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TIMES AETWORK NOW OR NOTHING 16% May, 2017. To ‘Phe Senior Inspector of Polic Azad Maidan Police Station, Mumbai Sub; Information disclosing the commission of cognizable olen: under the Indian Penal Code acommitted by Mr. Amab Goswami and Ms. Prema Sridevi along with others known and unknown persons punishable Under Sections 378 read with Section 379, 403, 405 read with Sections 406, 409, 411, 414, 418 of the Indian Penal Code, read with Section 66-B, 72 & 72-A of the Information Technology Act 2000 read with Section 34 and Section 120-B of the Indian Penal Code. Sir, }. ‘The undersigned begs to submit the following inform able olfesce your good self disclosing the commission of cogni by the aforesaid persons under the Indian Penal Code read s under the information Technology Ac various other provisior 2000, In respect of the said information an FIR be recordes | somamitted the of le U/Sec.3 nees pun ‘BENNETT, COLEMAN & COMPANY LTD. Aeattered Ofc: The Times oF na Bana, 379, 403, 405 read with Sections 406, 409, 411, 414, 418 of the Indian Penal Code, read with Section 66-B, 72 & 72-A of the Information Technology Act 2000 read with Section 34 and Section 120-B of the Indian Penal Code. It is submitted that in view of the disclosures contained hereinafter categorically making out a cognizable offence under the LP.C. and the Information Technology Act, 2000, It is submitted that, Bennett Coleman & Co. Ltd., have a television division with its office at Trade House, Kamala Mil Compound, Scnapati Bapat Marg, Lower Parel, Mumbai — 400 013; and with a registered office at Times of India Building, D.N. Road, Mumbai ~ 400 001. The undersigned Complainant Bennett Coleman & Co. Ltd., has been duly authorized by Bennett, Coleman & Co. Ltd. to submit the following information disclosing commission of cognizable offences against the aforesaid persons. It is submitted that Bennett, Coleman & Co. Ltd., owns and operates through its television division, various television channels in India with a substantial presence overseas, One of the channels owned and broadcasted by Bennett, Coleman & Co. Ltd., is “TIMES NOW”, an English news channel which was launched on 31* of January, 2006. One of the most popular programs aired on “TIMES NOW? Channel is “The NEWS HOUR”, which is a prime time live debate show on leading topics and stories touching national and international issues of the day. The said program is aired every day at 9.00 p.m. Needless to say that, the Television Division of Bennett, Coleman & Co. Ltd., is the unchallenged owner of the intellectual rights as well as the concept and design of the said program under the title “The NEWS HOUR.” Consequently the intellectual property rights of all programs aired under the aforesaid programme are in perpetuity with the Television Division of Bennett, Coleman & Co. Ltd. It is submitted that such Intellectual Property Rights are vested with the Television Division of Bennett, Coleman & Co, Ltd., not only for the programs already aired on The NEWS. HOUR everyday but also in respect of all information, including details in the form of script prepared, information collected either in written form or in the form of audio and video conversations inter se between third parties as well as interviews taken by reporters of Bennett, Coleman & Co. Ltd, on the strength of which the Editor in Chief along with others in the organization of the Television Division of Bennett, Coleman & Co. Lid. prepare a complete data based pattern of the future stories, episodes and programs to be aired under the title “The NEWS HOUR?” or in any other news bulletin over a period of 3 to 6 months. All such preparations so made are required to be used exclusively for the purposes of the “THE NEWS HOUR’ program to be aired on daily basis at 9.00 p.m. Consequently, the Television Division of Bennett, Coleman & Co. Ltd. possesses Intellectual Property Rights in respect of such data base which has been prepared for daily airing a particular topic and story on the “THE NEWS. HOUR.” Such data base, therefore, cannot be used for any other purpose other than the purpose for which it has been compiled over a period of 3 to 6 months, involving the contributions of several members of a team from the Television Division of Bennett, Coleman & Co. Ltd. in conceptualizing, designing, configuring, composing by any process or means, whether manual, mechanical or by usc of computer related hardware or such appropriate software as is required for preparation of a finished product to be aired on “THE NEWS HOUR’. It is submitted that the aforesaid two Accused named hereinabove i.e. Mr. Ammab Goswami and Ms. Prema Sridevi, were the ex-employees of the Complainant Company and were engaged in a capacity of Editor-in-Chief and the Reporter of Times Now channel respectively and were under an employment contract with the Television Division of Bennett, Coleman & Co. Ltd., involved in creation of all literary, dramatic and artistic work required to be done for airing of programs on “THE NEWS. HOUR” and other news bulletins of the Channel on the strength of information collected by them personally as well as through their network of reporters and contacts for building up the stories to be aired on “THE NEWS HOUR” And various other programmes of the Channel. Needless to say that such exercise involved collection of material including, text, photographs, illustrations, graphics, films, articles, stories, features, cartoons, books, audio recording, video recording, logos, audio visual recording, brand name and other items, so created by the Television Division of Bennett, Coleman & Co. Ltd., for the Channel. Consequently, the sole and exclusive intellectual property right in perpetuity of the same vested in the Television Division of Bennett, Coleman & Co. Ltd., and could have been used only for the programme “HE NEWS HOUR” or such other program with the consent and sanction of management of the Television Division of Bennett Coleman & Co. Ltd. At this stage, it would not be out of place to point out that the contract of appointment of the aforesaid two Accused persons categorically clarified that they would not be entitled to any residual rights in respect of the aforesaid information either as copyrights or in 5: any other form. The Accused were aware that exclusive and universal rights for publication, republication, sale or re-use of such information in any newspaper, magazine or any other medium including electronic medium of television, radio, internet, digital, web, etc., vested only with the Television Division of Bennett, Coleman @ Co. Ltd. It was also known and conveyed to the aforesaid two Accused that during the course of their employment with the Television Division of Bennett, Coleman & Co. Ltd., all their contributions or work could be used and exploited by the Television Division of Bennett, Coleman & Co. Ltd., in such manner as was desirable in all of the media whether in its portals or internet, radio, television, broadcasting or DTH, or in any other emerging form or media, driven by technology or otherwise. It is submitted that, Accused No.1 Mr. Arnab Goswami was employed by the Television Division of Bennett, Coleman & Co. Ltd. in May 2004 as Vice President and Editor in Chief of the “TIMES NOW” Channel. He resigned from services on 1 November, 2016 with his last working day being 18 of November, 2016. The Accused No.2 aforesaid Ms. Prema Sridevi had joined the Television Division of Bennett, Coleman & Co. Ltd. on 1% June, 2005 and resigned from services 8 December, 2016 i.e. a couple of weeks immediately after the resignation of the Mr. Arab Goswami. Her last working day was 7% of February, 2017. While Ms. Prema Sridevi was based in Delhi office of the Complainant Company, she closely worked with Accused Mr. Arnab Goswami in connection with program title “THE NEWS HOUR” on “TIMES NOW” Channel. While joining the “Times Now” Channel of the Television Division of Bennett, Coleman & Co. Ltd., both Accused had voluntarily signed and subscribed to an employment contract with Bennett, Coleman é& Co. Ltd., binding themselves to the working conditions stipulated therein, one of the most important conditions in the contract was, the maintenance of confidentiality of employment activities, trade secrets, company information etc. as well as an acknowledgment by both the Accused persons, employees of the Complainant Company admitting to the Intellectual Property Rights, held, possessed and controlled by the Television Division of Bennett, Coleman & Co. Ltd., of all work in any form whatsoever, manual, digital, etc., done and developed by them in the course of their employment. A copy of the said employment contracts of Mr. Arnab Goswami and Mr. Prema Sridevi are annexed hereto and marked as ANNEXURE-‘1’ collectively. ‘The only intention of Accused Mr. Arnab Goswami subsequently resigning from the Television Division of Bennett, Coleman & Co. Ltd. and starting his own competitive channel on the same line, design and concept, etc. of “TIMES NOW” Channel. A copy of the extract of ROC of both the companies ie. M/s. ARG Outlier Media Asianet News Pvt. Ltd. and M/s. SARG Media Holding, Pvt. Ltd. annexed hereto and marked as ANNEXURE. collectively. It is submitted that on 6 May 2017, Accused No.1 launched his news channel by the name, “Republic TV.” Accused Mr. Arnab Goswami is the Managing Director of M/s. ARG Outlier Media Asianet News Pvt. Ltd. (earlier known as ARG Outlier Media Pvt. Ltd.). It is submitted that between August, 2016 and 18% of November, 2016 which was the last working day of Accused Mr. Arnab Goswami, all the accused persons were already engaged in a conspiracy to cause the launching of a news channel which was subsequently disclosed as “Republic TV and for which purpose immediately after resigning from the Television Division of Bennett, Coleman & Co. Ltd., Accused Mr. Arnab Goswami joined M/s. ARG Outlier Media Asianet News Pvt. Ltd. and M/s. SARG Media Holding Pvt. Ltd. and launched “Republic TV.” Between 19% of November, 2016 and 6" May 2017 i.e. approximately 