Mr.

Imran Khan,
Chairman,Pakistan Tehrik-e-Insaaf,

I. Zaman Park, Lahore.

II. Range Road, Bani Gala
Islamabad.

LEGAL NOTICE FOR DEFAMATION UNDER SECTION 8 OF

DEFAMATION ORDINANCE, 2002
Dear Sir,

This is statutory required notice which we address to you under the instructions

and on behalf of our Clients jointly and severally namely (1) Independent Media

Corporation (Pvt.) Limited (2) Independent Newspapers Corporation (Pvt.)

Limited (3) News Publications (Pvt.) Limited and Mr. Mir Shakil ur Rehman

Group Chief Executive and Editor-in-Chief Jang Group and Geo TV.

1. That together our Clients represent the largest Media House of the

country which commands great respect, credibility, recognition and

largest viewership in Pakistan as well as amongst Pakistanis living

abroad. Our clients have an established legacy and unimpeachable

credentials in the field of print media dating back to last more than

seven decades, in the field of digital/online media more than two

decades and in electronic media for more then fifteen years. They

have a long standing and hard-earned credibility and reputation for

being independent, impartial, objective, pragmatic and

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 uncompromising source of information, education and entertainment

for millions of people in Pakistan and across the globe. Because of

their acclaimed reputation and acknowledged stature, our Clients are

not only recognized as fore-runner and pioneer in the media industry

but also recipient of several awards. Mir Shakil ur Rehman, Group

Chief Executive & Editor-in-Chief, who is a highly respected and

renowned media personality has also held post of the President of the

Council of Pakistan Newspaper Editors and the President of All

Pakistan Newspapers Society for several years. He was also the

founder Chairman of the Pakistan Broadcasters Association. In July

2005, he was named by the leading American magazine Business

Week, as one of the Twenty-Five stars of Asia.

2. That in view of invaluable services rendered by our Clients in field of

journalism and their large scale philanthropic work that serves the

cause of humanity; they enjoy unblemished reputation and respect and

are held in high esteem across the society and more particularly

amongst the general public, fellow media houses, journalists and

among corporate entities of significance within Pakistan and abroad.

You may also recall that along with our Clients, you had also been an

active participant in social welfare activities in the past. The most

relevant case is your association with the Jang Group under the banner

of MKRF and PUKAAR for large scale rehabilitation measures for the

flood affected people of Pakistan. It may also be added that because of

his international social and corporate stature and services to the media,

Mr. Mir Shakil ur Rehman has a large number of business associates,

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 friends, colleagues and well-wishers in Pakistan and abroad especially

in the UK, Canada, USA, UAE and several other counties.

3. That from the beginning our Clients have made extraordinary efforts to

maintain impartiality, transparency and objectivity in discharge of their

professional work for dissemination of information among the readers and the

viewers. While according prime importance to the glory of Islam, the security

and defense of Pakistan and public order, our Clients have through print and

electronic media, always maintained neutrality in reporting about political

developments, politics and political leadership in the country. Needless to assert

that uncovering the truth in informing the public about developing events of

significance has been most distinguishing virtue of our Clients.

4. That it is essential to point out here, that it has been our Clients who have

first disclosed the details of PANAMA issue which provided an impetus and

impulse to the PTI to agitate and organize a large-scale campaign against

corruption of elite classes associated with off-shore corporate entities which

ultimately precipitated into unprecedented and scrupulous questioning and

accountability of a sitting Prime Minister in Pakistan. Obviously, the role, alacrity

and vitality of PTI in bringing this matter to present stage need no

acknowledgment.

5. It is necessary to point out that our Clients are doing a noble duty of

seeking and reporting the truth which in some cases is not only disliked by some

but also proves to be bitter for others attracting unwarranted disapproval for such

reporting. Our clients are experiencing such difficulties and hardships for the last

over Seven decades. In this regard, our Clients very well appreciate that being a

broadcaster and a publisher; it is a recognized norm that their activities in

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dissemination of information are subject to a certain degree of public scrutiny by

opinion-makers and political leaders. It is also well appreciated that others have

a right of expression even in stronger tune and terms relating to what is presented

and broadcast by our Clients for public good. Our Clients have always accepted

such criticism with full intellectual generosity.

