In the court of Civil Judge

The Judicature of High Court [Ordinary Civil Jurisdiction]

Suit Number

Suit No: 56 of 2024

Mr. Amit Sharma PLAINTIFF

VERSUS

Mr. Jim Holland DEFENDANT 1

Mr. Jack Holland DEFENDANT 2

INDEX

Sr. no. Particulars Page Court fee

1. Memo of Parties
2. Suit for Malicious Prosecution and
Defamation
3. Verification
4. Affidavit

Filed by

Disha Mahajan Advocate

Mumbai

8th January 2024

 IN THE COURT OF HIGH COURT JUDGE AT BOMBAY HIGH COURT

Civil Suit No.:56 of 2024

IN THE MATTER OF:

Mr. Amil Sharma PLAINTIFF

VERSUS

Mr. Jim Holland DEFENDANT 1

Mr. Jack Holland DEFENDANT 2

MEMO OF PARTIES

Mr. Amit Sharma PLAINTIFF

218, Pali hills,

Bandra (W) aged 23yrs

s/o Vikram Sharma

VERSUS

Mr. Jim Holland DEFENDANT 1

512, S.V. Road,

Vile Parle (W),

Aged 29yrs

Mr. Jack Holland DEFENDANT 2

904, Akruti Heaven,

Santacruz.

Aged 30yrs
 Suit for Malicious Prosecution and Defamation

MOST RESPECTFULLY SHOWETH

1. That the Plaintiff aged about 23 is the son of Vikram Sharma, a leading Bollywood
actor residing at 218, Pali hills, Bandra (W).
2. That Defendant 1 aged about 25 is the son of Jill Holland residing at 512, S.V.Road,
Vile Parle (W) and Defendant 2 aged about 24 is the son of Lola Holland residing at
904, Akruti Heaven, Santacruz.
3. That the Plaintiff brings a legal action against Defendant 1 and Defendant 2 in
orchestrating and executing a malicious prosecution against, Plaintiff, as well as
engaging in defamatory actions that have caused irreparable harm to his
reputation and well-being.
4. That the Plaintiff who has maintained his distance from his fathers stardom and
scandalous life, a university student, attended a social house gathering hosted by his
peers, Defendant1 and Defendant 2 at Defendant 2’s residence in Santacruz. There
were other attendees in the party which were unknown to the plaintiff till that date.
5. That the few of attendees namely Aryan, Rahul and Navya which were Defendants
peers were seemed to have a good time with the Plaintiff who was not aware of the
fact about their dealings and activities.
6. That only after the party started the Plaintiff was aware of the fact about the drug
activities and denied to consume the same as it was against his personal morals and
ethics.
7. That when the attendees got an idea and knew about the party getting raided planted
70gms of cocaine in Plaintiffs bag as well as jacket which was unattended by Plaintiff
for a long-time during party. When the authorities arrived and conducted search and
they found the major chunk of drug within Plaintiffs belonging which was his jacket
and bag he removed due to the heat. The Plaintiff had no idea about the drug being
planted in his belongings until the law enforcements officials searched in his
belongings.
8. That after planting the gravely incriminating evidence in Plaintiffs belongings the
Defendants and attendees misleading the authorities claimed Plaintiff to be the dealer
of drugs in the party.
 9. That the attendees and Defendants orchestrated a plan to save themselves from getting
caught to implicate Plaintiff as the main master-mind of the drug related activities.
10. The fabricated evidence and given the Plaintiff’s fathers stardom and conspiracies the
authorities were convinced to go further with legal proceedings against the Plaintiff.
11. That even after denying the allegations and trying to tell the truth the Plaintiff after
being detained and arrested for 30 days was found to be innocent of the charges and
was acquitted of the offences charged against him.
12. That the evidence presented in the court of law was indeed fabricated and orchestrated
by Defendant 2 and his party attendees by falsely implicating the Plaintiff and damage
and cause harm to his career.
13. That during the trial and whole scenario the Plaintiff went through immense distress
and mental agony which as a result tarnished his reputation and resulted his
suspension from his university. He also lost his part time job as an Assistant Director
because of these accusations.
14. That the Defendants were indeed jealous and were complexed by his career, life, and
his stardom he got because of his father. The proceedings also cost his family a mental
and emotional distress and affected their lives.
15. This Hon’ble court has jurisdiction as the alleged events occurred within its
jurisdiction and the defendants reside within this jurisdiction.

PRAYER

In the facts and circumstances of case mentioned herein above this Hon’ble Court may
graciously be pleased to:

a) That the Plaintiff humbly prays for the issuance of an injunction restraining the
Defendant, their agents, servants, or any person acting under their authority, from
further disseminating or publishing false and defamatory statements regarding the
Plaintiff's character, specifically in relation to the alleged drug-related activities
falsely attributed to the Plaintiff.
b) That the Plaintiff prays for damages, both compensatory and exemplary, for the
mental anguish, distress, and loss of reputation suffered as a direct consequence of the
Defendant's orchestrated and false accusations.
c) That the Plaintiff requests this honorable court to order a thorough investigation into
the circumstances surrounding the fabrication and planting of incriminating evidence
 against the Plaintiff, and to take appropriate legal action against the individuals
responsible for such acts.
d) Any other relief, which the Hon-ble court deems fit, may please be granted to the
plaintiff in the interest of justice.

AMIT SHARMA

THROUGH

Disha Mahajan, Advocate

Place: Bombay

Date: Jan., 8th 2024

VERIFICATION

I, Amit Sharma, the above named Plaintiff states on solemn affirmation that contents of

Para 1 to 15 of the Plaint are true and correct to the best of my knowledge and belief and

those of legal averments are true and correct on the basis of legal advice received and

believed to be true by me.

Verified at Bombay on this 8th day of January 2024

Amit Sharma

AFFIDAVIT

I, Amit Sharma S/o Vikram Sharma, do here by solemnly affirm and declare as under:-

1. That I am the plaintiff in the above said case and am well conversant with the facts

and circumstances of the case and am competent to swear this affidavit.

2. That accompanying plaint for malicious prosecution and Defamation has been drafted by
my counsel under my instructions and contents of the same have been explained to me in
vernacular and understood by me and the same are not being repeated herein for the same of
brevity and may be read as part and parcel of this affidavit.

3. This is my true and correct statement.

Amit Sharma