ASAD LAW ASSOCIATES

LEGAL ADVISORS
CORPORATE AFFAIRS CONSULTANTS
ADVOCATES SUPREME COURT OF PAKISTAN

ISLAMABAD

M.A., LL.B., LL.M. (London)

H.No. 96, St. No. 40, I/8-2

Islamabad.

Dr. M. AKMAL SALEEMI

Ph: 051-2261844
Cell No: 0334-9551640, 0300-9551640

M. TARIQ ASAD

LL.B.,J.D. Laselle University USA

LAHORE

YOUSAF AMANAT
LL.B., LL.M. (Cardiff)

5-Mazang Road, Lahore

ABDULLAH TAHIR

Ph: 0423 -7352129, 0423-7233845

E-Mail:asadlawassociates@gmail.com

LL.B. Hon. (London)

Mr. Salman Iqbal,

Dated: 09-12-2015

Chief Executive, ARY TV Channel,

6 th Floor, Madina City Mall,
Abdullah Haroon Road, Saddar Karachi
Subject: Legal Notice under Section 8 of Defamation Ordinance, 2002.
Dear Sir,
I have been instructed by my client, namely Maulana Abdul Azeez
s/o Late Maulana Abdullah, Lal Masjid, Sector G/6, Islamabad as
under:
1. That my client is a religious scholar and is rendering his religious
services as Khateeb of Lal Masjid since the year 1998. Before that
his father, namely Maulana Abdullah, a renown religious scholar had
served as Khateeb, Lal Masjid for a period of 30 years from 1968 to
1998.
2. That it had been alleged by the US Government that a woman,
namely

Tashfeen

Malik

and

her

American

husband, Rizwan

Farook had rushed into a year-end party on December 2, 2015 in

San Bernardino, California and opened fire at Rizwan Farooks co-

2
workers that consequently killed at least 14 persons and injured 21.
However, they were shot dead later by police after an encounter.
3. That on December 4, 2015, your TV channel, ARY News created
hype in a live programme at 11-15 p.m. for one and a half hour in a
clandestine manner that the aforesaid alleged invaders /terrorists
had connections with Lal Masjid and photographs of Ms. Tashfeen
with maulana Abdul Azeez had been recovered from her house. The
programme started at about 11.15 p.m. and lasted till 12.45 a.m.
which was repeated twice by your channel. The programme was
anchored by a senior journalist, namely Mr. Kashif Abbasi and ARY
News senior Anchor/correspondent, Mr. Amir Ghauri from London
had joined him. After about 45 minutes Mr. Sabir Shakir, the Bureau
Chief of ARY TV Channel, Arshad Shareef, Mr. Amir Nadeem an
Analyst and Waseem Badami also joined in discussion. During the
whole programme, the above mentioned allegations were exploited
continuously against my client with the mala fide intention to
instigate the people of Pakistan, Armed Forces as well as the
Government of Pakistan against Lal Masjid and my client. All except
Mr. Amir Nadeem repeatedly alleged my client that the US
Government had found pictures of Maulana Abdul Azeez with MS.
Tashfeen and that she had connections with Lal Masjid of Pakistan.
Mr. Amir Nadeem, a positive thinker and true journalist, however,
pointed out that he had not seen any such news on International
media.
4. That

the

contents

of

your

programme

were

reported

and

broadcasted by several other TV channels and print media also. The

International Press reported in these words:
Investigation into shooting have lead to shocking revelation that
the female suspected shooter identified as Tashfeen Malik was in

