[4/29, 22:20] sekarreporter1: https://twitter.com/sekarreporter1/status/1652353945535393793?t=aovtAAwlX-5fMyKqYRo38A&s=08 [4/29, 22:20] sekarreporter1: Manuraj adv send notice to annamalai demand rs 1 கோடி on behalf of kanimoli mp dmk [4/29, 22:09] sekarreporter1: ,

S. MANURAJ

LEGAL NOTICE
25th April 2023
To
Thiru. K. Annamalai, State President, BJP,
Kamalalayam, Vaidyaraman Street, Parthasarathi Puram, T. Nagar, Chennai — 600017.
E-mail: biptnoffice@qmail.com
Via: R.P.A.D. and E-mail
Sir,
Sub: Defamation Notice — Cease and Desist
Ref: Defamatory Video published on 14.04.2023
We are instructed by Ms. Kanimozhi Karunanidhi, Member of Parliament, representing Thoothukkudi Constituency and Deputy General Secretary, Dravida Munnetra Kazhagam, having office at 367-369, Anna Arivalayam, Anna Salai, Teynampet, Chennai — 600017 (hereinafter, “Our Client”) to send you the following Legal Notice (hereinafter, “Notice”).
1. Our Client states that she is a Member of Parliament representing Thoothukkudi Constituency in the House of the People who secured 5,63,143 votes (56.77%) and having a victory margin of 3,47,209 votes against the runner-up BJP Candidate one Dr. Tamilisai Soundararajan in the General Elections of 2019. She belongs to the Dravida Munnetra Kazhagam (hereinafter, ‘DMK”), a party founded in 1949 and elected to

form Government by the people of Tamil Nadu on six occasions — 1967, 1972, 1989, 1996, 2006 and 2021.
2. Our Client states that she served as the Arts, Literature and Rationalism Wing Secretary of the DMK, Women’s Wing Secretary of the DMK, the first woman to be elected President of the Hindu National Press Employees Union, and was elected to the Council of States for two consecutive terms in 2007 and 2013. Our Client further states being an incumbent Member of Parliament, she is serving as a Chairperson for Tuticorin Airport Advisory Committee, District Development Coordination and Monitoring Committee and Parliamentary Standing Committee on Rural Development and Panchayati Raj. From 2019 to 2022, she served as the Chairperson of the Parliamentary Standing Committee on Chemicals and Fertilizers.
3. Our Client states that on 09.11 2022, she was appointed as a Deputy General Secretary to DMK and continues to serve the DMK party, which is the foremost political party in the state of Tamil Nadu having formed Government in 2021 and returned 23 Members of Parliament in the General Elections of 2010. In addition to hor political career, she is a renowned poel and journalist Who has dedlcated her career 10 advancing the principles of self-respect, women’s empowerment and the values honed by stalwarts of Dravidian Politics. Our Client states that she is wellknown and enjoys a high reputation in social, literary and political circles across the nation.
4. Our Client states that you are presently the State President of the Bharatiya Janata Party (hereinafter, “BJP”) for Tamil Nadu and that you have screened a defamatory video titled “DMK Files” (hereinafter,
“Defamatory Video”) at the Press Conference conducted on 14.04.2023 at your party headquarters’ in Chennai. The aforesaid Press Conference was streamed live on your Facebook Page under the name and style of “K. Annamalai” with the URL: httpe://www.facebook.com/k.annamalai.ips (hereinafter, “Official Facebook Page of K. Annamalai”), your You Tube channel under the name and style of “K. Annamalai” with the URL: https://www.youtube.com/@annamalai.k (hereinafter, “Official YouTube Channel of K. Annamalai”), and your party’s Facebook Page under the name and style of “BJP Tamilnadu” with the URL: https://www.facebook.com/BJP4TamilNadu (hereinafter, “Official Facebook Page of BJP Tamilnadu”). The above-mentioned press conference was broadcasted by several media houses having viewership across Tamil Nadu, YouTube channels and shared on other social media platforms.
5. Our Client states that the Defamatory Video is still accessible on many sites as a recorded feed and some of the them are tabulated below, for the purpose of issuing this Notice:
Name of the Source Page I Channel URL to Defamatory Video (with total duration)
Official Facebook Page of
K. Annamalai https://www.facebook.com/k.annamal ai.ips/videos/6340060979378386/
2. Official You Tube Channel of K. Annamalai https://www.voutube.com/watch?v=T
( 1 : : 55)
3. Official Facebook Page of
BJP Tamilnadu https://www.facebook.com/BJP4Tami
I Nadu/videos/1049744349320182/

