Dr. Mukul Sinha, Advocate, High Court of Gujarat, At office: 2, Swagat Palace, Ambli-Bo al !

oad, Ahmedabad-"#$ $%#&

Dated: 22-11-2013

To, Madhu Purnima Kishwar, At Address: C/13, Sangam state, 1, !nder "i## $oad, Ci%i# &ines, De#hi- 1100'(

Su)*e+t: ,oti+e in res-e+t o. the de.amator/ a##egations made )/ /ou against m/ +#ient Pradee- , Sharma

Madam,

0n instru+tion o. m/ +#ient Shri Pradee- , Sharma, resident o. (1'/A/2, Se+tor 1, 2andhinagar, aged '3 /ears, o++u-ation 4ndian Administrati%e Ser%i+e, 4 here)/ gi%e /ou the .o##owing noti+e on the a)o%e su)*e+t matter:

1. That m/ +#ient Shri Pradee- , Sharma is a mem)er o. the 4ndian Administrati%e Ser%i+e, ha%ing *oined the ser%i+e in the /ear 15316 "e )e#ongs to a %er/ re-uted and esta)#ished .ami#/ o. the +it/ o. Ahmeda)ad6 The .ather o. m/ +#ient was a we## 7nown -o#i+e o..i+er and the e#der )rother o. m/ +#ient is a retired 4PS o..i+er6

2. 0n instru+tion o. m/ +#ient, 4 ha%e to state that on 11 th ,o%em)er, 2013 10:'3 a6m6, it was )rought to the noti+e o. m/ +#ient )/ +ertain .riends that /ou had -osted +ertain de.amator/ and derogator/ messages on /our twitter a++ount 89madhu7ishwar: against m/ +#ient Shri Pradee- Sharma whi+h are re-rodu+ed here in )e#ow:

Cobrapost

has

relied

on

compromised

corrupt

officials-

IAS

officer

Pradeep Sharma, his brother Kuldip sharma are known rogue officers 1\n Ask Gu arat officers an! or people in districts where brothers Pradeep " Kuldip Sharma posted, u hear hideous stories of their corruption#\n

4 ha%e to state on instru+tions that a##egations made )/ /ou against Shri Pradee- Sharma are not on#/ .a#se and )ase#ess )ut a#so de.amator/, ma#i+ious and made with the de#i)erate intention o. damaging the re-utation o. m/ +#ient and his )rother Ku#di- Sharma who ha%e high standing in the so+iet/6 0n instru+tion o. m/ +#ient 4 ha%e to sa/ that he has ne%er )een +harged o. an/ +orru-tion, sa%e and e;+e-t, a.ter the Chie. Minister Shri ,arendra Modi started sus-e+ting m/ +#ient o. )eing -ri%/ to some in.ormation regarding the re#ation )etween the Chie. Minister and the -erson /ou ha%e re.erred to as Madhuri 9 Mansi Soni and a#so de%e#o-ing di..eren+es with his )rother, a senior 4PS o..i+er and to %i+timi<e his )rother, m/ +#ient was a#so targeted6 Certain +ases whi+h were .i#ed against m/ +#ient with the ma#a.ide o)*e+ti%e o. %i+timi<ing him on and a.ter 2010 are -ending and there.ore m/ +#ient does not wish to o..er an/ +omments on the -ending +ases6 4 ha%e to sa/ that the -enden+/ o. these +ases, no one has authorit/ to +omment on these +ases or to a##ege that m/ +#ient is +orru-t and #east o. a## de.ame m/ +#ient -u)#i+#/ )/ de#i)erating -osting the messages on /our -ersona# twitter a++ount6 4t is need#ess to -oint out that mi##ions o. -eo-#e ha%e a++ess to the messages whi+h are -osted on twitter and /ou had -osted the a.oresaid derogator/ and de.amator/ messages to de#i)erate#/ de.ame m/ +#ient )e.ore the so+iet/ in genera#6 4n .a+t, se%era# .riends and .ami#/ mem)ers ha%e )een in.orming m/ +#ient a)out the derogator/ messages .rom /ou and ha%e )een e;-ressing their re%u#sion at su+h de.amator/ a##egations )eing +ir+u#ated )/ /ou6 4 ha%e to there.ore sa/ that /ou are s=uare#/ gui#t/ o. +ommitting the o..en+e o. de.amation as de.ined under the se+tion (55 o. 4ndian Pena# Code6 4 add that the statements +ir+u#ated )/ /ou as a.oresaid are de.amation -er-se6

3. 0n instru+tion o. m/ +#ient, 4 ha%e to state that on 11 th ,o%em)er, 2013, /ou had +ir+u#ated .ew other de.amator/ and derogator/ messages against m/ +#ient Shri Pradee- Sharma on /our twitter a++ount 89madhu7ishwar: that ha%e )een )rought to the noti+e o. m/ +#ient )/ +ertain .riends6 These messages are re-rodu+ed here in )e#ow6

$%adhuri&s$ father sa!s in I' he re(uested modi to daughter on watch) *eason+ she was ha,ing affair with criminal " debauch Pradeep Sharma-

