released till the date of passing of the judgment by Narula, J., no question of any allegation of defamation, based on the film, could have existed. 14.9 As against this, the amendments to the plaint, which have been effected after the film had been released, specifically alleged that the film is based on unverified and unauthenticated news reports, many of which were defamatory to SSR, without verifying either their truth or their authenticity. As such, specific allegations of damage to the reputation of SSR have been incorporated in the amended plaint. It has also been alleged that several parts of the film are salacious and promiscuous and portray SSR in a negative light. These allegations are in addition, and de hors, the contention that no one could have publicised the life of SSR, or made any film based on his life, without obtaining prior permission of the plaintiff. 14.10 I am, therefore, of the considered opinion that, in examining IA 10551/2021, this Bench cannot regard itself as bound by the observations and findings of Narula, J., but would have to proceed on the basis that it has before it, a tabula rasa. Rival Contentions 15. Opening submissions of Mr Varun Singh 15.1 Mr. Varun Singh, learned Counsel for the plaintiff, submits that, over a period of time, celebrity rights have emerged as a distinct Signature Not Verified Signed By:KAMLA CS(COMM) RAWAT Signing Date:12.07.2023 10:10:24 187/2021 Page 14 of 68