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CONTENTS
The Satirical Dilemma ............................................................................................................................................. 3
The Legal Slap ......................................................................................................................................................... 3
• Libel ........................................................................................................................................................... 4
• Slander ...................................................................................................................................................... 4
1. The Statement Must Be Defamatory. ........................................................................................................... 5
The Innuendo ................................................................................................................................................. 6
2. The statement must refer to the plaintiff ......................................................................................................... 7
3. The statement must be published ..................................................................................................................... 9
1. Justification/ Truth ......................................................................................................................................... 9
2. Fair Comment ............................................................................................................................................... 10
3. Privilege (Absolute & Qualified) ................................................................................................................... 10
The Legal Notice ................................................................................................................................................ 11
Lawyers (A necessity) ........................................................................................................................................... 11
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INTRODUCTION
THE SATIRICAL DILEMMA
A Netflix series of the name “Hasmukh” was released on April 20, 2020, the series revolved around
the story of a small-town comedian whose inspiration came from murdering people around him, the
show was successful and garnered the attention of various viewers with its dark sense of humour and
take on real life issues. But the show’s dandy ride ended abruptly when they received a legal notice
claiming the show was defamatory.

THE LEGAL SLAP

On April 20, 2020, a defamation notice was sent to Netflix India by Advocate Abhishek Bharadwaj
and Advocate Hardik Vashishth claiming the fourth episode of the series titled “Bambai Main Bambu”
was defamatory to the entirety of legal association. This paper takes a deep dive into whether the
words said on the show were defamatory by looking into what is defamation under civil law and
criminal law. And whether the legal slap to Netflix was required or not.
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WHAT IS DEFAMATION?
A simple google search would take an individual to the Wikipedia page and the definition of
defamation is as follows:

Defamation (also known as calumny, vilification, libel, slander, or traducement) is

the oral or written communication of a false statement about another that unjustly
harms their reputation and usually constitutes a tort or crime.

Apart from the Wikipedia if one were to ask an individual on the street what does the word defamation
mean one would usually get the answer of “injury to the reputation of a person”. In the case of Dixon V.
Holden (English Case, 1869) where the plaintiff filed a suit against his two superior officers because
they did not act after finding out the plaintiff’s phone was being wire tapped, under this it was coined
that “A man’s reputation is his property”. Hence in the eyes of a layman defamation is just harm to
the reputation. But in the eyes of the legal profession, it is more intricate and complex than just harm
to a person’s reputation.

English Law divides any action of defamation under two categories:

• LIBEL
It is the representation of defamatory statements made in some permanent structure or
tangible objects.

Example: Writing, Printing, Pictures, or Statues etc.

• SLANDER
Slander is the publication of a defamatory statement in a transient form.

Example: it may be spoken by words or gestures

Under English Law, the difference between libel and slander is material for two reasons:

1. Under criminal law only libel has been recognized as an offence. Slander is not considered or
does not amount to offence.
2. Under the las of torts, slander is actionable only on proof of special damage. Libel is always
actionable perse, that is without any proof of damage.

In the case of Youssoupoff v. M.G.M. Pictures Ltd. where during a film produced by an English
company called M.G.M. Pictures Ltd. a lady princess Natasha was shown as having relations of
seductions or rape with the man Rasputin, a man of the worst possible character. Slesser L.J. held that
“There can be no doubt that, so far as the photographic part of the exhibition is concerned, that is a
permanent matter to be seen by the eye and is the proper subject of an action for libel, if defamatory.
I regard the speech which is synchronised with the photographic reproduction and forms part of one
complex, common exhibition as an ancillary circumstance, part of the surroundings explaining that
which is to be seen.”

Section 1, Defamation Act, 1952 provides that broadcasting of words by means of wireless telegraphy
shall be treated as publication in permanent form.
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In the following exceptional cases, slander is also actionable perse:

(i) Imputation of criminal offence to the plaintiff

(ii) Imputation of a contagious or an infectious disease to the plaintiff, which has the effect
of preventing other from associating with the plaintiff.
(iii) Imputation that a person is incompetent, dishonest, or unfit regarding the office,
profession, calling, trade, or business carried in by him.
(iv) Imputation of unchastity or adultery to any women or girl is also actionable per se. This
exception was created by the Slander of Women Act, 1891.

