https://www.scconline.com/blog/post/2018/12/19/innocuous-reference-as-atankwadi-to-a-person-accused-in-several-criminal-cases-not-libelous-as-he-had-already-lost-social-prestige-and-reputation-patna-hc/
Innocuous reference as "Atankwadi" to a person accused in criminal cases not libelous as he had already lost social prestige and reputation: Patna HC