5 to 6 months, Accused Mr. Arnab Goswami along with the aforesaid persons in continuation of his conspiracy as aforesaid was engaged in preparation for the launch of his news channel under the name “Republic TV" which actually went on air on 6th May 2017. It is submitted that before the launch of “Republic TV” on 6% May 2017 the Accused No.1 along with the aforesaid named persons was also assisted by Accuscd Ms. Prema Sridevi who had also resigned from the Television Division of Bennett, Coleman & Co. Ltd. on 8% December, 2016, i.e. a few days immediately after the resignation of Accused Mr. Arnab Goswami. It is noteworthy that both Accused Mr. Arnab Goswami and Ms Prema Sridevi after having submitted their resignations continued to work in the “Times Now” Channel for 18 days and 60 days respectively, during which period both the Accused persons with the knowledge of starting a new chanel, had access to all the above referred to intellectual property of the “limes Now” Channel which was collected and built up for the purposes of being aired on the Complainant's Channel after several weeks and months of preparation by a complete team of “Times Now” along with Accused Mr. Arnab Goswami and Ms. Prema Sridevi. Incidentally it would not be out of place to mention that Accused Ms. Prema Sridevi after having resigned from “Times Now” Channel as a reporter was inducted into “Republic TV” as a Sr. Reporter/ Journalist. It is submitted that on 6!" May 2017, the first story that was aired on “Republic ‘TV" related to a conversation between Mr. Lalu Prasad Yadav and Mr. Shahabuddin which was in the for of an audio conversation purportedly recorded discreetly, obviously without the knowledge of either Mr. Lalu Prasad Yadav or Mr. Shahabuddin regarding certain issues which are more specifically and explicitly recorded in the said audio conversation, A footage of programme wherein the said conversation is used on “Republic TV is annexed hereto and marked as ANNEXURE- It is submitted that on seeing the said program aired on “Republic TV” the undersigned and all other staff of “Times Now” Channel, involved in the creation of data for airing on THE NEWS HOUR program as also the management drew a reasonable belief that the said audio conversation was purportedly recorded before the resignation of Accused Mr. Arnab Goswami in November, 2016, in which case, the said audio conversation purported to be the intellectual property of “Times Now” Channel and consequently could not have been aired on “Republic TV” in the absence of a specific consent given by “Times Now” Channel to the “Republic 10. ‘TV" in its program. ‘The internal enquiry of the Complainant clearly point out that the tapes of conversation between Mr. Lalu Prasad Yadav and Mr. Shahabuddin were procured by Mr. Arnab Goswami while he was in service of the Complainant. It is submitted that on 8 May, 2017, Accused Mr.Arnab Goswami aired a story on his channel “Republic TV” around 7.00 p.m., relating to the death of Late Ms, Sunanda Pushkar wife of Mr. Shashi Tharoor a congress MP from Thiruvanathapuram During this breaking story on “Republic TV", both Accused Mr. Arnab Goswami and Ms. Prema Sridevi, released audio recordings of conversation on phone made by Accused Ms. Prema Sridevi between 16t and 17* January, 2014 revealing the conversations between Accused Ms. Prem Sridevi herein and Late Ms. Sunanda Pushkar and other connected persons purportedly having transpired one day before as well as on the day of demise of Late Ms. Sunanda Pushkar ie. on 17% January, 2014. It is submitted that the said audio recordings of conversations having taken place between 16% and 17% January, 2014, were at a particular point of time when both Accused Mr. Arnab Goswami and Ms. Prema Sridevi were legally bound by their contract of employment in respect of the said conversations which obviously formed an integral part of all that data base HDs collected by “Times Now” channel over a period of time for being used as a part of its news content including the programme “The NEWS HOUR” channel as a significant topic of BREAKING NEWS. It is submitted that both Accused Mr. Arnab Goswami and Ms. Prema Sridevi willfully, deliberately and knowingly withheld the said information with themselves and removed the same from the office of “Times Now” channel on or before the submission of their resignation or at least on or before the date of their last working day with “Times Now” Channel. It is submitted that it is abundantly clear that the said audio conversation which formed the part of intellectual property of “Times Now” channel was removed from the office of “Times Now” channel without the knowledge and consent of the team of “Times Now” channel as well as its management which had over a period of time worked upon collection of this material to form a data base for making BREAKING NEWS for their program. The Accused could have access to Ms. Sunanda Pushkar only and only in the capacity as a reporter/journalist working with ‘Times Now’ and not otherwise. Nowhere does the Accused No.2 claim that