Under Indian Law it has been noted that it is fruitless to make a distinction between libel and slander.
Both libel and slander are criminal offences under Section 499, IPC . As opposed to English Law under
which is defined that libel is actionable perse but in case of slander, except in certain cases, proof of
special damage is required, there has been a controversy whether, slander like libel, is actionable per
se in India, or special damage is required to be proved, as in England. The weight of the authorities is
for discarding between libel and slander in India and making slander and libel both actionable per se.

In Parvati V. Mannar, Turner C.J. and Muthuswami Ayyar, J. the two justices while deciding for this
case held that, “The laws of England relating to slander/oral defamation which requires the proof of
special damage has no reasonable basis. Hence should not be adopted by the courts of India.”

In D.P. Choudhary v. Manjulata (A.I.R. 1997; RAJ 107), the plaintiff-respondent, Manjulata, about 17
years of age, belonged to a family of Jodhpur with a good standing in the society. She was a student
studying B.A. There was a publication of a news item in local daily, Dainik Navjyoti, dated 18th
December 1977 that last night at 11 pm. Manjulata had run away with a boy named Kamlesh, after
she went out of her house on the pretext of attending night classes in her college.

The news article was false and was published negligently with utter recklessness. She was shocked
and ridiculed by persons who knew her, and her marriage prospects were adversely affected thereby.

It was held in this case that all defamatory words are actionable per se and in such as case, general
damages will be presumed. She was held entitled to an award of Rs.10,000/- by way of general
damages.

ESSENTIALS OF DEFAMATION
1. THE STATEMENT MUST BE DEFAMATORY.
Defamatory statement is one which injured the reputation of the plaintiff. Defamation is the
speaking or publishing nay statement or gesture or article etc. which tends, to lower a person
in the eyes of the right-thinking members of society generally or which tends to make them
alienate the person defamed. An imputation which exposes an individual to disgrace and
humiliation, ridicule or contempt which is defamatory. Whether the statement is defamatory
or not depends upon how the reputed personnel of the society are likely to take it. The
standard to be applied is that of a sane individual, a man of fair average intelligence, and not
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that of a special sect of society whose values or thoughts are not approved by the fair-minded
members of the society generally. If the said statement causes injury to the reputation of the
plaintiff then the defence that it was not intended to be defamatory will be not considered.
When the statement causes anyone to be regarded with feelings of hatred, contempt, ridicule,
fear, dislike, or dis-esteem, it is defamatory. The essence of defamation is injury to a person’s
character or reputation.

In S.N.M. Abdi v. Prafulla Kumar Mohanta , it was held that it is not necessary that the
statement need not show a tendency of imputation to prejudice the plaintiff in the eye of
everyone in the community or all his associates. It is sufficient to establish that the publication
tends to lower him in the eyes of substantial, respectable group, even though they are
minority of the total community or of the plaintiff’s associates. In the present case an article
published in the Illustrated Weekly of India dated 8-9-1990 made certain allegations of misuse
of man and muscle power by deposed Chief Minister of Assam, Prafulla Kumar Mohanta. The
article was held to be defamatory in nature and the plaintiff was amounted damages
amounting to Rs. 5,00,000/-.

Words which merely injure the feelings or cause annoyance but which in no way reflect on
character or reputation or tend to cause one to be shunned or avoided are not held liable.
Mere vulgar abuse if intended as a mere abuse and so understood by those who hear those
words only hurt a man’s pride. Such words are not considered defamatory as they do not
disparage the reputation.

In South Indian Railway Co. v. Ramakrishna, the railway guard, who was an employee of the
defendant, South Indian Railway Co., went to a carriage for checking the tickets and while
calling upon the plaintiff to produce his ticket said to him in the presence of the other
passenger: "I suspect you are travelling with a wrong (or false) ticket." The plaintiff produced the
ticket which was in order. He then sued the railway company contending that those words
uttered by the railway guard amounted to defamation. It was held that the words spoken by
the guard were spoken bona fide and under the circumstances of the case, there was no
defamation, and the railway company could not be made liable for the same.