3
contact with Islamabad Lal Masjid. Sources quoted a senior US
official as saying. ARY News senior correspondent Amir Ghauri
Friday quoted his sources as saying that a senior US official today
called on Prime Minister Nawaz Shareef in London and conveyed
him a message from US President Barrack Obama. The official
apprised Prime Minister Nawaz Shareef of Tashfeen Maliks contacts
in Pakistan, sources said. Tashfeen was in contact with Islamabads
Lal Masjid, US official told according to sources. Investigation
officials have found pictures in which she can be seen with Lal
Masjid cleric.
5. That following the said programme some TV channels also
telecasted the same false news item, but the reputed leading
channels like Geo News did not follow ARYs news item without
confirming its truth for which Geo and such others deserve tribute
according to the principles and bye-laws of journalism.
6. That the aforesaid programme has sternly instigated the people
against my client demanding once again to launch operation on Lal
Masjid.
7. That the contents of false allegations served the ulterior motive of
US to defame the Muslim Umma generally and Pakistan specifically.
Thus by the said programme, not only my client has been
humiliated and defamed, but also the Muslim Ummah as a whole
has been disgraced in the world on International level, particularly
at the time when United States, UK, Soviet Union, Europe and other
non Muslim countries have united to create miseries for the Muslims
of Islamic Countries alleging frivolously that the Muslims are
terrorists. In US the lives of Muslims have been made miserable.
Donald John Trump, the candidate for President of the United States

4
election of 2016 has demanded that the entry of Muslims in United
States be banned.
8. That it is also believed that Daesh/ISIS is the product of US and
Jews, which is being misused by them prejudicial to the security
and integrity of the Muslim Ummah as they are not taking severe
action against them, but are sponsoring them secretly. But on the
hand Muslims are being alleged for the terrorist activities of ISIS.
9. That my client, in an interview with media on 4th December, 2015
categorically affirmed on oath that he had no links with the female
shooter

involved

in

San

Bernardino,

California

incident

and

identified as Tashfeen Malik. He also condemned the deadly attack.

He sympathized over the massacre at the social services center in
California and remarked in the following words:
Islam does not permit attacks on innocent people and I also
condemned the Paris attacks but was still being presented as a
terrorist or a terrorist-sympathizer in the media. I swear, I do not
know Tashfeen Malik and have never been photographed with her. I
have never even been photographed with my wife and daughters.
How can you imagine I may have been photographed with a namahram.
10.

That my clients wife, namely Ms. Umme Hassan, the principal of

Jamia Hafsa, also stated that Maulana Abdul Azeez, my client gives
interview to female journalists very rarely and whenever he had to
give one, Umme Hasan or any of their daughters would sit in the
room with him. She added, I can say with complete assurance that
Tashfeen Malik had never taken any photograph with him.
11.

That on 5th December, 2015, the spokesman of Prime Minister

also denied receiving any information or pictures of my client with

Tashfeen Malik regarding the abovementioned matter and it was

5
categorically said that no proofs or any message from US President
Barrack Obama had been conveyed to the Prime Minister, Mr. Nawaz
Shareef in that regard. It was added that no US official had
apprised Prime Minister Nawaz Shareef of Tashfeen Maliks contacts
in Pakistan. The Prime Minister Secretariat further reported that all
the information on the Media regarding the abovementioned matter
was wrong. It is pertinent to point out that it was only ARY News
channel which broadcasted the false story for couple of hours and
created hype in the country and the whole world.
12.

That it is pertinent to mention here that in 2007, too,

the

electronic media had unanimously played a very partial and

negative role against Lal Masjid and Jamia Hafsa by brain-washing
the people against them and had conspired

by telecasting false

allegations against them demonstrating the messages of one-sided

unilateral version and, thus, indirectly joined hands with the
objectives of US Government to maneuver the brutal Armed Forces
Operation, namely Silence Operation on Lal Masjid wherein
hundreds students and teachers had been mercilessly killed and
were burnt by white phosphorus. Consequently suicidal attacks
caused instability in the country. Thereafter, too, since then
following the US policy, every now and then, the image of Lal Masjid
and my client, Maulana Abdul Azeez, is being falsely distorted. After
the tragic incident of attack on Army Public School, a movement
was started against the petitioner by the TV channels that he had
refused to condemn that attack whereas he had later, on several
occasions, in his interview clarified that he had not refused to
condemn, but had said that he not only condemns that incident, but
the others too, who have killed the innocent children, women and
old people in other attacks. But the media did not telecast his

6
subsequent version deliberately. The ulterior motive behind this
campaign is not the enmity against an individual, but to defame
and target indirectly the whole Muslim Ummah and to prove them
as terrorists on the one hand and to attack the mosques and
Madaris on the other
13.