she was a friend or acquaintance of Ms. Sunanda Pushkar It is submitted that the Complainant and the entire management of “Times Now” channel were shocked to sce the said taped conversation being aired on “Republic TV.” In fact, the discussion inter se between Accused Mr. Arnab Goswami and Ms. Prema Sridevi and other participants in the said debate show discloses that the Accused admittedly claim that the said audio conversations were acquired by the Accused and was in their possession from two years prior to the date of airing those tapes, which is during their previous service, which obviously is in the year 2014 with “Times Now” channel when they were legally bound by their contract of work employment and the conditions therein. The Accused were also legally bound to forthwith hand over the taped conversations to the Complainant and the police as the death of Ms. Sunanda Pushkar was under investigation. Needless to say that, “Times Now” channel had and continues to enjoy copyright over the said audio conversations as they were collected during their employment and the same having been aired on “Republic TV” by Accused Mr. Arnab Goswami and Ms. Prema Sridevi, it was but obvious that both the Accused have committed theft of the said intellectual property of “Times Now” whilst in service of “Times Now” channel and in breach of the contract of employment had converted the said information into a program of breaking news and aired it on “Republic TV’ without the consent and knowledge of the “Times Now" channel and its management. In fact, Accused Mr. Arnab Goswami and Ms Prema Sridevi boldly admit and claim that the said audio conversation being aired on 8% May 2017 was in their possession for the last two years when they were in their previous organisation. Needless to say that such audio conversation with Accused No.1 and 2 could not been in their personal possession and in personal capacity and in terms of the contract of employment they continued to remain in possession of both the Accused as the intellectual property of “Times Now” channel over which they had full and exclusive right to the knowledge of said Accused persons IN TRUST Removal of the said intellectual property of “Times Now” channel by Accused Mr. Arnab Goswami and Ms. Prema Sridevi and utilizing the same on ‘Republic TV” was done intentionally to take the said intellectual property out of possession of “Times ” channel dishonestly without the consent of the Now’ management of “Times Now’ channel. Consequently, Accused No.1 and 2 have committed the offence of theft U/Sec.378 I.P.C punishable U/Sec.380 of the LP.C. Footage of the program wherein the said conversation is used on Republic TV is annexed hereto and marked as “Annexure 1a 13. 14. IL is submitted that this offence of theft punishable U/Sec.379 of LP.C. was committed by Accused Mr. Arab Goswami and Ms. Prema Sridevi, by hatching a criminal conspiracy to commit such offence with the intention of causing wrongful gain to the “Republic TV” channel by causing an upscale of TRP and a consequent wrongful loss to “Times Now” channel by causing a decline of the TRP. It is submitted that all the aforesaid Accused persons were well aware that their act of theft would cause severe loss and damage to “Times Now” channel and its revenue. Despite being aware of the same the aforesaid Accused persons have conspired inter se between themselves to commit the aforesaid offence of theft thereby causing wrongful loss the “Times Now” channel and wrongiul gain to themselves It is submitted that Accused No.1Mr. Arnab Goswami and Accused No.2 Ms, Prema Sridevi abovenamed in and others known and unknown willfully, deliberately and with knowledge converted to their own use for airing on ‘Republic TV” the aforesaid intellectual property of “Times Now” channel and thereby dishonestly misappropriated and converted to their own use the said intellectual property of “Times Now” channel, 15. thereby committing the offence of criminal misappropriation of property punishable U/Sec.403 of L.P.C. It is submitted that in terms of the employment contract of Accused No.1 and 2 the aforesaid intellectual property during the period of service until such time as they resigned from “Times Now” channel, the aforesaid intellectual property of “Times Now” channel being the audio conversations aired on “Republic TV’ on both the occasions i.e. on 6"* May 2017 as well as on 8 May 2017 continued to remain entrusted with Accused Mr. Arnab Goswami and Ms. Prema Sridevi with dominion over the said property having been given to them only for the purposes of airing the same in the form of a Breaking Story or Breaking News on The NEWS HOUR program or in any other news bulletin to be aired of “Times Now? channel. However, Accused Mr. Arnab Goswami and Ms. Prema Sridevi in breach of the reason, purpose and objective of having been entrusted dominion over the said intellectual property of “Times Now” channel, in collusion, connivance and conspiracy with others known and unknown including the Directors of M/s. ARG Oullier Media Asianet