Professional Documents
Culture Documents
T.S. /2022
– 700124.
…Plaintiff
VERSUS
Kolkata – 700126
…Defendant
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jurisdiction of this Ld. Court and the Defendant also resides in the
2. That the plaintiff representing his client Aparna Pati W/O Prabir
Pati and Prabir Pati S/O Late Jatindra Nath Pati both are Residing
present defendant along with others before the Ld. 1 st Civil Judge
(Jr. Divn.) at Barasat being Title suit no. 295 of 2021 and against
the order no. 10 dated 24.11.2021 in connection with the said suit
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client have filed a Misc. Appeal before the Ld. District Judge at
Barasat which is transferred to the Ld. 2nd Civil Judge (Sr. Divn.) at
295 of 2021 passed by Ld. 1st Civil Judge (Jr. Divn.) at Barasat
Appeal and the said letter was duly received by your defendant.
3. That out of the grudge of the above mentioned action taken on the
https://www.facebook.com/bibaswanm/posts/
4755859417781246?
comment_id=4928284910538695¬if_id=1640795752006829&n
otif_t=feed_comment&ref=notif
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vabte shikhun.” And “Apnar client er 2to baba bole ki apni amr
baba r nam palte diyechhen. Parle aktu lekha pora kore chithi fiti
follows:-
https://www.facebook.com/ruma.bhadra.35?
comment_id=Y29tbWVudDo0NzU1ODU5NDE3NzgxMjQ2XzQ5Mjgy
ODQ5MTA1Mzg2OT U%3D
and by seeing the display picture, the plaintiff have every reason to
believe that the person who have made the above mentioned
And the screenshot of the post in the facebook along with the said
5. That seeking for the answer of the above questions your plaintiff
have also stated in the said legal notice that,-
“If the above mentioned questions are not clarified within 7 days
from the receiving of this letter then it would be deemed that the
above mentioned comments are made by you and you have posted
the above mentioned comments with a view to malign my image in
the public platform. And the client which you have referred in the
above mentioned comment “Apnar client er 2to baba…” is no one
but my client in connection with the above mentioned case, Prabir
Pati, because I have many reasons along with evidence to believe
that you can make such comments on me and my client, Prabir
Pati or Aparna Pati. And it would also be deemed that letter which
you have referred in your comment “Parle aktu lekha pora kore
chithi fiti likhun ba okaloti ta korun…” is the letter dated
24.12.2021 in connection with Misc. Appeal 1 of 2021 pending
before the Ld. 2nd Civil Judge (Sr. Divn.) at Barasat.
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9. Thus without having any other alternative the plaintiff have filed
the instant suit claiming for damages for defamation valued at Rs.
5,00,000/- and praying for injunction restraining the defendant
from making any defamatory post to malign the prestige and
dignity of the plaintiff till the disposal of the suit and permanent
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after trial in the same manner along with a prayer for Mandatory
Injunction etc.
10. That the first cause of action was arose on 12 th November, 2021
when the Plaintiff have made a post having the hyperlink as
follows:-
https://www.facebook.com/bibaswanm/posts/
4755859417781246?
comment_id=4928284910538695¬if_id=1640795752006829&n
otif_t=feed_comment&ref=notif
11. That the instant suit for Damages for Defamation is valued Rs.
5,00,000, permanent injunction valued at Rs. 100/- and
Mandatory injunction valued at Rs. 100/-, total value of Rs.
5,00,200/- and the court fee has been paid accordingly as per
proviso of Section 7(i) of west Bengal Court fees Act as amended
upto date.
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VERIFICATION
Deponent
10 | P a g e
AFFIDAVIT
1. That I am the sole plaintiff of the instant suit and well conversant
of the facts of this case. …this is true to my Knowledge.
2. That the statements made in the above paras are true to best of my
Knowledge and belief and I sign this affidavit in the Barasat Court
premises on
Deponent
Identified by me
Advocate