constitutes defamation differs from country to country. For example, in the U.K., the onus is upon the Defendants to show that the content is not defamatory. However, in the U.S., the onus on the Plaintiff in a defamation action is very high. Defamation laws differs from jurisdiction to jurisdiction, and therefore, passing of a global disabling order would be contrary to the principle of comity of Courts and would result in conflict of laws. 11. Mr. Tripathi further submits that the issues raised could have far reaching impact, and Section 79 of the Act is a work in progress. Dissemination of views on the internet is an essential ingredient of freedom of speech and expression and the integrity of national judicial systems has to be maintained. In fact, the injuncted book is itself available on various platforms internationally, which itself shows that the injunction has to be restricted to India alone. Plaintiff No.1, being a public figure, should be open to criticism. He submits that an injunction would not be liable to be granted inter alia on the following grounds: i) The main Defendants i.e. the persons who have uploaded the video have not been impleaded; ii) Though the Court has jurisdiction to pass a global injunction order, which is clear from a reading of Articles 244 and 246 of the Constitution, which provide for implicit long arm jurisdiction, the Court ought to be reluctant to pass a global blocking order; iii) In order to ensure that access is disabled, the platforms have resorted to geo-blocking which is more than sufficient to take care of the Plaintiffs‟ interests; iv) The Plaintiffs have not brought on record any evidence to show as to whether anyone has viewed the content globally; CS (OS) 27/2019 Page 7 of 76