LEGAL NOTICE copy by Dmk to Anamalai

p W I L S O N
AS SO C I ATES
Date: 26.03.2022
K. Annamalai
State President, Tamil Nadu
Bharatiya Janata Party,
Kamalalayam ,
Vaidyaraman Street, Parthasarathi Puram,
T. Nagar,
Chennai 600 017
LEGAL NOTICE
Sir,
Under instructions from our client Mr. R.S. Bharathi, Organising
Secretary, Dravida Munnetra Kazhagam having office at ‘Anna Arivalayam’, No. 367 & 369, Anna Salai, Teynampet, Chennai 600 018, we hereby issue you the following legal notice:
1. Our client states that he is the Organising Secretary of the DMK party. Our client states that the DMK Party, under the leadership and guidance of the Party’s President Thiru. M.K. Stalin, won the Tamil Nadu Legislative Assembly Elections in May 2021 with a thumping majority and Thiru M.K. Stalin assumed office as the Hon ble Chief Minister of Tamil Nadu. This victory is a clear representation of the trust and faith that the people of Tamil Nadu have for our party President Thiru. M.K. Stalin. After assuming office as Chief Minister of Tamil Nadu, Thiru M.K. Stalin has worked tirelessly and has introduced several schemes for the welfare and development of the people of Tamil Nadu and is now

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widely recognised as one of the best Chief Ministers in the country.
2. Our client states that you are an ex-IPS officer and currently the Tamil Nadu BJP State President. As you and your party have been unable to make a mark electorally in the State of Tamil Nadu, you have been making constant attempts to defame, scandalise and tarnish the reputation of the DMK President, and other leaders and members of the party. You have been constantly making vile, defamatory and scandalous statements against our party President with a mala fide intention.
3. Our client states that the DMK President/ Hon ‘ble Chief Minister of Tamil Nadu, in the course of discharging his official duties, has travelled to Dubai to attend the Dubai Expo 2022 to attract foreign investment into the State of Tamil Nadu so as to generate employment and to boost the economy of the State. Since our party President became the Chief Minister, he has left no stone unturned to develop the State, but at the same time keeping in mind social equality. This being so, you have repeatedly attempted to tarnish, defame and sully the DMK President / Hon ‘ble Chief Minister’s good name by making completely false, vile and scandalous statements in public.
4. Our client states that in pursuance of this nefarious scheme, on 24.03.2022, you participated and led a “protest” in Virudhunagar near MGR Statue between 10.30 am to 12 noon wherein you have made several vile, scandalous, malicious and false allegations against the DMK President/ Hon ble Chief Minister, Mr MK Stalin. The speech made by you in Virudhunagar is enclosed as Annexure I which may be read as part and parcel of this Notice.
Our client states that without even making basic enquiry as to the veracity of the statements you are making, without having basic general knowledge or awareness of local and global events, you have made these false allegations. In the said meeting, you have stated that anyone doing criminal activities requires an alibi and that the DMK President/ Hon ‘ble Chief Minister has travelled to Dubai only as an alibi and that he has travelled only to commit some crime. You have made these statements knowing full well that they are grossly false, frivolous malicious and untrue, with the sole intention to defame, denigrate and cause injury to our DMK Leader’s name and fame and his reputation and project the Hon ‘ble Chief Minister as if he is indulging in some crime. Such statements tend to lower the reputation and image of the DMK President/ Hon ‘ble Chief Minister amongst the general public. When the Hon ‘ble Chief Minister has travelled to Dubai in discharge of his official functions, surrounded by public officials and is spending each minute of his trip on official business, only an injudicious person would make these allegations. You are clearly making these statements to defame our DMK President/ Hon ble Chief Minister’s image and cause dent on his reputation and gain cheap publicity.
5. Our client further states that again on 25.03.2022, between 11.00 am to 12.30 pm you conducted another “protest” in Nungambakkam, Chennai wherein you have once again made false and defamatory statements against the DMK President/ Hon ‘ble Chief Minister Mr MK Stalin and his family. The speech given by you during the protest is enclosed as Annexure Il which may be read as part and parcel of this Notice. Here again, you have cast malicious aspersions against Mr MK Stalin about his official trip to Dubai to attend “Dubai Expo 2022” without having even an iota of information or knowledge, you have made per se false, baseless and defamatory allegations that all foreign investments will only be for the benefit of the Hon ble Chief Minister and his family. Our client states that your baseless allegations are part of your scheme to defame the DMK President / Hon ble Chief Minister Mr MK Stalin since you are unable to digest his popularity with the people of the State and schemes brought by him to the State and indeed the country.
6. Further, our client states that you have made false statements that the Hon ‘ble Chief Minister’s family function is taking place in Dubai. Such allegations are per se baseless and highly defamatory. Our client states that even a layman knows that the Dubai Expo 2022 is currently taking place and that the Hon ‘ble Chief Minister is attending the same in the interest of the State ‘to attract investments in to the State. The news media have documented that the Hon ‘ble Chief Minister has met with the top leaders of Dubai and also industry leaders, who have already responded positively to invest in Tamil Nadu. This would contribute to the development of the State and indeed the nation. However, you do not have even this basic level of knowledge and yet claim to be a politically spirited person. Our client states that quite ironically, you are the State President of Bharatiya Janta Party, yet you do not have the slightest idea of political, social or economical climate m Tamil Nadu, India and around the world. Our client states that you have made these statements as a cheap publicity stunt and nothing more, with a view to gain political

mileage at the expense of the reputation and image of the DMK President/ Hon ble Chief Minister Mr MK Stalin. One can only conclude that these statements besides being defamatory are anti national, and liable to be dealt with as seditious, since you are attempting to sabotage foreign investments into India.
7. Our client states that you have made these statements in full public view, which are false, defamatory and scandalous and tends to destroy the DMK President / Hon ble Chief Minister Mr MK Stalin’s image and reputation amongst the public. It is well settled that right to freedom of speech and expression is subject to reasonable restrictions which include defamation of a person. Our client states that your action of making wild, false, baseless and defamatory allegations with scandalous imputations against the DMK President/ Hon ble Chief Minister Mr MK Stalin attracts penal provisions under Section 499 and 500 of the Indian Penal Code. Without prejudice to the fact that the abovementioned statements are also liable to be prosecuted under section 199 of the CrPC since you have made defamatory statements against the Hon ble Chief Minster in discharge of his public duties, this Legal Notice is issued to you as it causes damage on the reputation of our DMK President Mr MK Stalin. These statements made by you in full public view have caused immense damage to the DMK President/ Hon ble Chief Minister’s social, political and personal reputation. Further, this notice is issued to you for your defamatory statements as mentioned above and without prejudice to the same being dealt with in accordance with law by the
Hon ble Chief Minister. Therefore, you are liable to pay damages.
8. Our client therefore calls upon you to
a. Tender an unconditional public to the Hon ble Chief
Minister of Tamil Nadu within 24 hours;
b. Cease and desist from making defamatory statements against the DMK President/ Hon ble Chief Minister of Tarnil Nadu Mr MK Stalin;
c. Pay damages to the tune of Rs. (Rupees
Hundred Crores only) payable to the Hon ‘ble Chief Minister of Tamil Nadu’s relief fund within two days from the date of receipt of this legal notice
failing which our client will be constrained to initiate appropriate civil and criminal proceedings holding you liable for all costs and consequences arising therefrom.

SETTLED BY
P.WILSON
Senior Advocate P. WILSON ASSOCIATES
Emc.LSeA AS