It’s getting dirty out there in the land of Gulabo Sitabo. The film, up for release on Amazon Prime on June 12, has been accused of plagiarism.

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Not even a week left for its release on Amazon Prime, Amitabh Bachchan-Ayushmann Khurrana starrer Gulabo Sitabo finds itself in a spot of bother. A legal notice has been sent to its maker Shoojit Sircar and the film’s writer Juhi Chaturvedi by lawyer Rizwan Siddique on behalf of a certain Agarwal family, who claim that the film’s story/script was written by the head of their family, Rajeev Agarwal.

The letter reads as follows:

“Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com __________________________________________________________________________________

Page No.1:

By Email Date : 3rd June 2020 chaturvedi.juhi@gmail.com / risingsunfilms@gmail.com (1) Ms. Juhi Chaturvedi (Writer) C/o. Rising Sun Films Pvt. Ltd. 201, Concorde CHS, N.S Road No 10, ak Circle, JVPD Scheme, Juhu, Mumbai, Maharashtra – 400049 (2) Mr. Sujit Sircar (Director) C/o. Rising Sun Films Pvt. Ltd. 201, Concorde CHS, N.S Road No 10, Circle, JVPD Scheme, Juhu, Mumbai, Maharashtra – 400049 (3) Rising Sun Films Pvt. Ltd. (Producer) Through its Directors Mr. Arijit Dhruv Lahiri and Mr. Sujit Sircar 201, Concorde CHS, N.S Road No 10, Circle, JVPD Scheme, Juhu, Mumbai, Maharashtra – 400049 Also having address as 4, Ripon Street Kolkata West Bengal – 700016 Ref : Copy of the Notice dated 3rd June 2020 addressed to Screen Writers Association which has also been marked to all of you on the above email id’s as concerned parties. Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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“The contents of the said Notice are self explanatory and clearly demonstrates the acts of plagiarism (copyright infringement) as well as cheating and criminal breach of trust, which appears to have been blatantly indulged in by you the Addressee No. 1 – by illegally copying, reproducing and adapting the said original story of Mr. Rajeev Agarwal titled ‘16 Mohandas Lane’ which was submitted to “Cinestaan India’s Storyteller Script Contest” of which you the Addressee No. 1 are one of the Jury Members – and then illegally using the copied (pirated) story in the film “Gulabo Sitabo” for personal monetary gains and to cause intentional losses to my clients – and thereafter malafidely and mischievously claiming that the story had been written by you the Addressee No. 1 and Addressee No. 2, without substantiating any of your claims in any manner whatsoever. The said film has been directed by you the Addressee No. 2 and is produced by you the Addressee No. 3, herein represented by its Directors Mr. Arijit Dhruv Lahiri and Mr. Sujit Sircar Madam / Sirs, This has reference to the matter as mentioned above in which regard I under instructions from my clients (1) Mrs. Rita Rajeev Agarwal (2) Mr. Akira Rajeev Agarwal and (3) Mr. Toshiro Rajeev Agarwal would like to address all of you as under : Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

ALSO READ: https://vickeylalwani.com/2020/05/15/gulabo-sitabo-amazon-theatre-controversy/