6. That on the contrary, it is also emphasized that any such expression of

opinion, representations, comments or criticism about our Clients; must be fair,

unbiased, without bend of mind, free of malice and without being injurious-

falsehood emanating from self-righteous conjectures, unilateral beliefs and

preposterous conclusions unsupported by any proof. It is further emphasized that

any such criticism, expression and/or representation must not injure reputation of

our Clients, must not tend to lower them in the estimation of others and must not

tend to reduce them to ridicule, unjust criticism, dislike, contempt or hatred.

Truthfulness in dissemination of information by our Clients must be appreciated

even if it be unpleasant and be not in consonance with political objectives of a

person or a party or a political leader of your stature.

7. That our Clients appreciate, recognize and acknowledge that as a citizen as

well as a leader of a Political Party and as a national figure you have the right to

make comments and raise questions, queries and concerns about national affairs

and impacting role of our Clients. It is evident and traceable reality that despite

your undeserved, aggressive and hostile posture towards our Clients; our Clients

have regularly and fairly reported about your activities, statements and events in

which you had participated just as it has been done in respect of other national

personalities or matters of public importance. It is sad that without appreciating

the truth behind the news stories, analysis of current affairs and broadcast

presented by our Clients; you habitually jump to draw conclusions that our Clients

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have affinity to favor the present government, whenever such broadcast is not in

consonance with objectives of PTI or your own perception. It is evident from

some of your recent utterances reported in electronic and print media.

Furthermore, this assertion by our Client has a traceable history of past over Four

years.

8. That it is regretfully noted that from the year 2014 onwards, you have

been making statements and assertions of facts about our Clients jointly and/or

severally, which were not only completely false and misleading but were also

highly defamatory, disparaging and damaging and such expressions include

uncivilized words like ‘blackmailer’ and ‘Firoan’ etc which cannot be part of

public discourse and discussion in any civilized society. Your attention is

particularly invited to your assertions on different occasions from 2nd May 2014 to

17thJune 2014 and subsequently. Some of these include your press conference that

was held on 2nd May 2014 at Islamabad. You again repeated these defamatory and

false assertions on 4th May 2014 on a private TV Channel Program. On 5th May

2014 you again repeated your false and frivolous allegations on two TV Channels.

We are enclosing transcripts of specific statements (Annex A) made on electronic

media as well as clippings from newspapers made by you about our Clients which

were not only false but were highly defamatory and damaging. A summary which

is only illustrative and not exhaustive of the false assertions of facts and

allegations made by you in the past through statements on electronic and print

media as well as in public meetings on different occasions, is produced hereunder

just as a reference and record to connect your aggravated acts of wrongdoings

towards our Clients.

a. Our Clients manipulated the election results through media

framing. The crux of your statements is that our Clients have been

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 partial and inclined towards your rival political party by way of

broadcasting a victory speech of their leader to influence election

results whereas electoral process had been completed 5 to six hours

before the time of speech (11:23 PM on 11th May 2012).

b. You falsely blamed that our Clients were corruptly allowed

to acquire the broadcast rights for the cricket series between

Pakistan and Sri Lanka.

c. You asserted that our Clients are being funded by foreign

country to follow their narrative. You have attempted to create

doubts about patriotism and loyalty of our Client towards his

county.

d. You leveled extremely serious allegations against our

Clients that our Clients have nexus with Indian and US

Governments to foster war on western borders and promote agenda

and purposes of these foreign countries.

e. You labeled and called our Client as blackmailer and

Firoun and made false accusation that he had been trying to

intimidate you.

