Counter by seeman / Advocate sanker filed mhc in varun kumar case / Dr. Varun Kumar, IPS (40/2024) S/o. Dr. R. Veerasekaran, Residing at No.C/91, 7th Cross, Thillai Nagar West, Trichy, Tamil Nadu …Applicant/Plaintiff Vs. Mr. Seeman,
IN THE HIGH COURT OF JUDICATURE AT MADRAS
(ORDINARY ORIGINAL CIVIL JURISDICTION)
O.A.No. 119850 of 2025
In
C.S.No. 119840 of 2025
Dr. Varun Kumar, IPS (40/2024)
S/o. Dr. R. Veerasekaran,
Residing at No.C/91,
7th Cross, Thillai Nagar West,
Trichy, Tamil Nadu
…Applicant/Plaintiff
Vs.
Mr. Seeman,
S/o. Senthamizhan,
Residing at No. 529, Sandeep Avenue,
Neelangarai,
Chennai – 600 115
…Respondent/Defendant
AFFIDAVIT OF SEEMAN
I, Seeman S/o. Senthamizhan, Indian, aged about 60 years residing at No. 529, Sandeep Avenue, Neelangarai, Chennai – 600 115 do hereby solemnly affirm and sincerely state as follows:
1. I am the respondent herein and I am fully conversant with the facts of the case.
2. I state that I am filing this counter affidavit denying the entire allegations made in the affidavit filed by the petitioner as false and contrary to the truth. The petitioner is put to strict proof of the allegations made in the affidavit filed by the petitioner.
3. I state that the suit filed by the petitioner seeking the relief of damages, permanent injunction and mandatory injunction is not maintainable. Since there is no valid cause of action to file the suit by the petitioner, the suit is liable to be dismissed in limini. However, this respondent without prejudice, his contention in respect of maintainability of the suit submits this counter affidavit to substantiate that the application is also misconceived and deserves dismissal.
4. I state that the averments in Para 1 to Para 7 are not admitted by the petitioner. The petitioner suppressed the facts and has come forward with the suit and application by statement expressing excessive pride of himself. Since the petitioner has shamelessly exhibited vainglory, it has become necessary for the respondent to place on record before this Hon’ble Court the stigma suffered by the petitioner while serving as police officer.
(i) The petitioner while undergoing training academy at New Delhi developed relationship with one G. Priyadharshini and had relationship with her. The relationship was accepted by the both the parents of the petitioner and said Priyadharshini but did not result in marriage as the petitioner demanded a huge dowry of Rs.50,00,000-/ in cash, 2 Kgs of Gold and a BMW car. A criminal case was filed against the petitioner under section 406, 417, 420, 506 Part 1 of IPC R/w section 4 of Dowry Prohibition Act of 1961, section 4 of Tamil Nadu Prohibition of Harassment of Women Act, 1988 and under section 66 of the Information Technology Act, 2000. The petitioner was remanded to Judicial custody by the trial court.
(ii) The petitioner challenged the final report filed against the petitioner in C.C No.2036 of 2015 before the XI Metropolitan Magistrate of Saidapet, Chennai by filing the quash petition in Crl.O.P.No. 14573 of 2017 before this Hon’ble Court on 26. 06.2018. The petition was allowed and complaint was quashed. The De-facto complainant G. Priyadharshini preferred a Criminal appeal by filing S.L.P. Crl No.5746-48 of 2018 before the Hon’ble Supreme Court of India. The Hon’ble Supreme Court disposed of the SLP in terms of Compromise reached by the petitioner with the De-facto complainant. The petitioner who indulged in tarnishing the name and reputation of the De-facto complainant paid a compensation of Rs.11,00,000-/ to the De-facto complainant. Thus, the petitioner has no clean record to proclaim himself as a man having excellent track record in professional career.