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1. That Mr. Rajeev Agarwal a professional story/script writer and the original author of the story titled ‘16 Mohandas Lane’ died intestate in Mumbai on the 10th of March 2019. He has left behind his legal heirs being his wife (1) Mrs. Rita Rajeev Agarwal and his sons being (2) Mr. Akira Rajeev Agarwal and (3) Mr. Toshiro Rajeev Agarwal, whom I represent as their Advocate. 2. That late Mr. Rajeev Agarwal had participated in “Cinestaan India’s Storyteller Script Contest” and had duly submitted his said story and script of ‘16 Mohandas Lane’. It is a matter of record that his story and script were shortlisted. For the sake of brevity and to avoid repetition of arguments I am briefly reproducing the said emails which speak for itself. Email received by Mr. Rajeev Agarwal on the 19th of June 2018 from Cinestaan, the opening paragraph of which read as under : From: Script Contest To: Rajeev Agarwal Cc:Bcc:Date: Tue, 19 Jun 2018 10:05:31 +0530 Subject: Re: Help neededDear Rajeev Agarwal, Wonderful news! 24 May 2020 at 16:08 Your story 16, Mohandas Lane, has been shortlisted for Round 2, i.e. the Bronze Round of the 2017 ‘Cinestaan India’s Storytellers’ Script Contest. After stringent evaluation, it has made it to this level from among thousands of stories.So, Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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Congratulations! Your Application Number is: CSC5108. Please remember this number.………. 3. That thereafter Mr. Rajeev Agarwal received “another email” on the 7th of September 2018, the relevant contents of which have been reproduced hereunder; and are self-explanatory. From: Cinestaan Team Sent: Fri, 07 Sep 2018 17:01:42 To: raajiv_agarwal@rediffmail.com Subject: Cinestaan India’s Storytellers Contest- Congratulations!! You are shortlisted.. Dear Rajeev B Agarwal, We are really excited to inform you that you are one of the shortlisted writers thereby moving into the Silver Round of the 2017 ‘Cinestaan India’s Storytellers’ Script Contest! This means that your script titled 16, Mohandas Lane, is truly one of the best to have made it to this level after evaluation. Please take yourself out for a treat. You deserve it! So, what happens now? Our respected Jury-Chairperson along with his team shall be reading these screenplays to whittle down 5 for the Gold category. As one of Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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Those shortlisted into our Silver Round, you have a chance at winning one of the following prizes for your script should you make it to the Gold Round: Grand Prize: 25 lacs INR First Runner Up: 10 lacs INR Second Runner Up: 7 lacs INR Third Runner Up: 4 lacs INR Fourth Runner Up: 3 lacs INR As a Silver Round candidate, you also have the option of entering our Video Pitch Contest on Cinestaan.com …… 4. That as per the terms and conditions posted on the website of Cinestaan having address as https://scriptcontest.cinestaan.com/terms.php, it has been categorically and clearly declared in paragraph 1 of Introduction that all shortlisted scripts would be judged by the “Jury Members” which includes Addressee No.1 as a Writer. The said paragraph reads as under (do specifically read the highlighted portions) The Script Contest shall ONLY be conducted online through the website Cinestaan.com (“Website”). If You are interested in participating in the Script Contest and fulfill the eligibility criteria set out in Paragraph 2 below, please fill up all the information in the application form (“Application Form”). The Participant (i) will be required to make a submission in the form of a Film Synopsis in Round 1 of the Contest, (ii) if shortlisted, will have to submit Script/ Screenplay in Round 2, as Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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As per the requirements and guidelines for the Contest (“Submission/s”). At the time of making the application and Submission for the first round, you will be asked for Participant or team biography (250 words) along with the Synopsis of the story Submission (Max 2500 words) words (collectively “Entry”). The initial rounds of the Contest will be judged by a panel of readers appointed by the Company at its discretion (“Readers”) and the short-listed Scripts, as set out in these Terms and Conditions will be judged by the senior members of the fraternity (“Jury Members”). Company reserves the right to determine and change the composition of the Jury Members/ Readers, from time to time. Readers/ Jury Members for the Contest or any round within a Contest, if any, may differ at Company’s discretion. Thereafter paragraph 1.1.1 (part 3) of the Terms and Conditions reads as under : Winners: The panel of Jury Members nominated by the Company will read/judge the Story/Script of the top selected Participants “who qualify from second round”. Based on their reading, thereafter the Jury Members will select the 5 (five) winners from the pool of top Participants (individually a “Winner”, and collectively “Winners”). The winners will be awarded a cash prize (which shall be inclusive of taxes) as follows … 5. In the premises aforestated, no one can ever contend and/or challenge the fact that Mr. Rajeev Agarwal had not qualified from the second round. It also has Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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cannot be denied that as per the terms and conditions posted on the website “it was publicly declared and confirmed” that the Panel of Jury Members will read/Judge the story/script of top selected participants who qualify from the second round. 6. Therefore it is prima facie apparent that you the Addressee No. 1 had full access to the story and script of the film from second round onwards, and therefore under no circumstances can the “glaring and stark similarities” between the story of Mr. Rajeev Agarwal titled ‘16 Mohandas Lane’ and the story of Ms. Juhi Chaturvedi for the film “Gulabo Sitabo” be coincidental. 7. I would like to further categorically place on record that the script/story written by Late Mr. Rajeev Agarwal titled as “16 Mohandas Lane”, is also “absolutely unique and original and can never be conceived by anyone, with such similarities”; that not only both the stories appear to be similar but also the manner, form and expression of ideas are similar. That every person known to my clients, who has seen the trailer of the film “Gulabo Sitabo” and read the script of “16 Mohandas Lane” could say with confidence that there is blatant infringement of copyright and the said film “Gulabo Sitabo” is a “literal imitation of the copyrighted work of my client with some very minute variations”. 8. I am reproducing herein below a comparative chart of the glaring similarities between the original story which was solely authored by Late Mr. Rajeev Agarwal titled “16 Mohandas Lane” and the story of film “Gulabo Sitabo” as portrayed through it Trailer, which has been claimed to be jointly written by you the Addressee No. 1 and 2. Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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The Central Characters of my client’s story “16 Mohandas Lane” are 1. An owner of an old dilapidated Haveli. (Character named Mr. Manoj) 2. His poor tenants who are unable to pay him rent (Character named Ms. Neha and her Dadaji) 3. Officer of Archeological Survey of India (Character named Mr. Lele) 4. Dadaji who keeps giving wrong advice to Manoj and gets him entangled in legal issues and takes the story forward. The Central Characters of “Gulabo Sitabo” film are all playing similar parts 1. An owner of an old dilapidated Haveli – (role played by Mr. Amitabh Bachan) 2. His poor tenant who is unable to bear the rent (role played by Mr. Anshuman Khurana) 3. Officer of Archeological Survey of India – (role played by Mr. Vijay Raaz) 4. Mr. Brijesh Kala keeps giving wrong advice to Mr. Amitabh Bachan and takes the story forward. Setting of the Story of “16 Mohandas Lane” The Story is set in a rural area in the North of India near Delhi called “Rampura”. Setting of the Story of “Gulabo Sitabo” The Story is similarly set in a rural area in the North of India and portions of Delhi and Jama Masjid are captured Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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Plot of the Story of “16 Mohandas Lane” The brief set-up of the story is that Manoj is unable to maintain a large Haveli, which is in a rural area near Delhi. He does not want to let-go of his Haveli despite the fact that he does not have sufficient income to maintain it and nor does he earn enough rent from tenants. Manoj desperately needs money therefore he manipulates and fabricates papers to sell his old and dilapidated Haveli at a very high price to the Archeological (Survey) Department of India “at the instance and on a wrong advice of a character named Dadaji”. Plot of the Story of “Gulabo Sitabo” The brief set-up of the story as seen from the trailer is that Mr. Amitabh Bachan (an old man) is unable to maintain his Haveli, which is inrural area of North India close to Delhi. Even his Tenant Mr. Anshuman Khurana troubles him for rent/money. Mr. Amitabh Bachan, in the film Gulabo Sitabo apparently also deals with his old and dilapidated Haveli with the Archeological (Survey) Department of India and it appears that his problems also increase because of wrong advice. Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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Conflict created in the story to add a sub-plot and make it more interesting After introduction of Archeological (Survey) Department of India and its officer Mr. Lele, “not only the Haveli of Manoj gets stuck with the Archeological Department but even he personally gets caught up, in his own web of lies.” Manoj is desperate to look for solutions however he gets caught deeper and deeper into more and more legal problems. Eventually the Haveli, which is very dear to Manoj, get legally disputed because of all the self-created problems. Dadaji continues to give wrong advice to Manoj all throughout, thereby landing Manoj into more and more problems, thus adding many layers to the story to make it interesting. This allows all other characters to pull the story forward. Same conflict is created in the story to add a sub-plot and make it more interesting After the introduction of Archeological (Survey) Department of India and its officer Mr. Vijay Raaz, “not only does Mr. Bachan’s Haveli gets stuck with the Archeological Department but even he gets caught up in his own web of lies” Mr. Amitabh Bachan is looking for solutions but gets caught deeper and deeper into more and more legal problems. Eventually the Haveli, which is very dear to Mr. Amitabh Bachan, is legally disputed because of self-created problems. An Advocate played by Mr. Brijesh Kala who is adviser of Mr. Bachan continues to wrongly him and increases his problems thus adding many layers to the story. Other characters take the story forward. Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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9. My clients categorically state that as the trailer of the film “Gulabo Sitabo” showed blatant infringement of the copyrighted work of Late Mr. Rajeev Agarwal and also because access to the said copyrighted work by you the Addressee No. 1 was prima facie established, my clients therefore brought the matter before the Screenwriters Association, hoping for a solution. 10. However it appears that you the Addressee No. 1 did not submit your story and script for authentication and verification, but instead chose to use all sought of diversionary tactics. Given this fact and also the fact that you the Addressee No. 1 and the Addressee No. 2, had even earlier indulged in a similar act of plagiarism by allegedly stealing and copying the story of a Marathi Cinematograph film titled “Aarti – The Unknown Love Story” and used the said pirated story, for making the Hindi Cinematograph film titled “October”. It was therefore obvious that this was not the first time that you have been accused of plagiarism and apparently you the Addressee No. 1 “out of obvious guilt” does not wish to co-operate and justify your claims of being the original author of the story used in the film “Gulabo Sitabo” 11. Under the said circumstances the said matter has been placed in my hands and Final Resolution to the Story Towards the end of the story Manoj finds gold in his backyard and all his financial problems are solved. Final Resolution to the Story Towards the end of the story Mr. Amitabh Bachan finds money in his backyard and his financial problems appear to be been solved. Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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Accordingly, I categorically and specifically call upon you the Addressee No. 1 as under : a. That your acts of willful commissions and omissions clearly suggest that as a “Writer yourself” you have misused your position as a Jury Member of “Cinestaan India’s Storyteller Script Contest” and have blatantly stolen the story of the Late Mr. Rajeev Agarwal for personal benefits and monetary gains and to intentionally cause losses to the said Late Mr. Rajeev Agarwal. b. That you have also been fully aware of the fact that the said story submitted by Late Mr. Rajeev Agarwal is not only his intellectual property but also his valuable security; and that no one else can malafidely and mischievously claim the same under any circumstances whatsoever. However, despite full knowledge of these obvious fact, yet you boldly sought to misuse your position and blatantly indulge in the criminal acts of “breach of trust” and “Cheating”, both of which are a punishable offence under Indian Penal Code. Do categorically note that the acts committed by you attract the provisions of Sections 405, 406 and 418 of the Indian Penal Code, which have been reproduced herein below for your ready reference Section 405. Criminal breach of trust Whoever, being in any manner entrusted with property, or with any dominion over property, dishonestly misappropriates or converts to his own use that property, or dishonestly uses or disposes of that property in violation of any direction of law prescribing the mode in which such trust Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ___________________________________________________________________________________

