Notice- Manish Tiwari- WDT

8/4/2019 Notice- Manish Tiwari- WDT

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Milind D. PawarMilind D. PawarMilind D. PawarMilind D. Pawar

Advocate

Office- 508, Amit Court, Shivajinagar,

Pune - 411 005

Mob : 9421003030

Date - /09/2011

NOTICE

(BY R.P.A.D.)

To,

MR. MANISH VISHWANATH TIWARI

Member of Parliament,

1) 228/A, Sarabha Nagar, Pakhowal Road,

Ludhiana-141003 Punjab.

2) C-I/3, Lodhi Garden,

New Delhi-1100033) [email protected]

(The copy of notice also served through e-mail)

Sir,

Under the instructions information and documents shown

by my client Shri. Kisan Baburao Hajare alias Anna Hajare,

R/at - At & Post Ralegan Siddhi, Tal- Parner, Dist. Ahmednagar,

Maharashtra, India you are hereby given this legal Notice which

is as under :

1) That my client is well known Social Worker, Crusader and

social activist in India. That since his young age he has

served the nation either by serving in the Indian Army

and later served the nation by Social Work. That my client

always being fighting against the corruption and tried to

stop the illegal Mal Practices in the various departments

of Government, which affects the common people of India.


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Advocate


Pune - 411 005

Mob : 9421003030

That my client is the cause of enactment of Right to

Information Act 2005 in Maharashtra State and

subsequently in Union of India. That my client has

reputation and social image in India as well as all over the

world. That my client devoted social worker and known

for his clean record in the social work. My client has been

felicitated by many awards by the Government of India,

Government of Maharashtra and Foreign Countries for his

contribution in the field. That my client has always

adopted the path led down by the Father of Nation

Mahatma Gandhiji, therefore, common man and Media

have compared my client with Mahatma Gandhi.

2) That my client states that you are Member of Parliament

and is National Spokesperson of All India Congress

Committee. That you are holding very responsible post in

India and entire nation always have attention towards you

and your statements. That you being responsible person

and holding responsible post, entire nation believes in you

and your statements made in public at large. That you

are one of the voice of Ruling Government i.e. U.P.A.

3) That as the entire nation and world knows that, recently

my client agitated his demand for proper Jan-Lokpal Bill


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Advocate


Pune - 411 005

Mob : 9421003030

by Hunger Strike (Fast) at Ramlila Maidan New Delhi and

the Government of India have agreed to enact the Jan-

Lokpal Bill. That entire nation supported my client and

his cause. That there is huge support by the citizens of

India right from downtrodden to high class society in

India.

4) That my client submits that you on 14/8/2011 in Press

Conference called by you at New Delhi, made a false

imputation and Defamatory Statement before the

Electronic Media which contents following offending

words/statements :

"" h_ {H$gZ ~m~wamd hOmao H$mo H$hZm MmhVo h,"" h_ {H$gZ ~m~wamd hOmao H$mo H$hZm MmhVo h,"" h_ {H$gZ ~m~wamd hOmao H$mo H$hZm MmhVo h,"" h_ {H$gZ ~m~wamd hOmao H$mo H$hZm MmhVo h,

Vw_ {H$g _whgo AZeZ H$amoJo, Vw_ Vmo ga goVw_ {H$g _whgo AZeZ H$amoJo, Vw_ Vmo ga goVw_ {H$g _whgo AZeZ H$amoJo, Vw_ Vmo ga goVw_ {H$g _whgo AZeZ H$amoJo, Vw_ Vmo ga go

boH$a nboH$a nboH$a nboH$a nmd VH$ Q>mMma _o {b hmo ''md VH$ Q>mMma _o {b hmo ''md VH$ Q>mMma _o {b hmo ''md VH$ Q>mMma _o {b hmo ''After this defamatory statement in Press Conference

called by you, all news papers have published your

defamatory statement all over India on 15/08/2011.

5) That my client submits that during your entire

Defamatory statement before electronic Media, one of your

above remark addressing my client with adamant

language and intentionally publishing the same, which is

not only false but per se defamatory. That above


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Advocate


Pune - 411 005

Mob : 9421003030

mentioned imputations are absolutely false and

defamatory to your knowledge as there was no base or

substantive evidence backed by your false and defamatory

statement and remarks. That this fact can very well

gathered by your apology before the electronic media on

25/08/2011. That by the above all facts and

circumstances goes to show your malafide and ill-

intention behind passing the above offending and

defamatory remarks and statements towards my client.

6) That due to your false and reckless imputation and

defamatory statement, many of the citizens and followers

of my client suspected about my client. That your false

defamatory statement lowered the reputation and social

image of my client in the society. That many of the

citizens of India and foreign citizens have enquired about

your false statement which is in fact deliberate false

imputation made by you with malafide intention in the

mind to harm the reputation and to defame my client and

thereby you have committed offence under the provision

of Section 499, 500 of Indian Penal Code for which you

are liable to be prosecuted and punished according to law

of land.


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Advocate


Pune - 411 005

Mob : 9421003030

7) That by this legal notice you are hereby called upon that

this is also your duty to clarify that the defamatory

statement which you have made on 14/08/2011 in your

Press Conference, whether that was your personal opinion

or statement made on behalf of your party.

8) That by this legal notice you are hereby called upon to

apologize my client with written application, by you and

on behalf of your Party undertaking not to commit such

false fame imputation and defamatory statement against

my client in future.

9) Therefore, my client calls upon you by this legal notice to

apologize my client with written application, failing which

my client will be constrain to take necessary legal action

in Civil as well as Criminal Court of law against you,

which you may kindly note.

10) That you are the cause for sending this notice, hence

notice charges of Rs. 5,000/- is kept upon you which you

may kindly note.

PUNE

DATE /09/2011 ADVOCATE

(MILIND D. PAWAR)

Documents

Notice- Manish Tiwari- WDT