IN THE HON’BLE CITY CIVIL AND SESSIONS COURT, MUMBAI.

ORDINARY ORIGINAL CIVIL JURICDICTION

Civil suit No. 319 of 2012

Chetan Bhagat s/o Shekhar Bhagat, Hindu, aged 40 years,

r/o 121/C, Jalsa bungalows, Santacruz, Mumbai, 302021. [Plaintiff]

Versus

Raju Hirani s/o Sanjay Hirani, Hindu, aged 43 years,

r/o G-22, Galaxy Apartment, Bandra, Mumbai, 302011. [Defendant]

The plaintiff abovementioned states as follows: -

i) That, the plaintiff is a playwright, dramatist and producer of stage plays by

profession and has written and produced many known plays.

ii) That in 2010 Mr. X had written a play titled “Hum Hindustani “depicting the

theme of provincialism and it soon became very popular.

iii) That, Defendant, Mr Raju Hirani, a producer of film came across this play and

was very impressed with the concept and the narration of the story.

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iv) That, he defendant Raju Hirani sent a letter to the plaintiff that he wishes to make

a movie based on the play. The plaintiff met the defendant and discussed the

entire play and gave permission for the same on about 10th March 2010.

v) That, after about six months in around the month of August, the defendant

communicates to the plaintiff that, he is not able to produce the movie out of this

play as the story and the script is very short and movie out of this cannot be made,

with which the plaintiff agreed and was with which the plaintiff was fine.

vi) That, the cause of action arose in the year 2012, when the defendant releases a

movie title ‘2 States’ based on the concept of provincialism; a love story of boy

from south India who want to marry a girl from north India.

vii) That, after watching the movie, the plaintiff was of the opinion that it is based on

the story of his play.

viii) The plaintiff claims that, the defendant has produced a movie based on the play

written by him without the permission of the plaintiff.

ix) That, the plaintiff and the defendant both resides in the Mumbai and the fraud was

taken place at Mumbai too. So, the present matter is well within the jurisdiction of

this Hon’ble Court. Also, the value of the subject matter of this suit for the

purpose of jurisdiction is Rs. 2,00,000/- as well as it is the same for the purpose of

court fees.

x) That, the plaintiff will rely upon the documents listed whereof is hereto annexed

as an Annexure A.

xi) The plaintiff therefore prays,

- That, the plaintiff seeks permanent injunction and the defendant

may be ordered to pay the plaintiff the compensatory amount for

committing fraud with the plaintiff. And compensate the plaintiff

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 by paying the original fees for using the playwright of the plaintiff.

i.e. Rs. 75,00,000/- (Seventy-Five Lakhs).

- That, the defendant may be ordered to be punished for the fraud

and Infringement of Copyright.

- The defendant should be ordered to pay the plaintiff’s costs of

the suit i.e. Rs. 2,00,000/- (Two Lakhs).

Mr. Chetan Bhagat

(Plaintiff)

VERIFICATION

I, Mr. Chetan Bhagat, the plaintiff abovenamed, do solemnly declare that what is

stated in paras i, ii, iii, iv, v, vi and vii is true to my own knowledge and that what is stated in

remaining paras is stated on the information and belief and I believe the same to be true.

Chetan Bhagat

(Plaintiff)

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 AFFIDAVIT

IN THE HON’BLE CITY CIVIL AND SESSIONS COURT, MUMBAI.

ORDINARY ORIGINAL CIVIL JURICDICTION

Civil suit No. 319 of 2012

Mr. Chetan Bhagat [Plaintiff]

v/s

Mr. Raju Hirani [Defendant]

I, Mr. Chetan Bhagat, the plaintiff abovenamed, do solemnly declare that what is

stated in paras i, ii, iii, iv, v, vi and vii is true to my own knowledge and that what is stated in

remaining paras is stated on the information and belief and I believe the same to be true.

Solemnly declared: Chetan Bhagat

At Mumbai, Maharashtra, (Plaintiff)
On the 18th September, 2012.

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