(supra), it has been held by the Court that the injunction, if any, has to be in the narrowest terms. Rejoinder submissions by the Plaintiffs 18. In rejoinder submissions, Mr. Darpan Wadhwa, ld. Senior Counsel submits that the plaint is not lacking in material particulars. In various paragraphs, the manner in which the content uploaded in the video is defamatory has been set out. Specific reliance is placed on pages 31, 33, 38, 39 and 53 of the plaint. Reliance is also placed on the judgment of the ld. Single Judge, specifically, pages 91, 118, 119, 121, 178, 179 and 201 where the very same content, as contained in the video, has been dealt with as part of the book. It is further submitted by Mr. Wadhwa that the right of reputation is a Right under Article 21 of the Constitution. Thus, the Court has to balance the Plaintiff‟s rights enshrined in Article 21 as against the rights under Article 19, which are being claimed by the platforms 19. Insofar as the argument of mis-joinder and non-joinder is concerned, he submits that the BSI does not give any details except the IP addresses. Only in some cases, mobile numbers and e-mail addresses have been given. It is not clear if those individuals are even identifiable. 20. He relies upon the pleadings i.e. written statements filed by the platforms wherein the platforms are attempting to justify as to why global blocking orders ought not to be granted. He submits that the apprehensions of conflict of laws and violation of the principle of comity of courts are all theoretical. He relies upon the judgment in Equustek-I (supra), especially paragraphs 20 and 27, to argue that Google Inc. is subject to personal jurisdiction before this Court and hence any injunction order granted by the CS (OS) 27/2019 Page 13 of 76

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