4 ha%e to state on instru+tions that a)o%e a##egations made )/ /ou against Shri Pradee- Sharma are a)so#ute#/ .a#se and )ase#ess6 4 ha%e to state that m/ +#ient is a +ommitted and ha--/ .ami#/ man and /our a##egation that he is a >de)au+h> and/or in re#ation with some gir# /ou +a## Madhuri is a)so#ute#/ .a#se, )ase#ess and mis+hie%ous6 Su+h dirt/ and #oathsome a##egations made )/ /ou ha%e se%ere#/ harmed the re-utation o. m/ +#ient )e.ore his .ami#/ mem)ers, .riends and the so+iet/ in genera#6 0n instru+tion o. m/ +#ient 4 ha%e to state that as -er the 7now#edge o. m/ +#ient, during the -eriod 200' to 2003, the Chie. Minister and Mansi Soni had maintained +#ose -ersona# re#ationshi- and Ms Soni had on %arious o++asions +on.ided in m/ +#ient regarding her re#ation with Modi6 M/ +#ient was to#d sometime in Mar+h, 2001, Ms Soni had in.ormed m/ +#ient that she had s-ent two da/s time with the CM Mr Modi at his residen+e, 2andhinagar6 0n instru+tion 4 ha%e to there.ore state that /our a##egation that Madhuri 9 Mansi Soni had an a..air with m/ +#ient is tota##/ .a#se and got u- and m/ +#ient +ategori+a##/ denies su+h mis+hie%ous a##egations6 0n the +ontrar/, it is in the -ersona# 7now#edge o. m/ +#ient that Ms Mansi Soni had maintained a -ersona# re#ationshi- with the Chie. Minister Mr6 ,arendra Modi and to +o%er u- this re#ationshi-, /ou ha%e made su+h .a#se and atro+ious a##egations against m/ +#ient6

36

0n .urther instru+tions o. m/ +#ient, 4 ha%e to state that /ou had

a--eared in a ta#7 show hosted on C,,-4?, tit#ed @4ndia at 5: Ta#7ing Points Sahi)-Shah Ta-es: Are the/ a huge em)arrassment .or ModiAB at 5 -6m6 on ,o%em)er 13th 20036 The trans+ri-t o. /our o-ening s-ee+h is re-rodu+ed here in under6 Title of the talk show: India at 9: Talking Points Sahib-Shah Tapes: Are they a huge embarrassment for Modi?

*a deep Sardesai. %adhu Kishwar, wh! don&t !ou take it head on since !ou&,e been a great supporter of /arendra %odi+ 0ue to a belief a case like this is an embarrassment for the Gu arat Chief %inister+ 1he fact that these tapes are coming out in the public domain that suggest that he had authori2ed the stalking of the woman

%adhu Kishwar. 3irstl! *a deep I would like to correct !ou, m! ob has been to unra,el la!er upon la!er of falsities and untruths being spread about %odi) I was not a supporter of 456 or %odi) I ust started stud!ing Gu arat and I found such humongous mountains of lies) 7hile I was tra,elling in Gu arat, I had heard enough e,en before this case came up) I heard enough about these two brothers Kuldip Sharma, 6radeep Sharma and their father b! the wa!, known as, used to be called /agad /arain Sharma) 1his is the most corrupt criminal minded team of fatherson duo) oka! /ow fact of the matter is it illegal if girl came upto !ou or to an!one else and said I was being illegall! trapped) 1hat8s not the case) 9er famil! has said that the! were tr!ing to protect her) 1he! had this criminall! minded accused, he&s in,ol,ed in ma or land scams))

*a deep Sardesai. 9old on %adam, 9old on %adam, 4efore !ou sa! criminal minded accused, let me ust tell our ,iewers that 6radeep Sharma was the %unicipal Commissioner of 4hu and Kuldip Sharma is a former I6S officer, one of the most distinguished officers of one time of Gu arat I might tell !ou %adhu Kishwar) %a! be as part of !our homework !ou should go and meet I6S officers of 0elhi and Gu arat and the! will tell !ou))

%adhu Kishwar. I ha,e done that, I ha,e done that

*a deep Sardesai. I&m sorr! %adhu Kishwar, some of us know as much as !ou do) :et8s not defame an officer) :et8s not defame an officer)

%adhu Kishwar. :et8s not defame, but there is a court case b! people from the da!s of the earth (uake for a huge land scam, 1;;; acres of land and )) 6radeep Sharma

*a deep Sardesai. I agree, I take !our point)) 6radeep Sharma was arrested) 6radeep Sharma was arrested)

%adhu Kishwar. :et me finish, :et me finish, what I8m sa!ing is this man if he is using his official position to harass and se<uall! e<ploit someone then can !ou call it illegal sur,eillance if the famil! has said that she needed protection that8s no one) Secondl! do !ou reali2e that !ou are ,iolating her pri,ac!, , she&s not coming complaining to !ou and thirdl! it is ,er! ,er! important that this same Congress 6art! was snooping on 6ranab %ukher ee when he was a Cabinet %inister, none of !ou ha,e allowed that phase to be actuall! unra,eled) Imagine a cabinet minister complaining, what happened, where is the in(uir!+ =ne last point, 9uman *ights Commission member %r S6 Sinha man! months ago told me that what the! are doing with Singla as well as what the! are did with >an2ara is what !ou call as as &legal third degree& because as a (uid pro (uo for Singla being bail which he was not entitled to the! are doing that) /ow this is C4I&s propert!)))))-

