14. Mr. Arvind Nigam, ld. Senior Counsel appearing for Google Inc. and YouTube LLC takes the following preliminary objections: i) That the suit has been filed by a Power of Attorney – Mr. Gyandeep Sharma. Since an action for defamation is an action in personam, the Plaintiff ought to have personally verified and filed the plaint. ii) That the suit lacks cause of action as there is nothing offensive contained in the video. iii) That the plaint does not refer to the judgment of the ld. Single Judge in CM(M) 556/2018, which has only been placed before the Court during the course of arguments, and only the closure report of the CBI was relied on. (iv) That the plaint relies upon four pages of URLs, however, there is no mention as to which is the one which is extracted in the Plaint. (v) That none of the persons who have uploaded the video have been impleaded. (vi) That there is no mention as to which is the offensive part in the video. It is the settled position that the specific words which are defamatory have to be pointed out, as held in the judgment of the Supreme Court in R. Rajagopal v. State of Tamil Nadu 1994 SCC (6) 632. Since the entire plaint is mere paraphrasing and is only alleging innuendo, the plaint ought to be rejected. (vii) That the necessary party i.e. the uploader of the video having not been impleaded, the suit would be liable to be dismissed. He relies upon the judgments in ABC Laminart v AP Agencies, Salem (1989) 2 SCC 163 and Ramesh Hirachand Kundanmal v Municipal Corporation of Greater Bombay and Others (1992) 2 SCC 524 to CS (OS) 27/2019 Page 10 of 76