LEGAL NOTICE

To,

Mr. Mahesh Bhatt s/o Mr. Naresh Bhatt

264, Arera Colony, Bhopal

SUBJECT- Legal Notice for Defamation

Sir,

With the permission and instructions of my client, Mr. Suresh Tiwari, son of Mr. Omprakash
Tiwari, resident of 102, Minal Residency, Bhopal, I serve you upon this notice for defamation on
the following grounds.

1. That, you have defamed my client on various social media platforms by spreading false news
and lodging a false complaint regarding the same.
2. That, you have falsely alleged that my client has caused grievous hurt to you and assaulted
you. You have molded and exaggerated the real facts and accused my client of assault
diminishing his reputation in the eyes of public.
3. That, there was no assault as such and it was a mere unintentional accident which caused you
a minor injury. My client being a motivational speaker does many motivational programs at
different cities and you attended one of the programs held at your city. While maintaining the
security of my client and managing the crowd at the program, you got a little push from one
of his security guards which might have caused you a minor injury. This was a mere accident
which was totally unintentional.
4. That, this trivial incident is not a criminal offence of assault for which you have lodged a
false complaint. Your allegations have no base and are malicious. That, my client is a
reputable motivational speaker and has good amount of followers on various social media
platforms including YouTube, Instagram, and twitter. He has people following him
 nationally as well as internationally. My client does programs at various cities across the
country.
5. That, my client enjoys a good reputation and command across all his followers and your
frivolous complaint has denigrated my client’s reputation and respect. You have caused an
irreparable damage to my client’s reputation.
6. That, my client has suffered mental agony and a serious backlash from his followers because
of your malicious, frivolous and fictitious complaint.
7. That, my client is demanding damages for mental agony and loss of his reputation along
with an unqualified public apology. My client is demanding Rs. 25,000 as damages for his
mental agony and loss of reputation, and Rs. 15,000 as the cost of legal assistance.
8. I, therefore, serve you upon this notice to pay Rs. 40,000 in total along with an unqualified
public apology within 15 days of issuance of this notice. In case of failure to respond to the
notice, we will be constrained to file a criminal suit for Defamation under section 499 of the
Indian Penal Code, 1860, the costs of which will be yours alone.
9. A copy of this legal notice for defamation is retained in my office for further necessary
action.

Counsel

Adv. Astha Jain

Adress-