THE INNUENDO

When the natural and ordinary meaning is not defamatory, but the plaintiff wants to bring an action
for defamation, he must prove the latent or the secondary meaning, i.e., the innuendo, which makes
the statement defamatory. Even a statement of commendation may be defamatory in the context in
which it is said. Even "Y is a saint" might be slander if the statement was understood to refer to a
criminal gang known as "The saints". Similarly, to say that X is an honest man and he never stole my
watch may be a defamatory statement if the persons to whom the statement is made understand
from this that X is a dishonest man having stolen the watch. The statement that a lady has given birth
to a child is defamatory when the lady is unmarried. Similarly, the statement that A is like his father
may be defamatory if it is likely to convey the impression that he is a ‘cheat’ like his father.
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I NTENTION TO DEFAME IS NOT NECESSARY

When the words are defamatory by the persons- to whom the statement is published, there is
defamation, even though the person making the statement believed it to be innocent.

It is immaterial that the defendants did not know of the facts because of which a statement otherwise
innocent, is defamatory. In Cassidy v. Daily Mirror Newspapers Ltd., Mr. Cassidy (also known as Mr.
Corrigan) was married to a lady who called herself Mrs. Cassidy or Mrs. Corrigan. She was known as
the lawful wife of Mr. Cassidy who did not live with her but occasionally came and stayed with her at
her flat. The defendants published in their newspapers a photograph of Mr. Corrigan and Miss ‘X’,
with the following words underneath: "Mr. M. Corrigan, the racehorse owner, and Miss ‘X’, whose
engagement has been announced." Mrs. Corrigan sued the defendants for libel alleging that the
innuendo was that Mr. Corrigan was not her husband and he lived with her in immoral cohabitation.
Some female acquaintances of the plaintiff gave evidence that they had formed a bad opinion of her
because of the publication. The jury found that the words conveyed defamatory meaning and awarded
damages. The Court of Appeal held that the innuendo was established. Obvious innocence of the
defendants was no defence. The defendants were held liable.

2. THE STATEMENT MUST REFER TO THE PLAINTIFF

In an action for defamation, the plaintiff must prove that the statement which he complains referred
to him. It is immaterial that the defendant did not intend to defame the plaintiff. If the person to
whom the statement was published could reasonably infer that the statement referred to the plaintiff,
the defendant is nevertheless liable. In Hulton Co. v. Jones , the defendants published a fictional article
in their newspaper, Sunday Chronicle, written by the Paris correspondent, purporting to describe a
motor festival at Dieppe. In the article aspersions were cast on the morals of a fictitious person-
Artemus Jones, stated to be a Churchwarden at Pekham and being present in the festival.

His case was referred to him. The defendants pleaded that ‘Artemus Jones’ was an imaginary or a
fictional name invented only for the purpose of the article and they never knew the plaintiff and they
did not intend to defame him. Notwithstanding this contention of the defendants, they were held
liable. According to Lord Alverstone, C.J., "..........If the libel speaks of a person by description without
mentioning the name to establish a right of action, the plaintiff must prove to the satisfaction of a jury
that the ordinary readers of the paper who knew him would have understood that it referred to him.

Newstead v. London Express Newspapers Ltd., the defendants published an article stating that
"Harold Newstead, a Camberwell man" had been convicted of bigamy. The story was true of Harold
Newstead, a Camberwell barman. The action for defamation was brought by another Harold
Newstead, a Camberwell barber. As the words were understood as referring to the plaintiff, the
defendants were held liable.

It has been noted above that the liability for the defamation did not depend upon the intention of the
defendant to defame, but upon the fact that the statement made by him was defamatory. This created
a lot of hardship for many innocent authors, printers, and publishers because the fact that they were
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innocent in publishing the statement did not save them from liability. Such hardship was particularly
noticed in cases like Cassidy v. Daily Mirror Newspapers Ltd., where a statement published
innocently turned out to be defamatory, and Hulton and Co. v. Jones and Newstead v. London
Express Newspapers Ltd., where there was no intention to defame the plaintiff, but he was deemed
to have been defamed.

The criticism of these cases led to the constitution of the Porter Committee to consider the Law of
Defamation and to report on the changes in the existing law, practice and procedure relating to the
matter which are desirable. On the Report of the Committee, Defamation Act, 1952 was passed to
remove the hardship which had been created for innocent persons. Section 4 of the Act provides a
procedure by which an innocent person can avoid his liability.

