IN THE DISTRICT COURT AT BENGALURU

SUIT NO. ………… /2024

Mr. Kwazy Kapoor,

13/B Ashwath Nagar,
Chokkanhalli, Rajankunte
Bangalore, Karnataka, - 561203
......................................... Plaintiff

VERSES

Mr. Simba Singham Suryavanshi

No 44, 5th Cross
Sollytood Mirror,
Bangalore, Karnataka - 561203
......................................... Respondent

Plaint under Order 7 Rule 1 for Compensation for Defamation

The plaintiff respectfully states as follows: -

1. That The Plaintiff Mr. Kwazy Kapoor aged 35 years and resident at 13/B
Ashwath Nagar, Chokkanhalli, Rajankunte Bangalore, Karnataka, is a
very popular Influencer and superstar known for his philanthropic work
and unblemished public image, with a following of 35 million on the
social media platform Instagram and is also highly acclaimed even
winning the best actor of 2022.

2. That The Plaintiff’s personal assistant was approached by the respondent

for an interview for an article that was to be published in Sollytood
Mirror a nationally circulated newspaper with a readership of over 15
million and naturally being a public figure the plaintiff accepted to give
the respondent the interview.
3. That The Interview took place, where the topic of discussion was brought
up by the respondent which was ‘if Women should be given the same
pay’ where the Plaintiff and respondent had a hearty conversation with a
lot of nuanced opinion that made for a great interview.

4. That The Plaintiff after the interview disclosed to the respondent about
the parameters of payment that is usually taken into consideration in the
industry which is not usually based on gender but is based on the
experience talent and their contribution in the movie. The plaintiff
further added that it is really difficult to expect equal pay in the industry.
The transcript of the said interview has been attached as ANNEXURE-A
for the reference of this honorable court

5. That the plaintiff further states that the information that was disclosed to
the respondent was on an unofficial basis and not during the course of
interview. The plaintiff also added that this was solely hi opinion based
on his experience that he had gained after being closely related to the
industry. The plaintiff also clearly mentioned that this was not supposed
to be put over the interview as it was just an opinion.

6. That the respondent despite being informed by the plaintiff has disclosed
this information on basis of his interpretation leading to
misrepresentation of facts in the said article in issue. The article which
has been published by the respondent on with the misrepresented facts
is marked as ANNEXURE-B

7. The plaintiff here in states that the published article in question has not
only added to the mental distress of the plaintiff but also led to
economically destroying the career of the plaintiff. The plaintiff has
incurred a ls of 4 million on his Instagram handle which was on of his
source of income. In addition to that the plaintiff has lost several movie
offers which was signed by him previously before the interview. Above of
which is Attached as ANNEXURE-C and ANNEXURE-D

8. That the plaintiff’s reputation has gone to ground with his own fan base
criticizing not only his character but also the charitable works that the
 plaintiff was involved in. the plaintiff herein has been backlashed on
every social media platform and in all other forms of media.

9. As mentioned in the article it is alleged that the plaintiff has disbelief in

the equal remuneration amongst the genders but if the Transcript which
is attached in ANNEXURE-A. It is evident that the plaintiff contextually
states that in the industry they are in it is the people who bring in the
box office is who gets paid the most which itself could be of any gender,
the construing of this statement and representing it in a way that
maligns the plaintiff and stating that he holds disbelief towards equal
pay is a deliberate attempt at defaming the plaintiff.

10. That The Said article was read by the regular readers of the
Sollytood Mirror which as stated is 8 million and was later picked up by
multiple news outlets further spreading a notion of identity of the
plaintiff that was not even true and which was maliciously painted by the
respondent.

11. That The effects that were a direct result of the said articles are the
ostracizing the plaintiff form any formal industry events, loss of
professional opportunity for my client who has even lost the existing
deals that were yet to be acted on.

12. That A large chunk of the plaintiff’s income used to come form
advertising on the platform Instagram which after the publication of the
article has led to a not only a loss of audience that discourages brands
but also a boycott from advertisers themselves leading to huge financial
losses to the plaintiff in reputation and monetary.

13. That the plaintiff after being constantly harassed and mentally
disturbed is present before this honorable court to claim justice and also
reparations for the consequences faced by him after the publication of
the said article
14. That the Legal Notice of the same was sent to the respondent
which is attached as ANNEXURE-E, on 01-03-2024 which was not
heeded to by the respondent, leading the plaintiff to litigation to get relief

15. That The interview scheduled at the offices of Sollytood Mirror No

44, 5th Cross
Sollytood Mirror,Bangalore, Karnataka - 561203,. and the article being
published on 20-02-2024 places this case in the jurisdiction of this
honorable court.

16. That The valuation of the suit for the purpose of jurisdiction and
payment of court-fees Rupees 2,42,125/- has been paid.
PRAYER
The plaintiff herein prays infront of this honorable court the following

1. To pass a decree directing the Respondent to have a written

apology be published in the Sollytood Mirror Newspaper.

2. To pass a decree directing the respondent to make a

apology video and deliver it to the Plaintiff for it’s publication
on the plaintiff’s social media platforms.

3. To pass a decree directing the respondent to pay the sum of

Rs 75,00,000/- as compensation to the Plaintiff.

4. To grant any other relief that this Honorable Court deems

fit and proper in the circumstances.

AND/OR

Pass any other order it may deem fit in the interest of justice, equity,
and good conscience.

All of which is most humbly and respectfully submitted

Place: ………………….

(Signature of the plaintiff)

Date: …………………..

Advocate
ForPlaintiff
 IN THE COURT OF CIVIL JUDGE CLASS - I AT BENGALURU

SUIT NO. ………… /2024

Mr. Kwazy Kapoor,

13/B Ashwath Nagar,
Chokkanhalli, Rajankunte
Bangalore, Karnataka, - 561203
......................................... Plaintiff

Vs.

Mr. Simba Singham Suryavanshi

No 44, 5th Cross
Sollytood Mirror,
Bangalore, Karnataka - 561203
......................................... Respondent

VERIFYING AFFIDAVIT

I, Mr. Kwazy Kapoor, do hereby verify on this 17 day of March, 2024 at Bengaluru that the
contents of the
above said affidavit are true and correct to my knowledge and information and nothing
material has been concealed therefrom.

Bengaluru
Date: 21-03-2024 DEPONENT

Identified by me:
Advocate
No of corrections: