argue that if a necessary party is not impleaded, the suit would be liable to be dismissed. 15. It is further submitted by Mr. Nigam that the order of ld. Single Judge in CM(M) 556/2018, which is in the public domain, itself contains the offending parts, and thus firstly, as Courts have to consider as to whether the content is vexatious or scandalous, the judicial record itself becomes defamatory. He relies on a judgment passed in the case of HPS Chawla v NPS Chawla and Ors. FAO (OS) No. 55/2005 (Decided on 22nd September, 2005) to submit that redaction was directed in the judicial order to ensure that offensive content is not made public. Since the Plaintiff is in public life and runs a business organization for crores worth of business, the Plaintiff ought to be open to criticism. 16. Insofar as the Act is concerned, it is submitted that under Section 1(2), it applies to only to the territory of India. Though under Section 75 it is clear that the Act applies to any offence or contravention committed outside of India if the same is committed through a computer, computer system or computer network located in India, the contraventions as contemplated under the Act are provided for in Sections 43, 43A, 66A, 66B, 66 66E and Section 66F. However, defamation is not covered in these provisions. Reliance is also placed on the decision in Playboy v. Chuckleberry 939 F. Supp. 1032 (S.D.N.Y. 1996) to argue that a U.S. court in the said case had held that there could not be an injunction by a U.S. Court against publication of a magazine titled „Playmen‟ in Italy. It is further argued that the grant of a global injunction at the interim stage is like decreeing the suit. Since the Plaintiff‟s reputation is restricted and localised in India, the Plaintiff is adequately protected by geo-blocking. If the uploader himself removes the CS (OS) 27/2019 Page 11 of 76

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