The procedure provided in the Act is that if the defendant has published certain words innocently, but
they are defamatory, he should make an offer of amends, i.e., he must publish a suitable correction
and an apology as soon as possible after he came to know that the words published by him were
defamatory to the plaintiff. If the offer of amends is accepted by the aggrieved party, no action for
defamation may be brought or continued against the party making such amends.

(i) the innocent party who had published the said statement can avoid the liability by
proving:
(ii) that the words which had been published by him were published innocently, and

that as soon as he came to know that these words published by him had resulted in the defamation
of the plaintiff, an offer of amends was made.

The words are deemed to be published innocently within the meaning of Section 4 of the Defamation
Act, if it is proved:

(a) that the publisher did not intend to publish them of and concerning that other person, and
did not know of circumstances by virtue of which they might be understood to refer to him;
or
(b) that the words were not defamatory on the face of them, and the publisher did not know of
circumstances by virtue of which they might be understood to be defamatory of that person,
and in either case that the publisher exercised all reasonable care in relation to the
publication; and any reference in this sub-section to the publisher shall be construed as
including a reference to any servant or agent of his who was concerned with the contents of
the publication.

D EFAMATION OF A CLASS OF PERSONS

When the words refer to a group of individuals or a class of persons, no member of that group or class
can sue unless he can prove that the words could reasonably be referring to him. Thus, "If a man wrote
that all lawyers were thieves, no particular lawyer could sue him unless there was something to point
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to the particular individual." In Knupffer v. London Express Newspapers Ltd., the appellant was the
member of a party, the membership of which was about two thousand, out of which twenty-four
members including the plaintiff were in England. The respondents published a statement of the party.
Some of the appellant’s friends considered the article to be referring to him. It was, however, held
that since the article referred to such a big class, most of the members of which were resident abroad,
it could not reasonably be referring to the appellant and the respondents were not liable. It was stated
by Lords Atkin in Knupffer v. London Express Newspapers Ltd., "There can be no law that a
defamatory statement made of a firm, or trustee, or the tenants of a particular building is not
actionable if the words would reasonably be understood as published of each member of the firm or
each trustee or each tenant. The reason why a libel published of a large or indeterminate number of
persons described by some general name generally fails to be actionable is the difficulty of establishing
that the plaintiff was, in fact, included in the defamatory statement."

In Dhirendra Nath Sen v. Rajat Kanti Bhadra, it has been held that when an editorial in a
newspaper is defamatory of a spiritual head of a community, an individual of that community does
not have a right of action. Where the statement though generally referring to a class can be reasonably
considered to be referring to a particular plaintiff, his action will succeed.

3. THE STATEMENT MUST BE PUBLISHED

Publication means making the defamatory matter known to some person other than the person
defamed, and unless that is done, no civil action for defamation lies, Communication to the plaintiff
himself is not enough because defamation is injury to the reputation and reputation consists in the
estimation in which others hold him and not a man’s own opinion of himself. Dictating a letter to one’s
typist is enough publication. Sending the defamatory letter to the plaintiff in a language supposed to
be known to the plaintiff is no defamation.

In Mahendra Ram v. Harnandan Prasad , the defendant sent a defamatory letter written in Urdu to
the plaintiff. The plaintiff did not know Urdu and therefore the same was read over to him by a third
person. It was held that the defendant was not liable unless it was proved that at the time of writing
the letter in Urdu script, the defendant knew that the Urdu script was not known to the plaintiff and
it would necessitate reading of the letter by third person.

DEFENCES TO DEFAMATION
General defences mean a situation where your action is justified under the law. The defences to
defamation are as follows:

1. JUSTIFICATION/ TRUTH
If there is truth in the statement it is not defamation. In a civil action for defamation, truth of
the defamation matter is complete defence. The act of defamation can result in 3 years of
imprisonment. It is compoundable even though it is a criminal offence. Under the Indian Penal
Code (IPC) an individual must prove that the statement was in public good. Under civil law
merely proving that the statement is true is a good defence.
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In Alexander v. North Eastern Railway (1885), there was a man fined with one pound or
fourteen days of imprisonment, he was a well reputed individual. The railway issued a public
notice which held all the information regarding the fine and imprisonment. It was held in this
case that the defence was not liable.

In Salina Dandas v. Gajjala Mallareddy (AIR, 2009; NOC), An advocate filed a suite for
defamation against a newspaper. The newspaper published an article by distorting the facts
in the FIR. In this case as well defence was not liable.