News Pvt. Ltd., dishonestly misappropriated and converted to their own use the said intellectual property and dishonestly used the same for airing on 16, “Republic TV” in violation of the direction of law and legal express contract, provided for in the respective employment contracts of Accused Mr. Arnab Goswami and Ms. Prema Sridevi prescribing the mode and manner in which such entrustment of intellectual property in both the Accused was expected to be discharged. Consequently, having misused the dominion over the said intellectual property and converted the same to their own use by airing the same on “Republic TV’, in breach of their express contract of employment, the Accused No.1 and Accused No.2 have committed offences punishable U/Sec.405 of the LP.C. and punishable U/Sec.406 L.P.C, It is submitted that the aforesaid offences have been committed by Accused Mr. Arnab Goswami and Ms. Prema Sridevi. The aforesaid Accused are consequently charged with having committed the aforesaid offences punishable U/Sec.405 read with 406 LP.C. read with Section 120-B of the 1.P.C. It is submitted that both Accused Mr. Arnab Goswami and Ms. Prema Sridevi were entrusted with the intellectual property of “Times Now” channel and dominion over the same, as an “agent” of “Times Now” channel authorized to continue to hold dominion over the entrusted property of “Times Now” channel from the date of its acquisition onwards till their resignation on 17. November, 2016 and December, 2016 respectively, to facilitate use of the said intellectual property during their period of service only for the purposes of preparing a story of breaking news on THE NEWS HOUR for “Times Now” channel only. However, having dishonestly converted dominion over the said intellectual property to their own use by airing the same on “Republic TV" on 6t May 2017 and 8® May 2017, the Accused Mr. Arnab Goswami and Ms. Prema Sridevi have committed the offence of criminal breach of trust as an “agent” of “Times Now” channel, inasmuch as the said intellectual property was being held by both the Accused for in the name and on behalf of “Times Now” channel as “agent” of “Times Now” channel. Moreover, Accused No.2 having been employed as a reporter for “Times Now” channel was in the position of an “agent” for and on behalf of “Times Now” channel, causing collection of information both digital as well as non digital for the purposes of compilation of data base for all the news programmes to be aired on Times Now channel. It is submitted that the aforesaid offence of criminal breach of trust as agent by Accused Mr. Amab Goswami and Ms. Prema Sridevi was committed and Consequently, the aforesaid Accused are charged with having committed offences punishable 18. U/Sec.406 LP.C. read with Section 120-B of the Indian Penal Code, It is submitted that the aforesaid audio conversations between Mr. Lalu Prasad Yadav and Mr. Shahabuddin which was aired on 6' May 2017 and the audio conversations between Accused No.2 and Late Ms, Sunanda Pushkar recorded between 16" and 17% January, 2014 was in possession held and controlled by “Times Now” channel for the purposes of airing the same on THE. NEWS HOUR program. Dominion over the said intellectual property was made accessible to Accused Mr. Arnab Goswami and Ms. Prema Sridevi for prescribed specific purposes and objective for airing the same on news channel, however, both the Accused, committed criminal misappropriation and criminal breach of trust in respect of such property but having stolen the same which was in the format of the computer resource and communication device, knowing and having reason to believe that the same when taken out of possession, control of “Times Now” channel as the intellectual property of “Times Now” channel, amounted to commission of offences of dishonestly receiving stolen computer resource and communication device 19. 20. thereby committing cognizable offences punishable U/Sec.66-B of the Information Technology Act 2000, It is submitted that both the said Accused pursuant to the authority vested in them under the employment contract with “times Now” channel, secured access to the information contained in the form of an electronic record by way of audio conversation and without the consent of “Times Now” channel and/or its management disclosed the said information contained in the audio conversation and maintained in the form of electronic record to the public at large by airing the same on ‘Republic TV" on 6'" May 2017 and 8% May 2017 without the consent of “Times Now” channel and its management, Consequently, the Accused Mr. Arnab Goswami and Ms. Prema Sridevi have committed the offence of breach of confidentiality and privacy as required to be maintained U/Sec.72 of the Information ‘Technology Act 2000. Jt is submitted that Accused Mr. Aranb Goswami and Ms. Prema Stidevi during the period of their employment contract of providing services to “Times Now” channel, in terms of their lawful employment contract, have secured access to material containing personal information about the conversation