(iii) The petitioner always used to post in his Instagram handle and Mail with exaggerated claims. The petitioner never had any modest approach towards the discharge of official duties. The petitioner while serving as Superintendent of Police, Ramanathapuram was removed from the posting due to the display of his view in the twitter account. The impartial investigation in a sensitive case could not be ensured by the petitioner and that resulted in his immediate transfer. The news was reported in newspapers and the petitioner was transferred from Ramanathapuram for his immature and insensitive comment in his twitter in respect of an investigation related to a sensitive murder.
These facts are sufficient to know the character and conduct of the petitioner as such the claim of the petitioner that his dedication, moral fortitude and adherence of high standard of professionalism are just without any basis and without any remorse.
5. I state that the averments in Para 1 to Para 5 are utter falsehood just as been invented for the purpose of the filing of the suit. It is an illusion that the track record and professional career of the petitioner is tarnished by the utterances made by the respondent while giving reply to the questions based by the press and media. As such the allegations in Para 6 and Para 7 are either due to total misconception by the petitioner or due to his lack of understanding.
6. I state that the allegations in Para 8 are not admitted by me. I am the Chief Coordinator of Naam Tamizhar Katchi. I never make any controversial statements. My Party’s main object is to coordinate the Tamil born and Tamil speaking people and espouse their causes and redress their grievances. I am striving to uplift the Tamil people and promote the awareness among the people to safeguard our ancient values and heritage. At times I have to submit my views by making emotive appeals and addressing forcible arguments so as to convey my deep concern for the people of the Tamil Nadu. It is quite natural to face criticism against any policy and ideologies propagated by any political party. The criticism is the basic right in a democracy which reflects the true spirit of democracy. I wonder how the petitioner who has become an IPS officer misconstrued the criticism as an affront. When the Hon’ble Supreme Court has repeatedly held that fair criticism of the Government and seeking regional autonomy is not an offence and permitted constitutional right conferred to every citizen. While so the petitioner who developed hatred against my speech may be because of his ideology and affiliation.
7. I state that the allegations and averments in Para 9 to Para 11 are denied by me. I never made any defamatory statement as against the petitioner except finding fault with his selective discharge of police powers against my party cadres. The statements made by me are not voluntary but answers given to press and media when they specifically referred to the deliberate allegations made by the petitioner against me and my party. I never either directly or indirectly indulged in cheap politics of making personal comments or denigrating any person in public. Throughout my political career I made criticisms against the political opponents but never maligned their personal life and character. Further, I never instigated or encouraged my cadres to make allegations and insinuations against any political leaders and officials. Whenever it is brought to my knowledge about the usage of harsh language by my cadres, I advise them not to make such allegations and refrain them from repeating the same. When there is no material available to substantiate my role or my in-action seeking ominous/blanket relief of injunction is not maintainable.
8. I state that the allegations made in Para 11 and the transcription of press meet are specifically denied by me. The petitioner is put to strict proof of video transcriptions allegedly made by me as against the petitioner. The pen drive provided to me by the petitioner was carefully watched by me and except the first video referred, in other videos Utterances were made by me against the ruling party and ruling dispensation. The perception of facts as perceived by me from the conduct of the petitioner in the discharge of the official duties. The petitioner worked as Superintendent of Police, Thiruvallur District and the petitioner had invoked Goondas Act to detain my party’s propaganda secretary Sattai Duraimurugan based on political statement made by him. Based on the instance of the petitioner, the Goondas act was invoked and the same was quashed by the Hon’ble High Court. The petitioner when transferred to Trichy again registered a case in Crime No.374 of 2024 on 10.07.2024 and attempted to remand Sattai Durai Murugan. The Learned First Additional District Judge (PCR) set the said sattai Durai Murugan at liberty and refused to remand. Then the petitioner registered another case in Crime no.547 of 2024 in Thillai nagar, P.S and attempted to arrest the said sattai Durai Murugan. In that case the Hon’ble High Court has granted anticipatory bail to the said Sattai Durai Murugan. Thus, the petitioner either on his own or due to political pressure had been continuously attempting to implicate the cadres of the respondent with view to demoralize them and to appease the ruling party and the same could be inferred from the instagram posts and highlights made by the petitioner in his account. Thus, the petitioner abuses his official position and invited wrath of the cadres of my party which might have enraged some of the cadres and they could have reacted strongly. I am in no way responsible for the abusive posts made by persons who were not under my control. Had the petitioner specifically brought to my notice with the proof against my cadres, I would have taken immediate steps as I do not approve personal attacks on politicians and officials.
