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KARTIK SETH
Advocate, Supreme Court Of India
Dated : May 132017
Ms Shobhana Bhartia
Chairperson & Editorial Director
HT Media Limited
Hindustand Times House
18-20, Kasturba Gandhi Marg
New Delhi ~ 110001, India
Subject : Legal Notice for Defamation
Dear Ma'am,
I write on behalf of and under instructions of my client, Shri Arun Kumar Mishra, Chief Engineer,
Uttar Pradesh State Industrial Development Corporation (UPSIDC).
One of your special correspondents of Kanpur, Mr Haidar Naqvi has written a news article which
has been published by your English Daily, Hindustan Times, which can be accessed at
sws/this-uy
including-rohatgj-sorabjee-and-salve-at-his-service/story-oZILWxgy0NkGTh2LBLq47L html
(last accessed on 13 May 2017, Saturday at 4:44 PM IST)
In this article, your newspaper (hereinafter referred as “you”) has casted aspersions on the integrity
of my client. The following are the points which you have raised without even verfying the veracity
of the facts at hand :
(1 : You have said that Senior Advocates : L Nageshwar Rao (Now, Justice L Nageshwar Rao),
Mukul Rohtagi, Soli Sorabjee, Shanti Bhushan, Harish Salve, Gopal Subramanium, Salman
Khurshid, Kapil Sibbal, Dr Abhishek Manu Singhvi have all appeared on behalf of my
client. Ere eeeeee
| M: +91-9582031845 | Email ID : kartik.seth4@gmail.com | ee = nee
Office: 181 Tower #8, Supreme Enclave, Mayur Vihar Phase I New Delhi ~ 110091 -
aKARTIK SETH
Advocate, Supreme Court Of India
While doing so, you have indicated that my client could not have paid their professional fees
in the salary which he earns, extract of the article is quoted herein below
“The unusual part -- Mishra draws a monthly salary of just over Rs 1 lakh while it is
understood that the lawyers often charge a fee ranging between five and twenty lakh per day."
To respond to that, it is pertinent to mention that Mr Mukul Rohatgi, the current Attorney
General of India, never appeared on behalf of my client, in fact he appeared for UPSIDC which is
a state run body. With regard to the other Senior Advocates mentioned in your article, it is
categorically stated that they have represented my client at some or the other stage of the
litigation he has been a part of, at either the Supreme Court or at the High Court of Judicature at
Allahabad. Before jumping to conclusions and casting aspersions on my client, you should have
atleast brushed up your knowledge about client- attorney privilege which includes non-
disclosure of professional fees charged by the lawyer to his clients. I have been also instructed
to mention the abovestated Senior Advocates have been kind enough to my client to represent
him in various foras at a heavily discounted rate considering his service strata and his
reputation and record in State of Uttar Pradesh,
(II) : You have referred to cases of CBI and ED against my client and tried to portray a
picture which shows him in very poor light and raises question marks over his
integrity.
In response to the above, it is hereby mentioned that none of the properties mentioned in your
article belong to my client and the case of CBI and ED stand quashed against him as on today.
| M: +91-9582031845 | Email ID : kartik.seth4@gmail.com |
Office : 181 Tower # 8, Supreme Enclave, Mayur Vihar Phase I New Dethi — 110091KARTIK SETH
Advocate, Supreme Court Of. India
‘Your aforesaid statements amount to defamation both civil and criminal under Section 499
of the Indian Penal Code punishable under Section 500 of the Code with imprisonment
which may extend to 2 years. By this Legal Notice, you are hereby required to remove/not
Publish the above-mentioned article that you have uploaded on to your website, as well as any other
similar articles published by you, or by any one on your behalf, on to any other prinV/online forum
whatsoever, and issue an unconditional public apology to my client for your vexatious allegations.
The said apology should include the true facts about the integrity of my client as can be evidenced
from his track record and not from maliciously put version in article. The coverage should be with
same prominence as the maliciously article. Further, you are required to immediately cease and
desist from making/publishing any more false, malicious and defamatory remarks/articles against
my client, we shall be constrained to directly launch criminal proceedings against you and your
company.
In case you fail to comply with the requirements stated above within 15 days from the receipt of the
present legal notice, please stand advised that we have been instructed to pursue all possible legal
actions against you, civil as well as criminal, in the appropriate courts of law, which legal actions
shall be solely at your own risk, cost and peril
Yours Faithfully,
KARTIK SETH KARTIK SETH
Advocate
ADVOCATE ‘Supreme Court of ee
* fo 2401 1845
| M: +91-9582031845 | Email ID: kartik.seth4@gmail.com |
Office : 181 Tower # 8, Supreme Enclave, Mayur Vihar Phase I New Dethi— 110091