee or any other person has done or
abstained from doing, or does or abstains from doing, or promises to do or to abstain from
doing, something, such act or abstinence or promise is called consideration.”
The consideration or object to an Agreement is lawful, unless:-
i.It is forbidden by law
ii.Is of such nature that, if permitted, it would defeat the provisions of any law, or is fraudulent;
or
iii.Involves or implies, injury to the person of another;
iv.The court regards it as immoral, or opposed to public policy
In each of these cases, the consideration or object of an Agreement is said to be unlawful.
Every Agreement of which the object or consideration is unlawful is void.”
In the instant case, the consideration part payment of an earnest amount of rs.1,00,000 at an
advance and part payment on Delivery is to be considered past consideration, which
constitutes as a valid consideration as per the ICA, 1872

4. NOT EXPRESSLY DECLARED TO BE VOID: According to SECTION 2(G) OF ICA,


1872 “An Agreement not enforceable by law is said to be void.”
Void Agreement is an Agreement in which consideration and objects are unlawful in part,
Agreement without consideration, and Agreement in restraint of marriage, Agreement in
restraint of trade,Agreementi n restraint to legal proceedings, Unmeaning agreements,
Wagering Agreements and Agreement to do impossible acts. In the instant case, the
Agreement is that a product will be delivered to the Plaintiff by the Defendants for lawful
consideration and this Agreement is not any of the above stated agreements. Thus this
Agreement stands valid.
And with the above stated arguments it can be easily established that it was a valid contract
which was formed between the two parties satisfying the essentials of a valid contract.

1.2 THAT THE CONTRACT HAS NOT BEEN BREACHED.


“A breach of contract occurs when a party thereto renounces his liability under it, or by his
own act makes it impossible that he should perform his obligations under it or totally or
partially fails to perform such obligations.”
A breach of Contract takes place when a party corresponding consents formally to abandon
his liability under it, or by his own act makes it impossible that he should perform his
obligations under it or fully or partially fails to perform such obligations.
According to the section 39 of the Indian contract Act, “Any intimation whether by words
or by conduct that the party declines to continue with the contract is repudiation, if the result
is likely to deprive the innocent party of substantial the benefit of the contract”
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The counsel for plaintiff would like to place reliance in the case of syed hasan miya zaidi v.
zabir the court was of the view that enshrined U/S 39 of Indian Contract Act, 1872, which
embodies the principle of English law, pertaining to the anticipatory breach of contract i.e.
if one party to a contract resiles from the contract, the other party i.e. the innocent party has
an option. He may accept the repudiation and sue for damages or breach of contract.
Whether or not the time for performance has come or he may if he chooses disregard or
refuse to accept it and then, the contract remains in full effect.
The anticipatory breach simply means that a party is in breach from the moment his
actual breach becomes inevitable
Thus, repudiation can occur when the either party refuses to perform his part, or makes it
impossible for him to perform or even fails to perform his part of contract in each of the cases
in such a manner as to show an intention not to fulfill his part of the contract.
In the instant case the counsel would like to state that since the defendants got to know about
the unfortunate incident it didn’t tried to check upon the status and contact the plaintiff”s in
any way and despite of waiting till the due date of the contract ie when the kits were to be
delivered to the defendants it placed an order of the same to the third party which itself shows
and proves that the defendants have repudiated the contract and without any intimation but
just with its actions has breached the contract while the plaintiffs tried to communicate with
the defendants.
In the case of Food corporation v. J.P Kesharwani , where one party making unilateral
alterations without any intimation to the other and then cancelling the contract, this amounted
to breach (repudiation) therefore it can be correctly stated that, any kind of contract may be
examined as broken once a party refuses to perform under the contract as promised,
regardless of when performance is supposed to occur. This unconditional refusal is known as
a repudiation of contract.
In the case of Universal Cargo in the year 1957 it was held by the Supreme Court that the
“Anticipatory breach means that a party is in breach from the moment that his actual breach
becomes inevitable. Since the reason for the rule is that a party is allowed to anticipate an
inevitable event and is not obliged to wait till it happens, it must follow that the breach which
he anticipates is of just the same character as the breach which would actually have occurred
if he had waited.”

