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ii) that Plaintiffs 1 and 2 were accordingly criminals and murderers;
iii) that Plaintiff No.1 should accordingly be shut down and
iv) that Plaintiff No.2 should be arrested and jailed for murder.

24 Mr. Chinoy has submitted that the transcripts/English translations of the videos uploaded and the tweets posted have been annexed in full at Exhibits E to K to the Plaint and the aforementioned defamatory and malicious statements made in each of the said videos and tweets have been separately highlighted and extracted in the Plaint and the Interim Application. Mr. Chinoy has submitted that these defamatory statements have been made inspite of the aforementioned affidavit of the Ministry of Health and Family Welfare of the Union of India in Rachana Gangu (supra) having referred to a noted scientific paper in the journal Lancet which estimated that the access to/ use of Covid-19 vaccines is estimated to have prevented at least 4 million deaths in India. Further, reference is made to the case of Jacob Puliyel wherein the Supreme Court IAL.33254.22 in SL.33253.22 wt..doc has referred to the "National AEFI Surveillance Secretariat" and setting up of a 'well defined mechanism for collection of data relating to adverse events that occur due to Covid vaccines', and had rejected the submission/allegation 'that the surveillance system of AEFI's in this Country is faulty and the correct figures of those who have suffered any side effects, severe reactions or deaths post inoculation have not been disclosed'.

IAL.33254.22 in SL.33253.22 wt..doc A total of 92,114 AEFI cases (0.0042%) have been reported, of which 89,332 (0.041%) were minor AEFI cases and a total of 2782 cases were serious and severe AEFI's (0.00013%). The figures were stated to be prior to causation analysis and any such severe AEFI's including death cannot be attributed to vaccination till the same is casually assessed by the National AEFI Committee.

57 In the case of case of Jacob Puliyel (supra) the Supreme Court had referred to the "National AEFI Surveillance Secretariat" and had considered it to be a 'well defined mechanism for collection of data relating to adverse events that occur due to Covid vaccines'. The Supreme court rejected the submission 'that the surveillance system of AEFI's in this Country is faulty and the correct figures of those who have suffered any side effects, severe reactions or deaths post inoculation have not been disclosed'. Thus, one can rely upon the figures given by the national AEFI surveillance system and which has been relied upon by Dr. Veena Dhawan in her Affidavit.