Sikhs for Justice v. Bachchan - actor sued for rule in 1984 anti-Sikh riots in India.pdf

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    c

    Q

    Babak Pourtavoosi, Esquire,

    SBN

    216287

    Law Offices o f Babak Pourtavoosi PC

    Of counsel to Pannun The Firm, PC

    75-20 Astoria Boulevard, Suite

    170

    Jackson Heights,

    NY

    11370

    (718) 672-8000; Fax: (718) 732-4514

    [email protected]

    Attorney for Plaintiffs

    Q

    ORI IN L

    UNITED S TATE S

    CENTRAL DISTR IC

    D ISTRICT COURT

    OF

    CAL IFORN IA

    o

    o-t-H

    m x j

    -r l jO

    o

    CD

    CO

    r

    m

    o

    SIKHS FOR JUSTICE, INC.

    SFJ

    On behalf

    of

    deceased and injured

    Member

    of

    Sikhs community;

    BABU

    SINGH DUKHIYA,

    on

    his

    own

    behalfandonbehalfof deceased and injured'

    Family members; and

    MOHINDER

    SINGH, on his

    own behalf

    And

    on behalf o f deceased

    and

    Injured family members

    Plaintiffs,

    CVU-08297M&

    C iv No

    AMITABH BACHCHAN,

    a na tiona l and c it iz en o f

    India

    De f endan t .

    Complaint

    SFJ,

    et

    al. v.

    Amitabh

    Bachchan

    - 1

    COMPLAINT

    A

    CIVIL

    ACTION

    CLASS ACTION

    JURY TR IAL DEMANDED

    F \ i J

    OCT l T

    ?n A

    Cle- '. S D;sirictCout

    COURT

    4612

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    o

    O

    1. Plaintiffs, on behalf of

    themselves,

    tieir deceased family

    members

    and all

    others similarly situated who were victims of or related to the victims of

    Sikh

    Genocide

    of

    November 1984'

    hereinafter referred to

    as

    The Sikh

    Genocideof 1984 which is popular

    Sikh

    Riots

    of 1984 (collectively Plaintiffs ), as

    and for their

    complaint

    against

    the Defendant

    in

    this

    action respectfully allege

    as follows

    I. PRELIMINARY STATEMENT

    2. In the year

    2013,

    theDefendant possessed a major role in a

    famous

    y and purposely misnomered as Anti

    Americanmovie The Great Gatsby'

    Hollywood film industry located witjiin

    made, sponsored and released by the

    in the territorial jurisdiction of this

    court.

    The

    movie which

    won 2 Oscar awards was

    co-starred by

    Leonardo

    DiCaprio and was produced by Warner Bros.

    3. On October 31, 1984 after Indira Gandhi the then Prime Minister

    of

    India

    and head of ruling Congress party was declared dead at All India Institute of

    Medical

    Sciences

    (AIIMS),

    the

    Defendant

    Amitabh Bachchan, raised the

    slogans

    Sikho

    ne Indira Ji ko mar dal

    la ( Sikhs have killedIndira );

    ko ( Kill these bastards , they are

    traitors ); 'khoon ke cheentay Sikhoi|i ke ghar ghar

    tak

    puhnchanay

    'Maro Saalon ko, desh ke ghaddaron

    chahiyay' ( the blood stains should

    reach

    the households

    of

    Sikhs ) and

    Complaint

    SFJ, et al. v. Amitabh Bachchan

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    Q

    o

    khoon ka badla khoon ( blood for

    blood ). Hearing defendantBachchan's

    call for violence against Sikhs, otherwise shocked and numb crowd

    immediately reacted violently towards Sikhs present in the

    crowd

    and started

    beating them.

    4. Blood

    for

    blood slogan raised byEachchan turned into Ebola Virus asit

    was instantly pickedby the

    crowd

    andIndia's state

    owned

    TV Station

    Door

    Darshan

    and All

    India Radio

    started telecasting

    slogans of Blood

    for

    Blood

    resulting

    in

    the

    killing

    of

    moi[e

    than 30,000

    Sikhs across

    the

    country

    during the next few days.