2. FAIR COMMENT
For the defence of fair comment to be available the following conditions should necessarily fulfil:

(i) It must be a comment, that is an expression of opinion rather than assertion of

facts.
(ii) The comment must be fair.
(iii) The matter commented upon must be of public interest.

It was held in the case Merivale v. Carson (1887), “when immorality is imputed by
suggesting that a play contained an incident of adultery when in fact there was no such
incident in the play, the plea of fair comment cannot be taken”

In K.S. Sundram v. S. Viswanathan (2013; NOC 217), the court held, “These articles are
not defamatory they do not defame the president, it is a fair comment on the management
of the company, no personal intention to defame.”

3. PRIVILEGE (ABSOLUTE & QUALIFIED)

In matters of absolute privilege, no action lies for the defamatory statement even though the
statement is false or true or has been made maliciously. Article 105 (2) gives absolute privilege
to members of parliament and Article 194 (2) to members of state legislature.

No action of libel or slander can be taken against a judge, witness, and individuals in judicial
proceedings.

Protection to the judicial officers in India has been granted by the judicial officer’s protection
act 1650.

To avail the defence of qualified privilege, the defendant must prove the following two
essentials:

(i) The statement was made on a privileged occasion, it was in the discharge
of duty or protection of an interest or it is a fair report of parliamentary,
judicial, or other public proceedings.
(ii) The statement was made without any malice.
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THE SATIRICAL PROBLEM

The Netflix series “Hasmukh” as mentioned earlier in the paper is a dark comedy following the anti-hero, a
comedian who gets his inspiration from murdering. A comical twist on dark issues such as murder, corruption
etc. this series brought a fresh new concept. The dilemma was caused by the fourth episode of this series titled
“Bambai Main Bambu”, where the protagonist was kidnapped by a corrupt lawyer, at gunpoint the lawyer
demands a certain sum of money from Hasmukh so he can pay his debt off. And in the tussle between the
protagonist and the lawyer, the protagonist chokes the lawyer to death. This whole fiasco leads to the comedian
being late for his set and on the stage Hasmukh says the following lines in the scene which were also mentioned
in the legal noticed issued to Netflix India:

“…arey kya gareeb ki tokri sy tum loam mang rahe ho? Bacchey ki chaddi ky andar tum minar dhoondh rahe ho?
Aisa pehla sehar dekha hai humny jahan chor bhi badey amir hotey hain. Lekin yahan unka naam chor nahi,
vakeel hot hai. Aapkey vakeel sabsy badey kameeny aur chor hotey hain. Yeh kannon ky thekedaar, jo kabhi nahi
hongey giraftaar, qyunki yeh kalam ky sath kartey hain, apka balatkaar. Arey bhaiya, log khety hain ki kanoon
andha hota hai. May kehta hoon, mumbai may kanoon ganda hota hai. Qyunki har vakeel ky hath may chotta sa
itna danda hota hai…”

These lines were spoken by the character with the trauma caused by the lawyer in mind. In these lines hasmukh
goes ahead to claim that all the lawyers of Mumbai are thiefs and goons and he also went as far as to call them
rapist, though it is figurative. As in they strip you away of all sort of semblance with their pens. This infuriated
by Advocate Abhishek Bharadwaj and Advocate Hardik Vashishth and they wrote a legal notice claiming
defamation to Netflix India.

T HE LEGAL N OTICE
The legal noticed summed up included the lines that were defamatory also the notice also read that the said
statements are highly defamatory and brings disrepute to law profession in the eye of public. “Said statements
are towards causing utmost damage to legal profession and impugn the image of lawyers in the eyes of millions
of viewers/subscribers who visit the streaming website.”

Bhardwaj and Vashisth also imply that this is just the latest example of lawyers being targeted by content
creators. The notice points out that the legal profession has been the subject of malicious and “ill-fated”
attempts by media houses, movies, TV shows etc to portray the profession and the legal system in a bad light by
making such “derogatory comments” in the guise of comedy.

LAWYERS (A NECESSITY)
My takeaway from this whole case is the legal notice was not necessary as this is not a first time, the legal
profession is hated upon or termed as evil. History is filled with pieces of literature as well as various famous
quotes berating lawyers. Did it harm the legal profession? No, it did not because lawyers are and always remain
intellectual personnel required to uphold law all around the world. Lawyers safeguard rights of an individual,
you can coin them as “warriors of law”, quite far-fetched but it is true.