The counsel would also place reliance upon the case ofInternational Contractors Limited v.
Prasanta Kumar Sur, properly analysed, only lays down that in certain circumstances it is
not necessary for the party complaining of an anticipatory breach of contract by the other
party to offer to perform his remaining obligations under the contract in order to show his
readiness and willingness to perform the contract and claim specific performance of the
said contract.
In case of 'Steel Bros and Co. Ltd. v. Dayal Khatav & Co.', 47 Bom 924, emphasising this
distinction Mullah J. observed as follows:
"A good deal was said on both sides as to the rule of 'anticipatory breach' in its relation to C.
I. F. contract. It is now elementary law that where in a contract for sale of goods a buyer
clearly shows his intention not to be bound by it and repudiates the contract it amounts to a
breach of the contract (Indian Contract Act, Section 120). In such a case the seller may
treat the notice of intention as inoperative, in which case he keeps the contract alive for the
benefit of the buyer as well as his own or he may treat the repudiation as wrongful putting an

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end to the contract and may at once bring his action as on a breach of
it. (Indian Contract Act, Section 39). But the repudiation which absolves the seller from the
performance of conditions precedent must have been made before the due date for the
performance of the contract.
In the case of Rajesh Deorao Meshram, ... vs Murlidhar S/O Namdeorao Khangar on 11
December, 2007 the courts was of view that once a party to a contract has repudiated
a contract, it is not necessary for the other party to tender the amount payable under
the contract in the manner provided in the contract in order to successfully claim the
specific performance of the contract. The decision, however, nowhere lays down that where
one party to a contract repudiates the contract, the other party to the contract who claims
specific performance of the contract is absolved from his obligation to show that he was
ready and willing to perform the contract.
Thus the counsel submits that the defendants breached the contract so formed between
the parties.

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2.WHETHER SANGWAN SPORTS ™ CANBE MADE LIABLE FOR


DEFAMATION?

It is humbly submitted before this Hon’ble court that the plaintiff is not liable for defamation
as the defendant has not come to the court with clean hands. The statements made by the
plaintiff are not defamatory in nature as-The statement is a matter of Truth (A); the statement
made was a fair comment (B);
(A) The statement is a matter of truth
i. The counsel on behalf of the plaintiff contends that the words complained of are in
substance and in fact true. The statement made was – “Travel Solutions Private
Limited – a bunch of liars, cheats and thieves with no ethics. The worst company
ever. A statement is true in substance if the erroneous details in no way aggravate the
defamatory character of the statement or alter its nature1 .In the case of Dainik
Bhaskar v. Madhusudan Bhaskar2,it was held that it is not necessary to justify every
detail of the charge, provided that the gist of the libel is proved to be in substance
correct, and that the details, etc., which are not justified, produce no different effect
on the mind of the reader than the actual truth would do.

ii. It is important to mention here that the plaintiff completed the order on time and did
everything to satisfy the plaintiff but the later didn’t even communicated with the
defendant once when they got to know that a fire broke down in their head office and
presumed that they will not be able to complete the order on time and gave it someone
else. The plaintiff has betrayed us when we needed their support and this shows their
opportunistic behaviour. These characteristics are certainly not possessed by a
company which has ethics and consequently it proves that imputation is true. The
statement “the law will not permit a man to recover damages in respect of an injury to
a character which he does not or ought not to possess”3aptly fits on the defendant.
(B) The statement made was a fair comment
i. It is humbly submitted before this Hon’ble Court that the statement made by the
plaintiff was a comment which is a statement of opinion of facts 4(which includes
inference of facts) and the matter alleged to be defamatory is nothing but a fair
comment on a matter of public interest, which a fair minded person can honestly
make on the facts proved.5 Any person, whether he is a private individual has a right
to hold any view he pleases on a matter of public concern, and to express the same.

ii. The matter complained of as defamatory, was an honest expression of opinion made
in good faith and for the good of the public.6 A matter of public interest is a matter

1
Clarke v Taylor, (1836) 2 Bing 654; Sutherland v Stopes, (1925) AC 78 -81.
2
AIR 1991 MP 162.
3
McPherson v. Daniels, (1829) 10 B & C 263.
4
Christile v. Robertson, (1889) 10 New South Wales LR 161.
5
J.B. Jeyaretnam v. Goh ChokTong (1985) 1 MLJ 334.
6
Balasubramania v. Rajagopalachariar, AIR 1944 Mad 484:46 Cr LJ 71.