4n the a.oresaid o-ening s-ee+h, /ou ha%e on+e again made a)so#ute#/ )ra<en a##egations against m/ +#ient, .irst#/ a##eging that m/ +#ient has misused his o..i+ia# -osition to harass and se;ua##/ e;-#oit Madhuri and /ou ha%e a#so a##eged that the .ather o. m/ +#ient is a %er/ +orru-t and that .ather-son are 7nown to )e a %er/ +orru-t and +rimina# team et+ et+6 4 ha%e to state that these a##egations are not mere#/ .a#se )ut se%ere#/ derogator/ and de.amator/ and /ou ha%e gone to the e;tent o. de.aming the .ather o. m/ +#ient who has died o%er a de+ade )a+76 This -rogram was wat+hed )/ mi##ions o. -eo-#e in 4ndia and a)road and m/ +#ient has )een a++osted with innumera)#e +ommuni+ations .rom his .riends and others are a)so#ute#/ sho+7ed to hear su+h de.amator/ a##egations )eing aired )/ /ou through the media o. C,,-4?,6 As the a##egations amount to de.amation -er-se, /ou ha%e s=uare#/ +ommitted the o..i+e o. wi##.u# de.amation against m/ +#ient as -er the de.inition o. Se+tion (55 o. the 4ndian Pena# Code6

(6

As i. the a)o%e a+t o. de.amation was not enough, /ou ha%e on+e again

-osted messages through /our twitter a++ount on 13 th o. ,o%em)er 2013, whi+h are re-rodu+ed here in )e#ow:

Pradeep Sharma might well ha,e done to$%adhuri$ what 0IG *athore did to *uchika Gehlot or %aderna did to 4hanwari 0e,i under Congress rule-

4 ha%e to state that the a.oresaid a##egations made )/ /ou and -u)#ished on /our twitter a++ount 89madhu7ishwar: amounts to the grossest de.amation in as mu+h as /ou are a##eging that m/ +#ient has -er-etrated o..en+es whi+h are same or simi#ar to the a+ts/o..en+es -er-etrated )/ D42 $athore and Maderna on their %i+tims whi+h are now o. -u)#i+ 7now#edge are a+ts and o..en+es o. mo#estation, ra-e and murder o. women6 ?/ a##eging that m/ +#ient might we## ha%e done to @MadhuriB, what Maderna and D42 $athore had -er-etrated on their %i+tims, /ou ha%e )/ innuendo a#so a##eged that m/ +#ient +ou#d ha%e +ommitted mo#estation/ra-e/murder o. Madhuri and .or that reason the sur%ei##an+e was ordered6 Cour a##egation )esides )eing .a#se, disgusting and #oathsome has +om-#ete#/ tarnished the .air re-utation o. m/ +#ient in the e/es o. his .ami#/ mem)ers, .riends, +adre o..i+ers as we## as so+iet/ in genera#6

4. 4n the a.oresaid .a+ts and +ir+umstan+es 4 ha%e to state that sin+e 11 th ,o%em)er, 2013 ti## toda/, /ou ha%e re-eated#/ +ontinued to de.ame m/ +#ient through /our tweets as we## as /our a--earan+es/utteran+es through the nationa# te#e%ision +hanne# C,,-4?,6 As -er the in.ormation /ou are the editor o. Manushi, a we## 7nown maga<ine and there.ore /ou as a *ourna#ist is aware o. the #aw o. de.amation and /ou ought to )e .u##/ aware that /ou ha%e a)so#ute#/ no right to ma7e su+h .a#se and de.amator/ a##egations against m/ +#ient6 4n that %iew o. the matter, 4 ha%e to su)mit that /ou are s=uare#/ gui#t/ o. +ommitting the o..en+e o. wi##.u# de.amation against m/ +#ient as de.ined under the Se+tion '00 o. the 4ndian Pena# Code and /ou are a#so #ia)#e to )e sued .or damages as we##6 ?/ this noti+e, 4 wou#d there.ore +a## u-on /ou to desist ma7ing an/ .urther de.amator/ statements against m/ +#ient and re-#/ as to wh/ a +rimina# +ase under se+tion '00 o. 4PC shou#d not )e .i#ed against /ou and/or a suit .or an amount o. $s 1 +rore .or damages )e .i#ed against /ou .or de.aming o. m/ +#ient6 4n +ase we do not hear .rom /ou within (3 hours, it wi## )e o-en .or m/ +#ient to .i#e an a--ro-riate +rimina# +ase and/or .i#e an a--ro-riate suit .or damages at /our +ost and ris7 whi+h ma/ 7ind#/ )e noted6

Dr Mu7u# Sinha, Ad%o+ate .or Pradee- , Sharma