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10.5. The High Court of Bombay in an earlier judgment in the case of STATE OF MAHARASHTRA v. SARVODAYA INDUSTRIES5, discusses the difference between Section 19 and Section 20(c) of the CPC. The Court observes as follows:

"13. Provisions of Section 19 are specific in subject and clear in its operation. Firstly it governs a suit seeking restitutiye reliefs of compensation on the basis of wrong done to the person or to movable property. Secondly it offers and furnishes option or choice if the conditions indicated by the qualifying clause are satisfied in that wrong complained of was done within the local limit of one Court while the defendant in fact resides or carries on business within the local limits of jurisdiction of another Court. Unless both these conditions together are available, no question of option or choice for forum can conceivably, arise. The conjunction "and" in the qualifying clause is very much indicative of this result, leaving aside the cases where these conditions together are not available, the matters of such suit are still governed by other provisions of the Code. It is noticeable that in the body of Section 19 the phrase "the cause of action, wholly or in part" has not been used and it only finds place in Section 20 of the Code. In a suit for compensation "wrong done" or "complained of" is the cause of action by which Code understands and contemplates all the bundle of necessary facts capable on proof of sustaining the relief claimed. Compensation clearly posits an injury resulting in loss and damage. Mere injury or wrong without anything more would not suffice to sustain the claim for compensation. It is clear that the phrase "wrong done" is not used in any narrow 1974 SCC OnLine Bom 21 sense but has to be understood in all its amplitude so as to afford forum and necessary relief. That clearly takes in both cause and effect. Injury or actual wrong may occur at place A but its effect may be felt at places other than 'A' and may effect places 'B' or 'C' Act or actions taking place at a given place may still give rise to results affecting persons or property at places quite different and at all these places and for all those effects, cause would arise seeking compensation. Without resultant loss or its proof restitutive justice may not afford any relief nor there could be any remedy in vacuum. Thus the phraseology used by Section 19 about "the wrong done" would clearly take in not only the initial action complained of but its resultant effect.

14. Putting the matter in terms of Section 20(c) the resultant damage would surely be the part of cause of action and would feedback the answer for jurisdiction, Assuming, therefore, that both Sections are to be read together the same would indicate a overlapping which is not at all attributable to such legislative scheme. It is enough to answer that Section 19, which deals with cases of compensation for wrong done to the person or movable property, is wide enough to take in those places where plaintiff or person complaining actually suffered the loss because of the alleged wrongful act notwithstanding the place of such wrongful act clearly furnishing place of action. The phrase "wrong done" is indicative of completed action as stated (supra) and is wide enough to take in the results as the basis for the purposes of restitution. The Court within whose local jurisdiction damage was caused or suffered or sustained would clearly answer the requirements of Section 19 for the purpose of suits mentioned therein. The matters of option afforded are not relevant nor decisive for this purpose nor the provisions of Section 20(c). The extract of the provisions of Section 20(supra) by its opening part indicates that Section 19 is treated as limitation upon the generality of the provisions of Section 20 itself. Reading both sections together if a case is not squarely answered by the earlier sections then it may still be answered by Section 20 itself. Its terms are thus residuary. Turning to suits for compensation, if any narrow construction is to be placed on the phrase "wrong done" available in Section 19 then the matter still can be answered by Section 20(c) of the Code. For then Section 1.9 would indicate and only operate as "part of cause of action"

29. In an action for defamation, the wrongful act is damage to the plaintiff's reputation. The injuries that he sustains may be classified under two heads:

(i) the consequences of the attitude adopted to him by other persons as a result of the diminution of the esteem in which they hold him because of the defamatory statement, and

(ii) the grief or annoyance caused by the defamatory statement to the plaintiff himself.

30. It is of the essence of defamation that the words tend to be injurious to a person's character or reputation. The standard to be applied in determining whether a statement is defamatory or not is that of a right minded citizen, a man of fair average intelligence. The standard to be applied is not that of a special class of persons whose values are not shared or approved by fair-mended members of the society generally. An imputation is defamatory, if it exposes one to disgrace and humiliation, ridicule or contempt.