The abovementioned Defamatory Video titled “DMK Files”, also formed part of the live streaming video of Press Conference published in your Official Facebook Page of K. Annamalai, wherein at about 21 :56 min, you have made a reference to Our Client by displaying her photo with the text “Kanimozhi Rs. 830.33 Cr”, which is followed by showing her family tree with reference to Husband and Son and background showing her late father Dr. Kalaignar M. Karunanidhi, the Former Chief Minister and Former Leader of the DMK party. Subsequently, you have displayed the website “MyNeta” comparing the year 2009 and 2019. Thereafter, at about 22:10 min, in the said Defamatory Video, you have displayed the following words: “Affidavit Assets Rs. 30.33 Crore, Kalaignar TV Rs. 800 Crore and Total Value Rs. 830.33 Crore” along with her name and photograph, which is an act tainted with malice and ill-will towards Our Client and are per se defamatory in nature.
6. Our Client states that the Defamatory Video was published by you in a reckless manner, with mala fide intent and for ulterior motive to scandalize her public life. The contents that you have published in the Defamatory Video state that she holds the assets to the Total Value Rs. 830.33 Crore is baseless, imaginary and are all contrary to the available records and documentation. It IS evident that your intent was to malign the public image of our Client and tarnish her reputation by projecting that she holds assets to the tune of INR 830.33 crore.
7. Our Client further states that the above-mentioned contents of the Defamatory Video, in the form of libel made therein, are false, frivolous, untrue and highly defamatory. Our Client states that since 10.022023, she has not held any shares in Kalaignar TV, and you have brought these serious claims against her without even checking the most basic details
in an effort to discredit her character. Our Client further states that the Defamatory Video and publication of the same in Official Facebook Page of K. Annamalai, Official You Tube Channel of K. Annamalai and Official Facebook Page of BJP Tamilnadu, individually and jointly, constitute a calculated attempt to malign and tarnish the reputation of Our Client who is an elected representative of the people of Thoothukudi Parliamentary constituency. Our Client further states that you have also utilized the website under the name and style of ” En Mann En Makkal” with the URL: https://enmannenmakkal.com/ (hereinafter, “En Mann En Makkal”) and published the Defamatory Video for wide circulation.
8. Our Client states that the DMK had won a decisive victory in all the constituencies in Tamil Nadu, barring one, during the Parliamentary Elections of May 2019 and in the Thoothukkudi Constituency, Our Client had won by a significant margin of 347,209 votes over the candidate of your party. The BJP — to which you belong and its allies were totally rejected by the people of Tamil Nadu because of their economic, communal, anti-federal, anti-Tamil and undemocratic policies and actions. Unable to digest the defeat, the leaders of the BJP, including you, have commenced and co-ordinated various mudslinging campaigns against the DMK and its leaders, which has culminated in the latest publicaliun ur lhe Deratnalury Video, As such, the actlons leadlng to the publjcaltun UI lhe Detamatory Video are born out of political iilåliee.
9. Our Client states that this is purely a politically motivated, ill-thought out and ulterior strategy employed by you to divert the attention of the people from the real issues affecting the people of Tamil Nadu and is intended to defame and discredit the DMK, in view of the General Election to the House of People to be conducted in April May 2024. Our Client further

states that you have fabricated these untrue, unfounded, and defamatory accusations in an effort to harm the reputations of the DMK and Our Client, to which she belongs.
10. Our Client states that the above-mentioned Defamatory Video published by you during the Press Conference conducted on 14.04.2023 at your party headquarters’ in Chennai makes you liable to be proceeded against, both under criminal and civil law. The constitutional protection of the freedom of speech and expression is subject to reasonable restrictions, which includes defamation. Therefore, these actions fall beyond the scope of free speech and expression. Moreover, it is clear that you are seeking political mileage and your ulterior motive is apparent from your statements at the Press Conference. Additionally, it is evident that you have no legitimate justification for distributing the said Defamatory Video.
1 1. Our Client states that, in any case, you ought to have verified the correctness of your claims and should have inquired into the subject matter of the Defamatory Video prior to publishing the same. Your actions have caused serious and irreparable loss, injury and damage to Our Client, for which you are solely liable.
12. Our Client further states that a number of friends, associates and wellwishers had called to enquire about the offending Defamatory Video and mentioned hereinabove. Furthermore, the libel that ou made in the Defamatory Video, has prompted inquiries from a number of constituents, party cadres, well-wishers and members of the general public, which maligns the reputation on both private and public spheres.

13. The combined acts listed hereinabove amount to offences punishable under Sections 499 and 500 of the Indian Penal Code, 1860. Due to the act of publishing the aforementioned Defamatory Video relating to Our Client, she has suffered immeasurable mental agony and torture resulting in unquantified damages, which, for the sake of court proceedings, is restricted to around INR (Rupees One Crore). Our Client, therefore, through this Notice, hereby calls upon you to:
(a) Withdraw and remove the above-mentioned Defamatory Video from above-tabulated platforms (refer to Para No.5 hereinabove) within 48 (forty-eight) hours from receipt of this
Notice;
(b) Tender an open and unconditional apology to Our Client within 48 (forty-eight) hours from receipt of this Notice;
(c) Cease and desist from making the unfounded allegations made against Our Client in the Defamatory Video in any form of public communication, including but not limited to speaking, writing, publishing, broadcasting, or other types of dissemination of information; and
(d) Refrain from repeating such unlawful acts in the future,
failing which, Our Client will be constrained to file a Civil Suit thus holding you liable for all costs and consequences arising therefrom.
Sincerely,

(S. MANURAJ)