9. I state that the averments made in Para 12 to Para 18 are pure imagination and baseless apprehensions without any iota of truth. I never made any defamatory statement just retorted and replied to the statements made against me by the petitioner and against the actions made by the petitioner. As I already stated in the earlier paragraph the petitioner does not have any reputation. The petitioner himself identified with ruling party and unnecessarily and without any material with malafide intention made scathing allegations against me and my party at IPS Officers Conference and expressed his view without any material to ban my party as if my party is canvassing for separation. This above speech reflects the hatred developed by the petitioner against me and my party. Even now I apprehend that the petitioner at the behest of ruling party as taken action against me for defamation both under civil and criminal law in the absence of credible material.
10. I state that the averments made in Para 19 to Para 26 are reproduction of the earlier paragraphs and allegations made without any material. I made it clear by issuing the statement even in the August month of 2024 that I have nothing to do with allegations made against the petitioner and the same was also posted in his Instagram account by the petitioner as such it is false to repeat the allegations that I made derogatory statements against the petitioner. The entire suit and application are misconceived and liable to be dismissed. No occasion has arisen for me to seek apology as I never slandered the petitioner by making abusive words. If the petitioner is unable to digest fair criticisms, then the petitioner is unfit to be a police officer. My humble view is it is high time the petitioner needs psychological counselling as the petitioner is imbibed with vainglory phobia.
In these circumstances it is therefore most respectfully prayed that this Hon’ble Court maybe pleased to dismiss the petition filed by the petitioner seeking injunction against me as not maintainable and pass such further or other order that may deem fit and proper and thus render justice.
Solemnly affirmed at Chennai Deponent
on this the 24th day of October
2025 and he signed his name
in my presence Before Me
IN THE HIGH COURT OF JUDICATURE AT MADRAS
(ORDINARY ORIGINAL CIVIL JURISDICTION)
O.A.No. 119850 of 2025
In
C.S.No. 119840 of 2025
Dr. Varun Kumar, IPS (40/2024)
…Applicant/Plaintiff
Vs.
Mr. Seeman,
…Respondent/Defendant
AFFIDAVIT OF SEEMAN
M/s. S.SHANKAR 669/1996
S.RUBAN
COUNSEL FOR RESPONDENT
IN THE HIGH COURT OF JUDICATURE AT MADRAS
(ORDINARY ORIGINAL CIVIL JURISDICTION)
O.A.No. 119850 of 2025
In
C.S.No. 119840 of 2025
Dr. Varun Kumar, IPS (40/2024)
S/o. Dr. R. Veerasekaran,
Residing at No.C/91,
7th Cross, Thillai Nagar West,
Trichy, Tamil Nadu
…Applicant/Plaintiff
Vs.
Mr. Seeman,
S/o. Senthamizhan,
Residing at No. 529, Sandeep Avenue,
Neelangarai,
Chennai – 600 115
…Respondent/Defendant
AFFIDAVIT OF SEEMAN
I, Seeman S/o. Senthamizhan, Indian, aged about 60 years residing at No. 529, Sandeep Avenue, Neelangarai, Chennai – 600 115 do hereby solemnly affirm and sincerely state as follows:
1. I am the respondent herein and I am fully conversant with the facts of the case.
2. I state that I am filing this counter affidavit denying the entire allegations made in the affidavit filed by the petitioner as false and contrary to the truth. The petitioner is put to strict proof of the allegations made in the affidavit filed by the petitioner.
