Madras High Court held that,

It is clear from what I have stated that the decision is hardly applicable to the facts of the present case. The decision refers to a publication in a paper and it should be proved that the accused was responsible for the publication. But in this case, the defamatory matter contained in the plaint was  admittedly signed and filed by the petitioner. There can be no doubt that there was publication of the defamatory matter.

Citations: [AIR 1966 Mad 363], [1966 CriLJ 1149], [1966 MLJ 1 547], [1965 SCC ONLINE MAD 248], [1966 MAD LJ 1 547],

Indiankanoon.org or Casemine link: https://indiankanoon.org/doc/1735036/

The Index for Defamation Judgments is here.

Reproduced in accordance with Section 52(q) of the Copyright Act 1957 (India) from main.sci.gov.in/judgments, judis.nic.in, lobis.nic.in, indiacode.nic.in and other Indian High Court and District Court Websites such as ecourts.gov.in