    5. Telecast of slogans by the state owned

    mediacalling for violence against

    forDemocratic Rights (PUDR) and

    ikhswas reported by People's Union

    People's Union

    for

    Civil Liberties (PUCL) in

    their

    report Who

    Are the

    Guilty stating that [w]e were also intri

    guedto

    find

    Doordarshan (the

    State-

    allowing the broadcast of highly

    khoon' (blood for blood). 1

    controlled Indian televisionnetwork)

    provocative slogans like 'khoon ka badla

    1

    Who

    Are The Guilty AReport ofa

    joint

    the riots in Delhi from 31 October to 10November

    finding team jointlyorganised [sic] by one

    (PUDR) and people's Union for Civil Liberties

    investigations from November 1to

    November

    the

    attacks

    on members

    of

    the

    Sikh

    period, far

    from

    being a spontaneous

    Complaint

    SFJ, et

    al. v.

    Amitabh

    Bachchan

    3

    inquiry into the causes and impact of

    1984

    PUCL

    -

    PUDR

    A

    fact-

    people's

    Union

    for Democratic

    Rights

    (PUCL) in the course of

    10,

    has come

    to the conclusion

    that

    Community

    in

    Delhi

    and its

    suburbs during the

    expression ofmadness

    and

    ofpopular

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    Q

    Q

    6. The slogans calling for blood of Sikhs coined and raised bydefendant

    Bachchan

    a day earlier outside

    AIIMS

    instantly

    became

    so popular

    that they

    were

    also

    raised bythe

    crowed

    at Teen

    Murti

    onNovember 1during Indira

    Gandhi 's burial .

    7. Defendant Amitabh Bachchanwas considered bymany in India to be an

    iconic legenddue to his movie star roles inBollywoodand alsoknown for

    his personal appearances on the government-owned All-India radio and

    television networks. He was generally liked and well known in such

    capacities during the 1980's.

    When

    he spoke, his words

    were

    like a plagued

    virus spreadingwildly without end aid the people listenedand moved at his

    beckon call. That notoriety and fame

    was u sed

    in

    what has

    become

    known

    as The Sikh Genocide

    of

    1984 foil :>wing the assassination

    of

    Prime

    Minister Indira Ghandi, a woman who Defendant revered as a mother

    figure and with whomhe had close :ies to her family, to excercise,

    facilitate, and proliferate the murders

    grief

    and anger at Mrs. Gandhi's assassination

    authorities, were the outcome

    of

    a well org

    deliberate commissions and omissions by

    at the top and by authorities in the administ

    http://www.pucl.org/Topics/Religion-comnliunalism/2003/who

    2

    See Who Are the Guilty

    at

    ibid.

    Complaint

    SFJ, et al. v. Amitabh Bachchan

    of

    count less thousands . S ince

    then

    to

    as made out to be by the

    inised [sic] plan marked by acts of both

    important politicians

    of

    the Congress (I)

    ation.

    are-guilty.htm.

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    o

    Q

    the

    Sikh

    community,

    Defendant

    Amitabh

    Bachchan

    became known

    as

    the

    butcher because his words had lee

    members of a primarily peaceful rel

    to the slaughter

    of

    over 30,000

    gion, Sikhism. Defendant's words and

    anti-Sikh propaganda

    were like venom being

    spit out

    ofacobra poisoning

    the minds and

    hearts

    of all they touched

    8. Reach, magnitude and consequences

    Sikhs

    was aptly reported

    by

    Hindustan

    showing 16 states

    of

    India where

    1984.

    PUBL I SHED

    BY :

    THE HINDUSTAN TIMES.

    NEW .

    ofBachchan's call for

    violence

    against

    Times

    in its

    November 1984 report

    Sikhs were

    targeted

    during November

    LHI

    NOV

    1,

    98

    SOURCE:

    LIBRARY

    OF CONGRESS NEWSPAPER RM

    Complaint

    SFJ,

    et al. v. Amitabh

    Bachchan

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    G

    o

    9. Perils caused byBachchan's call for

    violence against Sikhs continue to be

    unearthed even after more than two decades. Starting with the 2011

    discovery ofMass Grave of Sikhs in

    village Hondh-Chillar, District

    Rewari,

    states of India includingadditional

    aryana, the evidence located in sev jral

    nine (9)Gurudwara ruins in Delhi,

    Gurgaon, State

    of

    Haryana; ruins

    of

    Pradesh

    and

    Jammu & Kashmir

    trass

    cremation site in Pataudi and

    Sikh localities in

    West Bengal, Uttar

    the gravity, span, compass and

    spread nature

    of

    the attacks initiated

    exposes

    specially organized, identical and wide

    c

    iscovery coming twenty-six years after

    enocide of Sikhs thattook place

    of the coverup that

    began

    all

    those

    by the callgiven byBachchan. This

    the

    fact is evidence not only of the g