3. I state that the suit filed by the petitioner seeking the relief of damages, permanent injunction and mandatory injunction is not maintainable. Since there is no valid cause of action to file the suit by the petitioner, the suit is liable to be dismissed in limini. However, this respondent without prejudice, his contention in respect of maintainability of the suit submits this counter affidavit to substantiate that the application is also misconceived and deserves dismissal.
4. I state that the averments in Para 1 to Para 7 are not admitted by the petitioner. The petitioner suppressed the facts and has come forward with the suit and application by statement expressing excessive pride of himself. Since the petitioner has shamelessly exhibited vainglory, it has become necessary for the respondent to place on record before this Hon’ble Court the stigma suffered by the petitioner while serving as police officer.
(i) The petitioner while undergoing training academy at New Delhi developed relationship with one G. Priyadharshini and had relationship with her. The relationship was accepted by the both the parents of the petitioner and said Priyadharshini but did not result in marriage as the petitioner demanded a huge dowry of Rs.50,00,000-/ in cash, 2 Kgs of Gold and a BMW car. A criminal case was filed against the petitioner under section 406, 417, 420, 506 Part 1 of IPC R/w section 4 of Dowry Prohibition Act of 1961, section 4 of Tamil Nadu Prohibition of Harassment of Women Act, 1988 and under section 66 of the Information Technology Act, 2000. The petitioner was remanded to Judicial custody by the trial court.
(ii) The petitioner challenged the final report filed against the petitioner in C.C No.2036 of 2015 before the XI Metropolitan Magistrate of Saidapet, Chennai by filing the quash petition in Crl.O.P.No. 14573 of 2017 before this Hon’ble Court on 26. 06.2018. The petition was allowed and complaint was quashed. The De-facto complainant G. Priyadharshini preferred a Criminal appeal by filing S.L.P. Crl No.5746-48 of 2018 before the Hon’ble Supreme Court of India. The Hon’ble Supreme Court disposed of the SLP in terms of Compromise reached by the petitioner with the De-facto complainant. The petitioner who indulged in tarnishing the name and reputation of the De-facto complainant paid a compensation of Rs.11,00,000-/ to the De-facto complainant. Thus, the petitioner has no clean record to proclaim himself as a man having excellent track record in professional career.
(iii) The petitioner always used to post in his Instagram handle and Mail with exaggerated claims. The petitioner never had any modest approach towards the discharge of official duties. The petitioner while serving as Superintendent of Police, Ramanathapuram was removed from the posting due to the display of his view in the twitter account. The impartial investigation in a sensitive case could not be ensured by the petitioner and that resulted in his immediate transfer. The news was reported in newspapers and the petitioner was transferred from Ramanathapuram for his immature and insensitive comment in his twitter in respect of an investigation related to a sensitive murder.
These facts are sufficient to know the character and conduct of the petitioner as such the claim of the petitioner that his dedication, moral fortitude and adherence of high standard of professionalism are just without any basis and without any remorse.
5. I state that the averments in Para 1 to Para 5 are utter falsehood just as been invented for the purpose of the filing of the suit. It is an illusion that the track record and professional career of the petitioner is tarnished by the utterances made by the respondent while giving reply to the questions based by the press and media. As such the allegations in Para 6 and Para 7 are either due to total misconception by the petitioner or due to his lack of understanding.