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which invites public attention, is of public importance7 or in which public is


legitimately concerned8. A man has the right to publish, for the purpose of giving the
public information that which it is proper for the public to know.9It is a matter of
grave public concern that a highly reputed academy like the defendant has failed
miserably in being loyal to the company they are bound in a contract with. The
defendant is a very popular academy which trains a lot of kids and certainly the
subject matter complained of invites public attention. The comment was made by the
plaintiff in good faith so that the public comes to know the reality and the defendant
can be abstained from making false and frivolous assurances, thus betraying another
people like the plaintiff. Fair comment is the name given to the right of every citizen
to comment on matters of public interest.10

iii. Hence, the plaintiff had no malicious intention in doing so as the plaintiff
communicated the matter to the public from a sense of duty and legal morality being
a law-abiding citizen of the country. The comments made by the plaintiff are based
on facts as already mentioned.

iv. The doctrine of fair comment is based on the hypotheses that the publication in
question is one which, broadly speaking, is true in fact, that the facts stated therein
are such as would go to serve the public interest.11 It is said that nothing is libel
which is a fair comment on a subject fairly open to public discussion.12 It is the
expression of criticism that has to be fair.13

v. As remarked by Lord Denning in Slim v. Daily Telegraph Ltd.14 , “He must honestly
express his real view. So long as he does this, he has nothing to fear, even though
other people may read more into it.”

vi. The plaintiff sincerely criticises the deficient services discharged by the defendant.
The defendant has breached the trust and confidence reposed by the plaintiff which
invites criticism. Hence, the plaintiff states that the ‘fair criticism of plaintiff does not
amount to defamation’ as the view expressed is honest.15
Therefore it is well established before this Hon’ble Court that the comment is fair as it is
stated on facts. The defendant has expressed the opinions honestly, done so upon facts
accurately stated and hence there is hardly any scope for complaint of defamation.16

7
V. Mitter, Law of Defamation and Malicious Prosecution.
8
London Artists, Ltd. v. Littler, (1969)2 QB 375.
9
Cox v. Feeney, (1863) 4 F&F 13
10
Silikin v. Peaverbook Newspapers, (1958) 2 All ER 516.
11
VishanSarup v. NardeoShastri AIR 1965 All 439, 1965 Cr LJ 334
12
W.S. Irwin v. D.F. Reid, AIR 1921 Cal 282:63 IC 467:48 Cal 304:25 CWN 150.
13
V. Mitter, Law of Defamation and Malicious Prosecution.
14
(1968) 2 QB 157.
15
Silikin v. Peaverbook Newspapers, (1958) 2 All ER 516.
16
Branson v. Bower, (2002) 2 WLR 452.

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(C) SANGWAN SPORTS GETS DEFENCE FOR DEFAMATION UNDER TORTS


AND IPC
i. There are three defences of defamation namely –
1.Justification or truth –
Under criminal law, merely proving that the statement was true is no defence but in
civil law merely showing truth is a good defence. This is a matter of civil law and the
statement made by the plaintiff is true and based on facts. The defendants did tried to
communicate with the defendant but they didn’t responded and gave the contract to
some other company which proves that the defendant did betrayed the plaintiff.
In Alexander v. N.E. Rly17, the plaintiff had been convicted of riding a train from
Leeds without having purchased a valid ticket. The penalty was a fine and a period of
imprisonment of fourteen days if he defaulted on the fine. However, following the
conviction, the defendant published a notice that the plaintiff was convicted and
issued a fine or three weeks imprisonment if in default. The plaintiff alleged that the
defendant had committed libel by describing the penalty issued to him inaccurately.
The defendants argued that the conviction was described with substantial and
sufficient accuracy and the words so far as they differed in their literal meaning from
the words of the conviction were not libellous.Judgment was given in favour of the
defendants. The gist of the libel was that the plaintiff was sentenced to pay a sum of
money and, in default of payment, to be imprisoned. Blackburn J noted that the
substance of the libel was true but the question was whether what was stated
inaccurately was the gist of the libel.

2.Fair Comment-
# The comment must be an expression of opinion rather than assertion of fact.
# The comment must be fair i.e. without malice.
# The matter commented upon must be of public interest.

3. Privilege-
There are certain occasions when the law recognizes the right to freedom of speech
outweighs the plaintiff’s right to reputation, the law treats those occasions as
‘Privileged’. These are further of two types –

Absolute privilege- No action lies for the defamatory statement even though the
statement is false or made maliciously. It applies to :
Parliamentary Privilege, Judicial proceeding and State communication.

Qualified privilege- It is necessary that the statement must have been without malice.
The defendant has to prove that statement was made on a privileged occasion fairly.

4.Imputation of truth which public good requires to be made or published.—It is


not defamation to impute anything which is true concerning any person, if it be for the

17
(1865) 6 B&S 340

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public good that the imputation should be made or published. Whether or not it is for
the public good is a question of fact.18
With these defences, the plaintiff is not liable to pay compensation for defamation,to the
defendant.

18
IPC_186045.pdf

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PRAYER

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