reputation or to assuage his injured feelings.”75 Instead, the plaintiff “wished to punish the respondent but also that he saw the opportunity to institute proceedings against the respondent […and…] to teach others that the ‘time for impunity is gone’ and in so doing prevent public comment on his conduct and/or matters of public importance in which he may have been directly or indirectly involved.”76 The Court also considered the nature of remedies sought, namely the request for an apology and a retraction.77 l l The motive of plaintiffs was relied on in awarding damages in Bombay in NSE v. Moneywise Media Private Limited,78 concerning an application for an interim injunction on a defamation action filed by one of the premier stock exchanges in India (NSE) against an online newspaper. The High Court declined the application79 and awarded costs recognising that the application for injunction was an abuse of process brought in mala fide.80 The Court imposed awards as a disciplinary measure to ensure Courts are not used “as playgrounds for imagined and imaginary slights for those who command considerable resources”.81 The judge highlighted that there was no prima facie claim in the application, neither a question of balance of convenience or any sort of prejudice caused to the plaintiffs if the injunction was declined.82 The rules on abuse of the law were used to qualify SLAPPs as a form of “judicial harassment” against freedom of expression in Ciro Guerra Picón v. Catalina Ruiz-Navarro & Matilde de los Milagros Londoño.83 The case concerned a constitutional action (amparo) initiated by a famous movie director against two feminist journalists. The journalists published accusations of eight victims of sexual harassment and violence against this movie director. The Court denied constitutional protection of the claimant’s good name, honour, and presumption of innocence84 after assessing whether the case constituted judicial harassment. The Court reached this conclusion by applying the following criteria: (i)the claimant makes use of the right to litigate with the purpose of silencing expression, especially when it concerns a public interest matter; (ii) the person has good economic resources that allow him/her to pay legal services and cover the costs of access to justice; (iii) there is a power imbalance between the parties; (iv) the claimant formulates disproportionate or impossible claims to be satisfied by the defendant, especially, millionaire compensations; (v) the action is filed seeking to generate a silencing effect or chilling effect.85 The Court found inter alia power imbalance and the use of multiple legal avenues to claim damages 75 Ibid. 76 Ibid., para 39. 77 Ibid., paras 40 and 49. 78 The High Court of Judicature at Bombay, National Stock Exchange of India Limited v. Moneywise Media Private Limited & Others, Notice of Motion no. 1220 of 2015, Suit no. 627 of 2015, 9 September 2015. The case summary of the decision by Global Freedom of Expression is available here. 79 bid., para 27. 80 Ibid., para 28 and 29. 81 Ibid. 82 Ibid., para 27. 83 Constitutional Court of Colombia, Ciro Guerra Picón v. Catalina Ruiz-Navarro & Matilde de los Milagros Londoño, Sentence T-452/22, 12 December 2022. The case summary of the decision by Global Freedom of Expression is available here. 84 Ibid., para 431 in connection with paras 427-430. 85 Ibid., para 426 in relation with 305 & 306.