That Interior Minister, Ch Nisar Ali Khan addressing press

conference has said the pictures of Tashfeen Malik had been

examined and were found fictitious. The intelligence report reveals
that in this scandal neighbour country has played the major role.
From the said statement of the Interior Minister it may be
understood that your ARY News channel has links with RAW as only
ARY had broken that news.
14.

That my client had started a peaceful movement in good faith in

the year 2007 to eliminate immoral and obscene programmes and

advertisement on electronic media and to enforce Sharia law which
was entirely in accordance with the tenets of Islam/injunctions of
Quran and Sunnah and to enforce the provisions of the Constitution
in its letter and spirit, but since it was against the interests and
plans of US against Muslim Ummah; hence on their demand and
pressure the Silence Operation was imposed by Pervez Musharraf
against Lal Masjid and Jamia Hafsa wherein hundreds innocent
children and teachers and other staff were brutally massacred and
burnt with white phosphorus as witnessed by General Gulzar Kiani.
15.

That your above mentioned programme has created such a

degree of hatred and contempt in the minds of the people at large

against my client that they are again demanding operation against
Lal Masjid and arrest of my client likely to cause another tragic
incident which is tantamount to stabilization of Pakistan.

7
16.

That my client is a peaceful and humble citizen and has never

done any act prejudicial to public order, security and integrity of

Pakistan, but your Ary News channel has always been telecasting
false and frivolous breaking news against my client and his family
members, e.g. You maneuvered to telecast a false story on your
channel that a madrassa, namely Abdullah Bin Ghazi situated in
Rujhan (Rajanpur) which is being controlled by Maulana Abdul
Azeez was raided by the police and arms and explosives were
recovered from the said madrassa. This false story aggravated the
situation and the mischievous protestors further created nuisance
against Maulana Abdul Azeez and Lal Masjid whereas the news
telecasted by your channel was entirely false and no explosives or
any arms and ammunition had been recovered from the Madrassa.
The undersigned had then also served you legal notice on January
1, 2015, but my client had then sparingly given up to file suit for
damages in the competent court of law. On March 3, 2015, Bureau
Chief, ARY News channel, Mr. Sabir Shakir in its National news
telecasted at 12 noon that Hafiz Ehtsham had claimed responsibility
of armed attack on the District Courts Islamabad on behalf of
Shohada Foundation. He had later tendered apology which was
accepted unconditionally.
17.

That my client is an eminent religious scholar/Alim-e-Deen and is

son of reputed Alim-e-Deen and pioneer Khateeb of Lal Masjid,

Maulana Abdullah. The false and frivolous programme mentioned
herein above broadcasted by your ARY News channel has injured
the reputation of my client, his father and the family and it has
lowered him in the estimation of others and it has reduced him to
hatred in the eyes of public at large. Whereas currently your ARY
News channel has crossed all limits alleging clandestinely as if Lal

8
Masjid is a source of

International terrorism and my client is a

terrorist or a terrorists facilitator.

18.

That you are thus liable for committing defamation within the

meaning of libel under Section 3 of the Defamation Ordinance,

2002.
You are, therefore, given this notice under Section 8 of the
Defamation Ordinance, 2002 to tender apology and hold a similar
programme on your ARY TV channel to assert the contrary of
allegation in similar manner and with the same prominence as the
defamatory statement made and pay compensatory damages of
Rs.100 million (Rs.100,000,000/-) within 14 days of the receipt of
this notice, otherwise my client shall have no option left open to
him except to file suit for compensatory damages in the competent
court of law.

M Tariq Asad
Advocate Supreme Court