V.G.PRAGASAM.

,
S.J.ARISTOTLE.,
Advocates-On-Record,
Supreme Court of India

To 02-06-11
New Delhi.
1. R. Kannan,
Editor, Anandha Vikatan,
Vasan Publications (P) Limited,
757, Anna Salai,
Chennai – 600 002.

2. K. Asokan,
Printer and Publisher,
Anandha Vikatan,
Vasan Publications (P) Limited,
757, Anna Salai,
Chennai – 600 002.

3. S. Madhavan,
Printer, Anandha Vikatan,
Vasan Publications (P) Limited,
757, Anna Salai,
Chennai – 600 002.

4. P. Thirumavelan,
News Editor, Anandha Vikatan,
Vasan Publications (P) Limited,
757, Anna Salai,
Chennai – 600 002.

5. R. Saravanan
Correspondent, Anandha Vikatan,
Vasan Publications (P) Limited,
757, Anna Salai,
Chennai – 600 002.

Sirs,

Re: Legal Notice Regarding Publication of Article in Anandha Vikatan Dated 01.06.2011

Under instructions from our Client Ms. Kanimozhi Karunanidhi residing at 14, Ist Main Road, CIT
Colony, Alwarpet, Chennai - 4, the following legal notice is issued to you:

1. Our Client is a Member of Parliament (Rajya Sabha) since 2007 and is presently in judicial
custody in relation to CC-1A/2011 in FIR number RC-DAI-2009-A-0045 registered by CBI, in the

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V.G.PRAGASAM.,
S.J.ARISTOTLE.,
Advocates-On-Record,
Supreme Court of India

Patiala House Courts, New Delhi.

2. Our Client states that in the “Anandha Vikadan” edition dated 01.06.2011, you have published an
article titled "Ammavai Mannichividu Aadhi" authored by R. Saravanan, the addressee No. 5 herein,
along with a photograph of our Client and her minor son Aadhithyan aged about 11 years. Our Client
further states that, under the guise of reporting the proceedings in the Patiala House Court complex, you
have published the aforesaid article which is imaginary, derogatory and mischievous. Besides, the
publication of the photograph of the minor son of our Client is highly defamatory, malicious and against
all established ethics of journalism.

3. Our Client states that her son is a school going child and the publication of the aforesaid article
and photograph tends to identify him and embarrass him among his peers and teachers. Your action of
publication of photograph and article relating to the minor son of our client is illegal, unwarranted and
would unnecessarily bring the child into public focus, which, 'inter alia,' infringes upon a child's right to
privacy and compromises his safety and security. It is amply clear that this is a calculated attempt with
ulterior motive to mentally torture, malign, intimidate and shame our Client's minor child. You have
completely abused the freedom of press with total disregard to any probity, moral/ethics.

4. You are aware that as per international treaties and norms, mandatory legal requirements
warrant media to exercise extreme restraint and circumspection while reporting matters relating to
minor children especially publication of their photographs. The ongoing legal proceedings have already
imposed much suffering and difficulties on our Client and her minor child. Our Client states that the
aforesaid act of your publication regarding a sub-judice matter has in addition caused psychological
trauma on her minor child depriving him of his right to be brought up in a normal and healthy
environment.

5. Our Client states that, in your article, and title to the photo, you have sought to portray an
impression as if you were privy to a personal conversation between her and her minor child. Our Client
refutes this portrayal as completely untrue and intentionally misleading. Our Client finds no reason or

No.104, V Floor, Tower 12, Supreme Enclave Apartments, Mayur Vihar Phase-I,
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V.G.PRAGASAM.,
S.J.ARISTOTLE.,
Advocates-On-Record,
Supreme Court of India

rhyme in continuously publishing the photograph of her minor child with utmost prominence, except
with a malafide intention to cause harm and mental agony.
6. Our Client further states that this is not the first time her son’s photograph is being published by
you. In your issue dated 30.03.2011, you had printed the photograph of our Client’s minor child, in total
disregard to the Child’s privacy and privileges, and you had mischievously claimed that Ministers of
Government of Tamil Nadu were playing cricket with him in order to win favours from our Client’s
family. Our Client takes very serious exception to these repeated baseless, slanderous and defamatory
pieces of writing and publication of the photographs of our Client’s minor child.