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is to be discharged, or of any legal contract, express or implied, which he has made touching the discharge of such trust, or willfully suffers any other person so to do, commits “criminal breach of trust”. Section 406. Punishment for criminal breach of trust Whoever commits criminal breach of trust shall be punished with imprisonment of either description for a term, which may extend to three years, or with fine, or with both. Section 418. Cheating with knowledge that wrongful loss may ensue to person whose interest offender is bound to protect Whoever cheats with the knowledge that he is likely thereby to cause wrongful loss to a person whose interest in the transaction to which the cheating relates, he was bound, either by law, or by a legal contract, to protect, shall be punished with imprisonment of either description for a term which may extend to three years, or with fine, or with both c. That besides the above provisions of the Indian Penal Code infringement of Copyright is also a punishable offence under the “Copyright Act 1957” and Section 63 of the said Act reads as under 63. Offence of infringement of copyright or other rights conferred by this Act.— Any person who knowingly infringes or abets the infringement of— (a) the copyright in a work, or (b) any other right conferred by this Act Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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shall be punishable with imprisonment for a term which shall not be less than six months but which may extend to three years and with fine which shall not be less than fifty thousand rupees but which may extend to two lakh rupees d. That in the said premises I therefore, for and on behalf of my clients and under their instructions call upon you for the last and final time to immediately justify all your claims within 24 hours from the time of receipt of this Notice by you, – by duly proving your said claims and formally submitting the story of “Gulaabo Sitaabo” to my clients through me “for comparison and authentication” of your claims. 12. Do specifically note that in any event if you the Addressee No. 1 fails and neglects to duly participate and prove the genuineness of your claims within 24 hours, then it shall be deemed that you are guilty of the crimes as mentioned herein above and under these circumstances it shall further be rightly assumed that you have been intentionally refusing to submit your story since the 25th of May 2020 only to conceal your crimes. 13. The other Addressees being Addressee No. 2 and 3 ought to take specific note of the fact that I have brought to your full knowledge the apparent acts of plagiarism and copyright infringement by Addressee No. 1 (unless she sufficiently proves otherwise before 5th of June 2020 12:00 noon). Therefore in the event if you continue to use the infringed work, then I shall have no options but to initiate appropriate civil and criminal actions against each of you entirely at your risks, costs and consequences, which do take specific note of. Siddiquee and Associates Advocates Office : 214/215 2nd Floor, Woodrow Commercial Premises, Veera Desai Road Opp. Veera Desai Police Station, Andheri , Mumbai – 400 043 Tel No :26398484 / 26300189 /26321013 Email Copy addressed to 1) chaturvedi.juhi@gmail.com (2) risingsunfilms@gmail.com ____________________________________________________________________________________

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14. HOPING THAT ALL OF YOU FULLY UNDERSTAND THE SERIOUSNESS OF THE MATTER AND TREAT THIS NOTICE AS MOST URGENT, BY DULY ACTING ON THE SAME WITHOUT ANY DEMUR, DELAY OR FURTHER EXCUSES. SD/- Advocate Rizwan Siddiquee.  

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