6. I state that the allegations in Para 8 are not admitted by me. I am the Chief Coordinator of Naam Tamizhar Katchi. I never make any controversial statements. My Party’s main object is to coordinate the Tamil born and Tamil speaking people and espouse their causes and redress their grievances. I am striving to uplift the Tamil people and promote the awareness among the people to safeguard our ancient values and heritage. At times I have to submit my views by making emotive appeals and addressing forcible arguments so as to convey my deep concern for the people of the Tamil Nadu. It is quite natural to face criticism against any policy and ideologies propagated by any political party. The criticism is the basic right in a democracy which reflects the true spirit of democracy. I wonder how the petitioner who has become an IPS officer misconstrued the criticism as an affront. When the Hon’ble Supreme Court has repeatedly held that fair criticism of the Government and seeking regional autonomy is not an offence and permitted constitutional right conferred to every citizen. While so the petitioner who developed hatred against my speech may be because of his ideology and affiliation.
7. I state that the allegations and averments in Para 9 to Para 11 are denied by me. I never made any defamatory statement as against the petitioner except finding fault with his selective discharge of police powers against my party cadres. The statements made by me are not voluntary but answers given to press and media when they specifically referred to the deliberate allegations made by the petitioner against me and my party. I never either directly or indirectly indulged in cheap politics of making personal comments or denigrating any person in public. Throughout my political career I made criticisms against the political opponents but never maligned their personal life and character. Further, I never instigated or encouraged my cadres to make allegations and insinuations against any political leaders and officials. Whenever it is brought to my knowledge about the usage of harsh language by my cadres, I advise them not to make such allegations and refrain them from repeating the same. When there is no material available to substantiate my role or my in-action seeking ominous/blanket relief of injunction is not maintainable.
8. I state that the allegations made in Para 11 and the transcription of press meet are specifically denied by me. The petitioner is put to strict proof of video transcriptions allegedly made by me as against the petitioner. The pen drive provided to me by the petitioner was carefully watched by me and except the first video referred, in other videos Utterances were made by me against the ruling party and ruling dispensation. The perception of facts as perceived by me from the conduct of the petitioner in the discharge of the official duties. The petitioner worked as Superintendent of Police, Thiruvallur District and the petitioner had invoked Goondas Act to detain my party’s propaganda secretary Sattai Duraimurugan based on political statement made by him. Based on the instance of the petitioner, the Goondas act was invoked and the same was quashed by the Hon’ble High Court. The petitioner when transferred to Trichy again registered a case in Crime No.374 of 2024 on 10.07.2024 and attempted to remand Sattai Durai Murugan. The Learned First Additional District Judge (PCR) set the said sattai Durai Murugan at liberty and refused to remand. Then the petitioner registered another case in Crime no.547 of 2024 in Thillai nagar, P.S and attempted to arrest the said sattai Durai Murugan. In that case the Hon’ble High Court has granted anticipatory bail to the said Sattai Durai Murugan. Thus, the petitioner either on his own or due to political pressure had been continuously attempting to implicate the cadres of the respondent with view to demoralize them and to appease the ruling party and the same could be inferred from the instagram posts and highlights made by the petitioner in his account. Thus, the petitioner abuses his official position and invited wrath of the cadres of my party which might have enraged some of the cadres and they could have reacted strongly. I am in no way responsible for the abusive posts made by persons who were not under my control. Had the petitioner specifically brought to my notice with the proof against my cadres, I would have taken immediate steps as I do not approve personal attacks on politicians and officials.
9. I state that the averments made in Para 12 to Para 18 are pure imagination and baseless apprehensions without any iota of truth. I never made any defamatory statement just retorted and replied to the statements made against me by the petitioner and against the actions made by the petitioner. As I already stated in the earlier paragraph the petitioner does not have any reputation. The petitioner himself identified with ruling party and unnecessarily and without any material with malafide intention made scathing allegations against me and my party at IPS Officers Conference and expressed his view without any material to ban my party as if my party is canvassing for separation. This above speech reflects the hatred developed by the petitioner against me and my party. Even now I apprehend that the petitioner at the behest of ruling party as taken action against me for defamation both under civil and criminal law in the absence of credible material.