7. Our Client states that, after the aforesaid publication dated 30.03.2011, she had specifically
requested you orally several times to refrain from publishing the photograph of her minor child. Despite
such requests, it is abundantly clear that your repeated publication of the photographs of our Client's
minor child is a vengeful act filled with dishonourable and disgraceful intent.

8. In this regard, we have to point out that, Article 2 of the United Nations Convention on Rights of
the Child 1989, which mandates the member-countries that they “should ensure the rights of the child,
irrespective of the child’s or his parent’s or legal guardian’s race, colour, sex, language, religion,
political or other opinions…”. Your mindless and motivated reporting wherein you have dragged the
name of our Client’s minor son, and the mischievous manner in which you have published the
photograph, would seriously compromise the safety and security of the minor child, besides impeding
the full and harmonious development of child’s personality. Your inconsiderate article and the
photograph have infused ignominy, embarrassment, confusion and disgrace into the young mind, which
is in no way connected with public office and social status associated with his mother or the false and
frivolous case foisted against her.

9. Further, Article 16 of The United Nations Convention on the Rights of a Child (Nov. 1989)
clearly prohibits that: “No child shall be subjected to arbitrary or unlawful interference with his or her
privacy, family, home or correspondence nor to unlawful attacks on his or her honour and reputation.”

No.104, V Floor, Tower 12, Supreme Enclave Apartments, Mayur Vihar Phase-I,
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V.G.PRAGASAM.,
S.J.ARISTOTLE.,
Advocates-On-Record,
Supreme Court of India

10. Our Client’s family has been in public life for over 70 years. It is matter of grave concern that by
your constant publishing of her minor son's photograph there is a possibility of his identity being
revealed, which is detrimental for his safety and security. Our Client states that, by publishing the
photograph of our Client’s minor son, you have infringed upon his right to privacy and special care,
besides flouting international conventions and treaties relating to the rights of minor child and adopted
by India. Your malafide act, to satisfy commercial considerations, has left an indelible scar in the child’s
mind.

11. The individual and combined act of all of you, amounts to offences punishable under Sections
336,500,501 and 502 of Indian Penal Code, among other offences and our Client contemplates to
initiate appropriate, criminal and civil proceedings against all of you. The act of publishing the
photographs of our Client's minor child has caused immeasurable mental agony and torture for which
our Client also reserves her right to initiate appropriate legal proceedings without prejudice to her rights
to claim damages.

12. Our Client hereby calls upon all the addressees to refrain from repeating such unethical acts of
publishing articles and photograph relating to her minor child. Our Client further calls upon you to
immediately tender your open and unconditional apology within three days from the date of receipt of
this notice, by publishing your apology, in your magazine giving the same prominence, as was given to
the defamatory news item, failing which our Client will be constrained to institute criminal and civil
proceedings against all of you besides initiating contempt of court proceedings as the matter is sub-
judice. Needless to mention that all legal actions initiated by our Client will be at your own costs,
consequences and peril.

V.G.PRAGASAM.,

No.104, V Floor, Tower 12, Supreme Enclave Apartments, Mayur Vihar Phase-I,
Delhi-110091
Mob - + 91 9212018118, Tele Fax- 011 -22754773, email – aristotlesj@gmail.com
V.G.PRAGASAM.,
S.J.ARISTOTLE.,
Advocates-On-Record,
Supreme Court of India

S.J.ARISTOTLE.,

Advocates On Record.,
Supreme Court of India.

No.104, V Floor, Tower 12, Supreme Enclave Apartments, Mayur Vihar Phase-I,
Delhi-110091
Mob - + 91 9212018118, Tele Fax- 011 -22754773, email – aristotlesj@gmail.com