VISHAL SINGH (ADVOCATE)

Chamber No. 11 , Opp. CJM Court,

High Court (Nainital)
State- Uttarakhand

To,
Dev Singh Dhanu S/o Balvant Singh Dhanu, Residence- Village and Post
office Balan District Chamoli (Uttarakhand)

Legal Notice on behalf of Madan Ram S/o Prem Ram that inappropriate
Conduct and Unauthorized Video Upload.

I hereby serve upon you this notice as under:-

I am writing to address a concerning incident involving the creation and
unauthorized dissemination of a video. It has come to our attention that a video was
recorded by Mr. Dev Singh Dhanu, in which Madan Ram S/o Prem Ram is depicted
in a compromised state due to alcohol consumption. This video was subsequently
uploaded to Facebook by Mr. Ram Singh Bisht using the account under the name
"Ram Shngh Ram Shing”,

1. That Such actions are highly inappropriate and constitute a violation of

privacy. The unauthorized recording and sharing of this video not only
disrespects the Madan Ram involved but also breaches acceptable standards
of conduct.

2. Furthermore, this video has been shared on a Facebook account with 229
friends, causing significant defamation to the Madan Ram involved. This
conduct is in violation of the following sections of the Indian Penal Code
(IPC)
 Section 500 (Defamation): Whoever defames another shall be punished with
simple to two years, or with fine, or with both.

In light of the aforementioned, we hereby demand the following actions on

your part:

Immediate Removal( section 66 A of the Information Technology Act, 2000):

We demand that you immediately remove the video in question from all online
platforms where it has been disseminated, including but not limited to
Facebook, and cease any further distribution or sharing of the video.

Public Apology( Section 499 of the Indian Penal Code): We demand that you
issue a public apology to the individual whose privacy and dignity you have
infringed upon, acknowledging the harm caused by your actions. This apology
should be posted on the same platforms where the video was shared, as well
as any other relevant channels.

Compensation( Section 75 of the Indian Contract act, 1872): We reserve the

right to seek appropriate compensation for the damages incurred by the
affected individual as a result of your actions, including but not limited to
financial losses, emotional distress, and reputational harm.

Legal Action: Failure to comply with the demands outlined above will leave
us with no choice but to pursue all available legal remedies against you. This
may include but is not limited to initiating civil litigation to seek damages and
injunctive relief, as well as lodging criminal complaints with the relevant
authorities.

3. This notice serves as a formal warning to both parties involved. Any further
dissemination or similar actions may lead to legal consequences.

4. If this matter is not resolved amicably, we will pursue all available legal
actions for defamation and breach of privacy. Should both parties fail to reach
a satisfactory agreement, we are prepared to escalate this issue to the High
Court.
 5. We wish to remind you that such actions constitute a serious violation of
privacy rights and are subject to legal consequences. The individual depicted
in the video has right to privacy and dignity, which have been egregiously
violated by your actions.

6. We demand that you immediately remove the video from all platforms where
it has been disseminated and cease any further distribution or sharing of the
vibes. Failure to comply with this demand will result in legal action being
taken against you.

7. Furthermore, we demand a written apology from you to the individual whose

privacy you have infringed upon, acknowledging the harm caused by your
actions. Please be advised that we are exploring all available legal remedies
in this matter and will not hesitate to pursue appropriate legal action to protect
the rights and dignity of the affected individual.

8. You are hereby notified that you must resolve this matter within a period of
one month from the date of this notice. Failure to reach a settlement or
resolution within this stipulated time frame will compel us to pursue all
available legal remedies to enforce our rights. We urge you to consider this
matter with the utmost seriousness and contact us promptly to discuss and
finalize the necessary arrangements for a settlement.

That my client will be constrained to initiate legal proceedings before the court of
competent jurisdiction against you at your cost and responsibility. You are also liable
to pay Rs. 5000/- notice fees.

Note: Please treat this matter with the utmost urgency to avoid
further legal consequences.

Copy retained.
Dated: 22nd May 2024