Analysis of DP Chowdhary v Manjulatha case by Krishna Sreeja @lexcliq


The courts in India have seen a  variety of defamation cases. Of these the following is one of the  landmark cases which have interesting facts or  have an important count ruling regarding defamation.

Any type of deliberate false communication either written or spoken, that can harm a person’s reputation or decreases the respect, regard or confidence of a person; induces disparaging, or a hostile opinion as or feeling against a person is known as Defamation.


D.P. Choudhary vs. Manjulatha :


Kumari Manjulatha, daughter of Mohan Singh, was a BA student and  all her family members are well educated and valued in the Society. But, a local daily newspaper called Dainik Navjyoti, published a news about her which caused the damage to her reputation and affected her family members. The journal published that, Manjulatha had an affair with someone, and she ran away  from her home with that guy. This news caused a greater damage to her and her family’s reputation. Because of this news, many people started pointing at her and her marriage proposals also ruined. These all situations caused her a great mental trauma and she developed inferiority complex. Then, along with her family members, she sent a legal notice to the  publisher of the newspaper asking him to pay a compensation of 10,000 for their loss. The news paper authorities claimed that the news published was a truth and it was verified and collected information from the plaintiff’s mother and ignored the notice. Later, in the district court, they further argued that the news published was truth and it was made in good faith to help the family members to get their daughter back to home.


The district judge ruled  in favour of Manjulatha and asked the publisher of newspaper to pay  them a compensation of 10,000/-. Then the  defendant appealed this matter in High Court. It was verified from the evidences of records that, it was not a truth. The appellants further argued that they had no intention to cause any damage to her reputation. But the High Court, given its verdict that the malice or mala fide intention was irrelevant here. Therefore, the verdict came in favour of the Respondent Manjulatha.

The court’s verdict in this matter was absolute and very justifiable because even though, appellants had no intention to cause any damage to the reputation of the  respondent, but because of their false publishing, she undergone through a great suffering because of the damage to her reputation.

When there is/ way no intention to  defame, but anyways if it causes damage to anybody’s reputation, then it becomes a civil offense and the  defendant needs to pay compensation to the plaintiff.

In case if it involves the malice i.e. bad intention/ intention to defame, then it falls under the criminal offence which is defined in Sec. 499 of Indian Penal Code and punishable under Sec. 500 of Indian Penal Code with simple imprisonment which may extend to two years or fine or both.

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