10. I state that the averments made in Para 19 to Para 26 are reproduction of the earlier paragraphs and allegations made without any material. I made it clear by issuing the statement even in the August month of 2024 that I have nothing to do with allegations made against the petitioner and the same was also posted in his Instagram account by the petitioner as such it is false to repeat the allegations that I made derogatory statements against the petitioner. The entire suit and application are misconceived and liable to be dismissed. No occasion has arisen for me to seek apology as I never slandered the petitioner by making abusive words. If the petitioner is unable to digest fair criticisms, then the petitioner is unfit to be a police officer. My humble view is it is high time the petitioner needs psychological counselling as the petitioner is imbibed with vainglory phobia.
In these circumstances it is therefore most respectfully prayed that this Hon’ble Court maybe pleased to dismiss the petition filed by the petitioner seeking injunction against me as not maintainable and pass such further or other order that may deem fit and proper and thus render justice.
Solemnly affirmed at Chennai Deponent
on this the 24th day of October
2025 and he signed his name
in my presence Before Me
IN THE HIGH COURT OF JUDICATURE AT MADRAS
(ORDINARY ORIGINAL CIVIL JURISDICTION)
O.A.No. 119850 of 2025
In
C.S.No. 119840 of 2025
Dr. Varun Kumar, IPS (40/2024)
…Applicant/Plaintiff
Vs.
Mr. Seeman,
…Respondent/Defendant
AFFIDAVIT OF SEEMAN
M/s. S.SHANKAR 669/1996
S.RUBAN
COUNSEL FOR RESPONDENT
IN THE HIGH COURT OF JUDICATURE AT MADRAS
(ORDINARY ORIGINAL CIVIL JURISDICTION)
O.A.No. 119850 of 2025
In
C.S.No. 119840 of 2025
Dr. Varun Kumar, IPS (40/2024)
S/o. Dr. R. Veerasekaran,
Residing at No.C/91,
7th Cross, Thillai Nagar West,
Trichy, Tamil Nadu
…Applicant/Plaintiff
Vs.
Mr. Seeman,
S/o. Senthamizhan,
Residing at No. 529, Sandeep Avenue,
Neelangarai,
Chennai – 600 115
…Respondent/Defendant
AFFIDAVIT OF SEEMAN
I, Seeman S/o. Senthamizhan, Indian, aged about 60 years residing at No. 529, Sandeep Avenue, Neelangarai, Chennai – 600 115 do hereby solemnly affirm and sincerely state as follows:
1. I am the respondent herein and I am fully conversant with the facts of the case.
2. I state that I am filing this counter affidavit denying the entire allegations made in the affidavit filed by the petitioner as false and contrary to the truth. The petitioner is put to strict proof of the allegations made in the affidavit filed by the petitioner.
3. I state that the suit filed by the petitioner seeking the relief of damages, permanent injunction and mandatory injunction is not maintainable. Since there is no valid cause of action to file the suit by the petitioner, the suit is liable to be dismissed in limini. However, this respondent without prejudice, his contention in respect of maintainability of the suit submits this counter affidavit to substantiate that the application is also misconceived and deserves dismissal.
4. I state that the averments in Para 1 to Para 7 are not admitted by the petitioner. The petitioner suppressed the facts and has come forward with the suit and application by statement expressing excessive pride of himself. Since the petitioner has shamelessly exhibited vainglory, it has become necessary for the respondent to place on record before this Hon’ble Court the stigma suffered by the petitioner while serving as police officer.
(i) The petitioner while undergoing training academy at New Delhi developed relationship with one G. Priyadharshini and had relationship with her. The relationship was accepted by the both the parents of the petitioner and said Priyadharshini but did not result in marriage as the petitioner demanded a huge dowry of Rs.50,00,000-/ in cash, 2 Kgs of Gold and a BMW car. A criminal case was filed against the petitioner under section 406, 417, 420, 506 Part 1 of IPC R/w section 4 of Dowry Prohibition Act of 1961, section 4 of Tamil Nadu Prohibition of Harassment of Women Act, 1988 and under section 66 of the Information Technology Act, 2000. The petitioner was remanded to Judicial custody by the trial court.
