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New Delhi

Dated 23 August 2014


Subject: Complaint against Teesta Setalvad for intentionally hurting
religious sentiments of Hindus, and for intentionally attempting to
prove breach of peace and communal harmony, and also for
causing enmity between people of different religious, and hence
seeking registration of FIR under various sections of IPC and IT
Act, or any other Law as applies accordingly

Honble Sir,

This is to bring into your kind notice and attention, certain serious
offences, committed willfully, intentionally and maliciously, by one Teesta
Setalvad, a social activist, which requires your immediate attention and lawful

At the outset, I wish to mention that www.twitter.com is a social-media
internet website where people open their personal accounts and post their opinions,
through words or pictures. It is further mentioned for the sake of understanding
that Twitter account can be opened by anyone who has attained the age of majority
(18 yrs in India). As per the terms and conditions of use of Twitter, anything which
is posted through such Twitter Handles is the property and creation of such User,
and hence such person is responsible for everything posted through such Twitter
Handle. Thereby, it will not be out of place to conclude that everything which is
posted by the User through his/her Twitter Handle is posted intentionally and
willfully, knowing fully that he/she shall be responsible for the same.

On 22/08/14, at about 12.36 PM, Teesta Setalvad, posted a picture on her
Twitter Handle @TeestaSetalvad, with a title Chilling Reality
The said picture is attached along with this complaint for your perusal, as the
picture has been since removed by Teesta Setalvad as it was apparent violation of
many provisions of Indian Penal Code and IT Act.

It can be clearly seen in the attached picture that:

3 different pictures have been used and joined together to create one
single picture. It is clear that Teesta Setalvad has made an intentional
effort to edit and morph many pictures to make it one single picture.

Picture on right side shows the recent brutal beheading-murder of US
Journalist by ISIS terrorist in Iraq. The said image has been edited by
strategically placing a chakra behind the head of the masked
terrorist. The said chakra, yellow in colour, is traditionally used
behind the heads of Hindu Gods and Goddess to show and highlight
their great Aura and Divinity. The use of chakra clearly indicates
that Teesta Setalvad has intentionally compared the said masked-
terrorist with Hindu Gods, thereby intentionally insulting Hinduism
and thereby bringing Hinduism into disrepute, and further hurting
religious sentiments of many Hindus including complainant.

Picture on top-left side shows an image of Hindu Godess Kali-
Mata. The said picture has been further edited and morphed by
Teesta Setalvad by removing the head of Kali Mata and replacing it
with the head of one ISIS Terrorist. The picture speaks for itself,
giving a meaning meaning thereby that the way Kali-Mata used to
behead demons/Rakshasa, similar actions are being employed by
terrorists. The said picture has clearly hurted the religious sentiments
of many Hindus, including complainant, and the said picture has the
tendency of breach communal peace between Hindus and Muslims in

Picture on below-left side shows an image of an ISIS Terrorist. This
picture is again edited and morphed intentionally and maliciously by
Teesta Setalvad. In the said picture the ISIS terrorist has raised his
finger and one chakra has been strategically placed on his finger
giving it the colour and depiction of Lord Vishnu/Krishna in
Hinduism. The background of said picture shows many bleeding
heads, attempting to show that said heads have been cut by the said
chakra. The picture has shown Lord Vishnu/Krishna is bad light
with an image of murderer.

Moreover, the background of the complete picture shows ISIS written
all over, which further causes impression that the ISIS terrorists in
Iraq are as equal to Hindu Gods and Goddess. The said picture has
caused discomfort to many Hindus. The said picture has the tendency
to jeopardize the communal peace in society, and can lead to
communal tension.

Now, as it stands at present, the picture has been deleted by Teesta
Setalvad from her account, after realizing there was public outrage. But
deleting the picture does not itself delete the offence committed and hence
the legal action may be initiated against Teesta Setalvad.

It is hereby most humbly brought into your kind notice that this is not the
first time Teesta Setalvad has committed such mischief. She has a long list of
misdeeds committed by her, ranging from filing false affidavits in Courts to
intimidating witnesses to depose falsely in cases before Courts.

Keeping the attention strictly to the present issue, the following sections,
amongst others, are visibly and apparently offended and committed by Teesta

Under Indian Penal Code:

S.153A: Promoting enimity between groups on grounds of
religion, race, place of birth, residence, language etc and
doing acts prejudicial to maintenance of harmony:

S.153B: Imputations, assertions prejudicial to national-

S.295: Injuring or defiling place of worship with intent to insult
the religion of any class

S.295A: Delibrate and malicious acts, intended to outrage
religious feelings of any class by insukting its religion or
religious beliefs

S.298: Uttering, words, etc. with deliberate intent to wound the
religious feelings of any such person

S.504: Intentional insult with intent to provoke breach of peace

S.505: Statements conducing to public mischief

S.201 : Causing disappearance of evidence


Under IT Act:

S.66A: Punishment for sending offensive messages through
communication service, etc.

It is hereby brought into your kind notice that above said offences are
committed by Teesta Setalvad most apparently and with clear intention to hurt the
religious sentiments of Hindus and knowing fully that the said picture shall bring
Hinduism into disrepute and may also cause communal tension and enmity
between two religious groups.

In view of the above said facts, it is hereby requested to your good office to
register FIR against Teesta Setalvad and launch investigation against her as per


Phone Number-

Annexure 1- Screenshot of Teesta Setalvad Tweet and Picture