R.C. PAUL KANAGARAJ, B.L., ADVOCATE                      To  Date: 05-05-2023 Mr.S. Manuraj Advocate 1K, Gaiety Palace No.l, Blackers Road, Chennai – 600 002 Sir, Ref:- Legal notice dated 25/04/2023 on behalf of Mrs. Kanimozhi Karunanidhi The above referred notice has been placed in my hands by my client Thiru. K. Annamalai, S/o .Kuppusamy, having office at ‘Kamalalayam’, Vaidyaraman street,- Parthasarathipuram. நாங்க ரெடி நீங்க ரெடியா?,

R.C. PAUL KANAGARAJ, B.L.,

ADVOCATE

To  Date: 05-05-2023

Mr.S. Manuraj

Advocate

1K, Gaiety Palace No.l,

Blackers Road, Chennai – 600 002

Sir,

Ref:- Legal notice dated 25/04/2023 on behalf of Mrs. Kanimozhi Karunanidhi

The above referred notice has been placed in my hands by my client Thiru. K. Annamalai, S/o .Kuppusamy, having office at ‘Kamalalayam’, Vaidyaraman street,- Parthasarathipuram,

T.Nagar, Chennai-600 017, with instructions to reply as under:-

1. My client denies all. the statements in your notice except those are specifically admitted hereunder and your client is put to strict proof of the same.
2. My client at the outset states that the all the statements by him in the interview which is the subject matter of the notice under reply were made by him bonafide, in larger public interest and to create awareness about the actual facts and figures among the common public. There is absolutely no violation of any law of defamation as sought to be alleged in your notice. The mode and manner in which your notice is issued is nothing but a feeble attempt to act with impunity. This act itself is indicative that the notice is nothing but a feverish attempt to somehow or other prevent the people from knowing the facts, figures and truth, which was the subject matter of my clients interview and a peevish attempt to subvert and suppress my client from voicing the truth by threatening legal proceedings. Your client may well be advised that my client stands by the statements made by him, and has made the statements with all responsibility in the larger public interest of knowledge to the public, and after due diligence as to the correctness of the facts and figures.
3. My client states that the averments in para 1 to 3 of your notice relate to your client’s political background and alleged achievements in the field. My client denies that all the posts held by her and her election victories were on account of her merit.

: paulkanagaraj16@gmail.com

Mobile : 98400 75747, 94443 75747

2

My client states that all these are a direct result of only her dynastic inheritance from her father. My client denies that your client’s party is the foremost political party in the state. My client denies that your client has dedicated her career to advancing the principles of self-respect, women’s empowerment or any other values. “. My client states that Your client has been accused of.erious offences in .the pas!ang case renatihg to corruption allegations against her is still

4. My client stands by his comments made about your client during press conference on 14/04/2023. My client has portrayed the correction picture of your client’s wealth. My client is in possession of sufficient material to establish both the value of the assets and your client’s connection with them. My client will produce the same before the appropriate authorities at the appropriate stage.
5. My client vehemently denies allegations in para 8 & 9 of your notice. My client had no motive in giving the press conference on 14/04/2023 except generating awareness about political corruption perpetuated by your client and your client’s party.
6. My client denies that his statements could have prompted inquiries “from a number of constituents, party cadres, well-wishers and members of the general public
7. My client states that he has made sufficient enquiries and exercised due diligence before publishing the statements regarding your client. My client states that your notice is nothing but an attempt to muzzle his voice. My client denies he has committed any offence. There is no question of rendering any apology or paying damages. Rather than accepting the legal and moral responsibility for the various acts of corruption, your client has attempted to use the law of defamation to intimidate and silence my client and prevent an open discussion on an issue of immense public interest. My client states that by claiming such fanciful amounts as compensation your client wants to not just sensationalize the issue and deflect public attention.
8. In spite of the above, if your client ventures to initiate any action against my client, the same shall be suitably defended by my client at your client’s risk and cost.

Date: 05-05-2023     Yours sincerely

Chennai