(ii) The petitioner challenged the final report filed against the petitioner in C.C No.2036 of 2015 before the XI Metropolitan Magistrate of Saidapet, Chennai by filing the quash petition in Crl.O.P.No. 14573 of 2017 before this Hon’ble Court on 26. 06.2018. The petition was allowed and complaint was quashed. The De-facto complainant G. Priyadharshini preferred a Criminal appeal by filing S.L.P. Crl No.5746-48 of 2018 before the Hon’ble Supreme Court of India. The Hon’ble Supreme Court disposed of the SLP in terms of Compromise reached by the petitioner with the De-facto complainant. The petitioner who indulged in tarnishing the name and reputation of the De-facto complainant paid a compensation of Rs.11,00,000-/ to the De-facto complainant. Thus, the petitioner has no clean record to proclaim himself as a man having excellent track record in professional career.
(iii) The petitioner always used to post in his Instagram handle and Mail with exaggerated claims. The petitioner never had any modest approach towards the discharge of official duties. The petitioner while serving as Superintendent of Police, Ramanathapuram was removed from the posting due to the display of his view in the twitter account. The impartial investigation in a sensitive case could not be ensured by the petitioner and that resulted in his immediate transfer. The news was reported in newspapers and the petitioner was transferred from Ramanathapuram for his immature and insensitive comment in his twitter in respect of an investigation related to a sensitive murder.
These facts are sufficient to know the character and conduct of the petitioner as such the claim of the petitioner that his dedication, moral fortitude and adherence of high standard of professionalism are just without any basis and without any remorse.
5. I state that the averments in Para 1 to Para 5 are utter falsehood just as been invented for the purpose of the filing of the suit. It is an illusion that the track record and professional career of the petitioner is tarnished by the utterances made by the respondent while giving reply to the questions based by the press and media. As such the allegations in Para 6 and Para 7 are either due to total misconception by the petitioner or due to his lack of understanding.
6. I state that the allegations in Para 8 are not admitted by me. I am the Chief Coordinator of Naam Tamizhar Katchi. I never make any controversial statements. My Party’s main object is to coordinate the Tamil born and Tamil speaking people and espouse their causes and redress their grievances. I am striving to uplift the Tamil people and promote the awareness among the people to safeguard our ancient values and heritage. At times I have to submit my views by making emotive appeals and addressing forcible arguments so as to convey my deep concern for the people of the Tamil Nadu. It is quite natural to face criticism against any policy and ideologies propagated by any political party. The criticism is the basic right in a democracy which reflects the true spirit of democracy. I wonder how the petitioner who has become an IPS officer misconstrued the criticism as an affront. When the Hon’ble Supreme Court has repeatedly held that fair criticism of the Government and seeking regional autonomy is not an offence and permitted constitutional right conferred to every citizen. While so the petitioner who developed hatred against my speech may be because of his ideology and affiliation.
7. I state that the allegations and averments in Para 9 to Para 11 are denied by me. I never made any defamatory statement as against the petitioner except finding fault with his selective discharge of police powers against my party cadres. The statements made by me are not voluntary but answers given to press and media when they specifically referred to the deliberate allegations made by the petitioner against me and my party. I never either directly or indirectly indulged in cheap politics of making personal comments or denigrating any person in public. Throughout my political career I made criticisms against the political opponents but never maligned their personal life and character. Further, I never instigated or encouraged my cadres to make allegations and insinuations against any political leaders and officials. Whenever it is brought to my knowledge about the usage of harsh language by my cadres, I advise them not to make such allegations and refrain them from repeating the same. When there is no material available to substantiate my role or my in-action seeking ominous/blanket relief of injunction is not maintainable.
