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The plea of the plaintiff in the plaint/IAs

4. The plaintiff claimed that he also watched the episode of the said show featuring the 1st defendant, was interested in the inspiring ::4:: MSR,J & TA,J cma_355_2020 &batch life story of the 1st defendant, and approached the 1st defendant and entered into a Life Story Rights agreement dt.19.11.2017 ( Ex.P1) for assignment of 1st defendant's true life story events in favor of the plaintiff so as to enable the plaintiff to direct/make a feature film in any language in the world as against which the plaintiff had agreed to pay Rs.12 lakhs; later another Life Story Rights agreement dt.19.3.2018 ( Ex.P3) was entered into by plaintiff with the 1st defendant to enable the plaintiff to make a biopic/feature film based on the true life story of 1st defendant. The 1st defendant also executed Ex.P.4 - 'No Objection Certificate' and a declaration letter dt.19.03.2018 in favour of the plaintiff stating and confirming that the plaintiff had bought / acquired exclusive True Life story events of the 1st defendant to make a biopic / feature film and that the plaintiff is the only authorized person to make a screenplay / story of true life story events of the 1st defendant. Under Ex.P.5 - Acknowledgment, part consideration of Rs.5.5 lakhs was also paid by the plaintiff to the 1st defendant for the transfer of the true life story of the 1st defendant to the plaintiff. According to the plaintiff, he intended to make a feature film on the real life story of the 1st defendant.

5. The plaintiff claimed that he improvised the story line and modified the sequence of true life story events of the 1st defendant by adding more characters / plots and got registered a film script / screen story with the title 'Slum Soccer' with the Telangana Cinema Writers' Association (Ex.P.7) on 11.07.2018.

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6. The plaintiff claimed that in April, 2018, it was widely published in the Print and Electronic Media that a Hindi film 'Jhund' starring the defendant no.12, a renowned movie actor, and produced by defendant nos.4 to 11 and directed by defendant no.3 was in production / shooting stage. He alleged that in the said film, defendant no.12 would play the role of the 2nd defendant who was football Coach / Mentor of the 1st defendant, and that the said film would be based on the core concept of 'Slum Soccer' and real life incidents of the 2nd defendant.

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9. The plaintiff contended that he learned from Print and Electronic Media that the film 'Jhund' is based allegedly on the real life incidents of the 2nd defendant and it also shows / depicts his real life pupils / students including the 1st defendant as various characters in the film. The plaintiff claimed that he apprehends that in the guise of making the film 'Jhund', defendant nos.1 to 12 would infringe upon his copyright over the real life incidents of 1st defendant by making use of the name of the 1st defendant, his image, likeness, life story and / or identity in relation to the said film. He filed Ex.P.16

53. Defendants 5 and 7 filed CMA No. 356 of 2020 challenging the order dt.17.9.2020 in IA No.829 of 2020 and CMA No. 355 of 2020 challenging the order dt.17.9.2020 in IA No.830 of 2020; the defendant 3 filed CMA No. 358 of 2020 challenging the order dt.17.9.2020 in IA No.830 of 2020 and CMA No.357 of 2020 challenging the order dt.17.9.2020 in IA No.829 of 2020.

54. Sri Venkatesh Dhond and Sri S.Niranjan Reddy, Senior Counsel made submissions on behalf of the defendants 3,5 and 7 ::20:: MSR,J & TA,J cma_355_2020 &batch / appellants and Sri Sunil B.Ganu made submissions on behalf of the plaintiff/1st respondent in the appeals.