from one country to another, an Indian court‟s perception of public interest ought not to bind other jurisdictions. He further submits that the right of freedom of speech and expression in India ought to be at least as much as in the U.S., and the principles of territoriality ought to be applicable in these cases. A decision of the Sao Paulo State Court of Appeal, Brazil in Twitter Brasil Rede de Infromacao Ltda v. Tim Cellular S/A, Interlocutory Appeal No. 2055830-58.2016.8.26.0000 is relied upon in support of the principle of territoriality. Reliance is also placed on an article written by Marc P. Epstein published in the Fordham Law Review titled Comity Concerns Are No Joke: Recognition of Foreign Judgments Under Dormant Foreign Affairs Preemption3 which severely criticized what was termed as “libel tourism.” Further reliance is also placed on a publication by Alex Mills titled “The Law Applicable to Cross-Border Defamation on Social Media: Whose law governs free speech in ‗Facebookistan4‘ published in the Journal of Media Law, wherein the author raises the question as to whose laws govern free speech on social media platforms. It is argued that if orders can be passed by national Courts which would result in global removal of content, then law of free speech on internet would be reduced to the lowest common denominator. 13. Mr. Tripathi also cites the order of this Court dated 14th January, 2019 in Sasikala Pushpa v. Facebook & Ors. CS (OS) 510/2016 and order dated 25th April, 2019 passed by this Court in Patanjali Ayurved Ltd. v Facebook Inc. & Ors. CS (OS)449/2018. 3 Marc P. Epstein, Comity Concerns Are No Joke: Recognition of Foreign Judgments Under Dormant Foreign Affairs Preemption, 82 Fordham Law Review 2317 (2014) 4 Alex Mills, The Law Applicable to Cross-Border Defamation on Social Media: Whose law governs free speech in ‗Facebookistan‘, Journal of Media Law 7 (2015) 1-35 CS (OS) 27/2019 Page 9 of 76