8. I state that the allegations made in Para 11 and the transcription of press meet are specifically denied by me. The petitioner is put to strict proof of video transcriptions allegedly made by me as against the petitioner. The pen drive provided to me by the petitioner was carefully watched by me and except the first video referred, in other videos Utterances were made by me against the ruling party and ruling dispensation. The perception of facts as perceived by me from the conduct of the petitioner in the discharge of the official duties. The petitioner worked as Superintendent of Police, Thiruvallur District and the petitioner had invoked Goondas Act to detain my party’s propaganda secretary Sattai Duraimurugan based on political statement made by him. Based on the instance of the petitioner, the Goondas act was invoked and the same was quashed by the Hon’ble High Court. The petitioner when transferred to Trichy again registered a case in Crime No.374 of 2024 on 10.07.2024 and attempted to remand Sattai Durai Murugan. The Learned First Additional District Judge (PCR) set the said sattai Durai Murugan at liberty and refused to remand. Then the petitioner registered another case in Crime no.547 of 2024 in Thillai nagar, P.S and attempted to arrest the said sattai Durai Murugan. In that case the Hon’ble High Court has granted anticipatory bail to the said Sattai Durai Murugan. Thus, the petitioner either on his own or due to political pressure had been continuously attempting to implicate the cadres of the respondent with view to demoralize them and to appease the ruling party and the same could be inferred from the instagram posts and highlights made by the petitioner in his account. Thus, the petitioner abuses his official position and invited wrath of the cadres of my party which might have enraged some of the cadres and they could have reacted strongly. I am in no way responsible for the abusive posts made by persons who were not under my control. Had the petitioner specifically brought to my notice with the proof against my cadres, I would have taken immediate steps as I do not approve personal attacks on politicians and officials.
9. I state that the averments made in Para 12 to Para 18 are pure imagination and baseless apprehensions without any iota of truth. I never made any defamatory statement just retorted and replied to the statements made against me by the petitioner and against the actions made by the petitioner. As I already stated in the earlier paragraph the petitioner does not have any reputation. The petitioner himself identified with ruling party and unnecessarily and without any material with malafide intention made scathing allegations against me and my party at IPS Officers Conference and expressed his view without any material to ban my party as if my party is canvassing for separation. This above speech reflects the hatred developed by the petitioner against me and my party. Even now I apprehend that the petitioner at the behest of ruling party as taken action against me for defamation both under civil and criminal law in the absence of credible material.
10. I state that the averments made in Para 19 to Para 26 are reproduction of the earlier paragraphs and allegations made without any material. I made it clear by issuing the statement even in the August month of 2024 that I have nothing to do with allegations made against the petitioner and the same was also posted in his Instagram account by the petitioner as such it is false to repeat the allegations that I made derogatory statements against the petitioner. The entire suit and application are misconceived and liable to be dismissed. No occasion has arisen for me to seek apology as I never slandered the petitioner by making abusive words. If the petitioner is unable to digest fair criticisms, then the petitioner is unfit to be a police officer. My humble view is it is high time the petitioner needs psychological counselling as the petitioner is imbibed with vainglory phobia.
In these circumstances it is therefore most respectfully prayed that this Hon’ble Court maybe pleased to dismiss the petition filed by the petitioner seeking injunction against me as not maintainable and pass such further or other order that may deem fit and proper and thus render justice.
Solemnly affirmed at Chennai Deponent
on this the 24th day of October
2025 and he signed his name
in my presence Before Me
IN THE HIGH COURT OF JUDICATURE AT MADRAS
(ORDINARY ORIGINAL CIVIL JURISDICTION)
O.A.No. 119850 of 2025
In
C.S.No. 119840 of 2025
Dr. Varun Kumar, IPS (40/2024)
…Applicant/Plaintiff
Vs.
Mr. Seeman,
…Respondent/Defendant
AFFIDAVIT OF SEEMAN
M/s. S.SHANKAR 669/1996
S.RUBAN
COUNSEL FOR RESPONDENT