Here are a few famous proverbs in history that berate lawyers, a simple google search would bring these quotes
to you:

• “Lawyers and painters can soon change white to black”

• “A lawyer with a briefcase can steal more money than a hundred men with guns” -Mario Puzo
• “I think we may classify lawyers in the natural history of monsters” -John Keats
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• “Lawyer even sounds like liar” -Walter Mosley

• “Lawyers are like beavers. They get in the mainstream and dam it up” -John Naisbitt
• “the trouble with law is lawyers.” -Clarence Darrow

I find it quite hilarious that through out history lawyers are always hated on and represented big mad evil
individuals who will eat up your money, but despite all this the lawyers thrived, there would be no independent
India without a lawyer advocating the rights of the indigo farmers, Mahatama Gandhi. There would be no
constitution for America without the 7 lawyers involved in the making of this constitution. There would be no
women’s rights if it were not for the court petitions in 1920 by lawyers. The world needed, needs, and will need
lawyers in the times to come. The hate it will not ever go away everyone has their personal opinions about a
profession that is understandable but to go ahead and send a legal notice over a small show is unnecessary. The
statement did no personal harm to the individuals involved in the case as well as the fact that it did not affect
the legal profession at all. People still come to lawyers for representation in court, it is one of those jokes that
were always and will always be said about lawyers, we as a reputed profession should pay no mind to such
comments.

Since childhood I have heard a joke from everyone around about how if heaven were to ever sue hell, hell would
win the case because all the lawyers go to hell. It always made me laugh and now that I am a law aspirant it
makes me chuckle more, people love to paint lawyers as the “big bad wolf out for money”, truth is lawyers are
the intellectuals and just sort of tired of from all the continuous studying the must do. Shakespeare in his play
Henry VI writes,” Let us kill all of them, first kill all the lawyers.” People took this out of context and thought
Shakespeare hates lawyers but in the reality the line was written in the context that Henry VI wanted to stop
the upcoming revolution and suggests killing lawyers first as they safeguard the rights of an individual.
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CONCLUSION
In conclusion all I want to say is the statement made was harsh, but does it amount to defamation? No, it does
not. It is one of those caricatures of lawyers drawn up since the dawn of history that lawyers are the antagonist.
The irony is that if we were to completely get rid of lawyers, the laymen would have to learn law in turn creating
more lawyers. So, if you kill all the lawyers you would turn the whole world into lawyers. Under the second
essential of defamation, the statement was not meant particularly to those individuals but rather a fictional
lawyer, and the whole lawyer association of India takes no offence to the statements said.

The legal notice created a Streisand effect leading to more exposure of the show, in the back of my mind, I have
a crazy theory that it might be a way to advertise the series by involving a controversy, but it only remains a
theory. Despite any statement made by the series the legal profession will always thrive and still thrives and is
respected. No one can look down upon an intellectual lawyer. Obviously, all lawyers are not the same there
might be some bad ones, but we have many who work to help the one in need.

As a law aspirant I take no offence to such a statement because I am aware that at the end of the day I will come
out as an intellectual and capable lawyer. I am aware that the profession that I am studying to pursue is not of
thieves and goons rather of warriors of justice, having their flaw lawyers are mandatory. In short, the statement
made was not defamatory as it did not cause any sort of injury reputation. I do not think any lawyer did not get
a client just because Hasmukh told them “vakeel chor hain”. People look to lawyers for representation in the
court and to safeguard their right in the court of law. There always be a Henry VI plotting to kill lawyers so there
will be no safety for the rights of individuals. Despite all this the profession grows all around the world and
lawyers are always regarded as an intellectual wherever they go.
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REFERENCES
o https://attorneyatlawmagazine.com/what-world-look-without-lawyers
o https://en.wikipedia.org/wiki/Hasmukh
o https://www.imdb.com/title/tt9359294/
o https://deadant.co/defamation-notice-sent-to-the-makers-of-hasmukh-for-comments-about-
lawyers/
o R.K. Bhangia, The Law of Torts including consumer Protection Laws India.
o www.lawsteert.com
o Advocate Abhishekh Bharadwaj & Advocate Hardik Vashishth, Legal Notice to Netflix India.