between Ale 7) Mr. Lalu Prasad Yadav and Mr. Shahabuddin as well as the conversation which the Accused No.2 had with Ms. Sunanda Pushkar and others and with the intent to cause and knowing that it is likely to cause wrongful loss to “Times Now” channel, without the consent of “Times Now” channel and its management and in extended breach of a lawful employment contract disclosed the said material to the public at large by airing the same on “Republic TV’ and thereby committed offence punishable U/Sec.72-A of the Information Technology Act, 2000. It is submitted that all the aforesaid Accused being the Promoters and Directors of M/s. ARG Outlier Media Asianet News Pvt. Ltd. along with others known and unknown have aided and abetted in the commission of the offences aforesaid and therefore stand charged with having committed the aforesaid offences in conspiracy with Accused Mr. Arnab Goswami and Ms. Prema Sridevi and others known and unknown. Consequently, all the aforesaid Accused deserve to be charged and tried for the aforesaid offences along with Section 120-B of the Indian Penal Code It is submitted that all the aforesaid Accused persons viz., the Promoters and Directors of M/s. ARG Outlier Media Asianet 23. 24. News Pvt, Ltd. along with others known and unknown by various acts of omission and commission done the aforesaid criminal acts inter se between themselves and with knowledge, collusion and conspiracy with each other, in furtherance of their common intention. Consequently, each of the aforesaid persons is liable for each of the aforesaid criminal acts in the same manner as if it were done each of the aforesaid Accused persons alone. In the circumstances, it is abundantly clear that all the aforesaid Accused dishonestly committed the aforesaid offences with the mala fide intention to grab viewership, deceive unsuspecting viewers, mislead the public at large and make erodes and gains on popularity and goodwill by motivating TRP on the strength of such stolen intellectual property over which neither the company M/s. ARG Outlier Media Asianet News Pvt. Ltd. nor the Accused Mr. Arnab Goswami and Ms. Prema Sridevi abovenamed nor “Republic TV” had even semblance of right to air on 6 May 2017 and 8 May 2017. The Accused are consequently charged with having committed offences punishable U/Sec.378 read with Section 379, 403, 405 read with Sections 406, 409, 411, 414, 418 of the Indian Penal 25, 26. Code, read with Section 66-B, 72 & 72-A of the Information ‘Technology Act 2000 read with Scction 34 and Section 120-B of the Indian Penal Code. As aforesaid in the foregoing paragraphs the above offences being cognizable in nature, you are hereby requested and called upon to record an FIR by registering a case for the aforesaid offences to facilitate further investigation in the matter. Needless to say that, since Accused Mr. Arnab Goswami and Ms. Prema Sridevi have been in employment under the contract of employment with “Times Now? channel for over a decade the “Dimes Now” channel rightly and justifiably apprehends that the said Accused along with others known and unknown as well as the Promoters and Directors of M/s. ARG Outlier Media Asianet News Pvt. Ltd. are and continue to remain in dishonest possession of similarly stolen intellectual property either in the form of digital or non digital/print information in electronic or any other form, which they shall over a period of time dishonestly air on “Republic TV’ in the forthcoming irying to portray that the said information was their personal possession. Recovery and/or discovery of such stolen intellectual property is a must to prove the charges carved out hereinabove against the 27. Accused abovenamed. In the absence of custodial interrogation, the entire process of investigation is likely to be severely prejudiced and compromised. To prevent such injury being caused to the case of the Complainant, it is just, fair and proper that immediately upon registration of an FIR, and case against the abovenamed Accused, the police needs to ing into immediate action by due process of law taking the Accused into custody for the purposes of investigation and recovery and discovery at their instance of the stolen intellectual property which they continue to retain dishonestly in their possession. In the circumstances the undersigned Complainant pray that action be taken on this complaint in terms of the law laid down by the Hon'ble Supreme Court in the matter of Lalitha Kumari failing which the same shall be considered as a deliberate breach of the guidelines of the Hon’ble Supreme Court compelling and constraining the Complainant to knock the doors of the High Court and the Supreme Court for reliefs in terms of the observations made by the Hon’ble Supreme Court in the case of Lalitha Kumari, while dealing with such breach by the police department. Thanking you, Yours faithfully, For Bennett, Coleman & Co. Ltd. (Television Div) wos We Manish Wadkar Authorised Signatory Encl. As above. Copy to : Commissioner of Police Mumbai Police Commissionerate Crawford Market, Mumbai.