9. The above are some of the illustrations of the false and malicious

allegations made by you as a leader of a political party during the year 2014.

These are by no means exhaustive. However, our Clients acted with perseverance

and decided not to initiate legal action for defamation against you, despite highly

objectionable and provocative allegation and showed utmost patience,

perseverance and restraint. Such course was adopted by our Clients believing that

someday wisdom would prevail amongst the leadership of PTI and the Party

would stop its policy of regression and intolerance toward difference of opinion

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and dissent. Unfortunately, this most valuable democratic virtue is being ignored

in pursuit of foisting self-righteousness and suppressing the dissent that is not in

consonance with your objectives or those of PTI as a Party.

10. That it is evident that for the past over Four years, you have launched an

intermittent malicious personal campaign against our Clients and you are making

continual wild and preposterous allegations ranging from accusation of rigging

the election results of 2013 general elections to securing award of televising

cricket rights contract in a corrupt manner as a reward for rigging election results

of 2013 and being secretly funded by foreign agencies to vilification for launching

peace campaign named amn ki asha. These and other false and wild allegations

are completely baseless and mischievous and were vehemently denied by our

Clients. You are put to the strict proof of it.

11. That most of the above allegations were scrupulously scrutinized by a UK

based Court in a defamation action by our Clients and consequently these

allegations were found to be baseless and the ARY TV Channel broadcasting such

allegations and defaming our Clients was humbled by a Court decree in 2016.

12. That it is regrettably pointed out that despite utmost restraint and patience

exercised by our Clients, you have started a second round of highly defamatory

and objectionable campaign against our Clients in regard to reporting of

developments over PANAMA scandal and investigation proceedings by Joint

Investigation Team and allied matters. That on 17-06-2017, during a press

briefing, you have uttered following highly defamatory and slanderous words to

defame our Clients.

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13. That again on 28-06-2017, you uttered following slanderous and baseless

allegation during a press briefing.

14. That a summary which is only illustrative and not exhaustive of the false

assertions of facts and allegations made by you in the last two occasions as stated

above in press briefings and as simultaneously reported on electronic and print

media, is produced hereunder just as a reference and record to connect your

aggravated acts of wrongdoings towards our Clients.

a. That our Clients are protecting the corruption of Prime minister by

way of misreporting or false reporting of developing events about JIT

investigation and proceedings in Supreme Court.

b. That Mir Shakil Ur Rehman is controlling the media to favor the

corrupt like a God-father in media industry, meaning thereby that he is a

leader of organized crime family (Media) to protect the corrupt

individuals.

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 c. That Jang Group is misreporting and is misrepresenting in favor of

present government in exchange for receiving money by way of large

scale advertisements from government departments.

d. That our Clients are defaming Supreme Court by way of

uncovering WhatsApp story published in Daily The News International.

e. That Mir Shakil ur Rehman is an accomplice of criminals although

no trial of any person has taken place in PANAMA scandal.

f. That Mir Shakil ur Rehman is protecting the thieves and that he is

a perpetrator before the nation.

g. That Mir Shakil Ur Rehman is protecting his financial interests by

abusing his media houses.

15. That besides being false, damaging and defamatory, your expressions as

stipulated above are such that these amount to direct provocation and incitement

to the members of the public particularly your political supporters and workers to

act against our Clients which seriously endanger life, property and business of our

Clients and those associated and affiliated with them.

16. It is established that your defamatory campaign is deliberate and devoid of

any element of good faith and has malicious motives. Regrettably you have lost

the wisdom and patience to tolerate expressions which are not in consonance with

your perception and designed objectives. Evidently, over exuberance and

impatience to dislodge the present Government by all means, has vitiated the

virtues of tolerance in your thoughts and collectively within the PTI.

17. That in the past, sincere efforts were made on behalf of our Clients to

convey to you their deepest anxiety caused by the barrage of false and malicious

campaign launched by you against them for no rhyme or reason. In this context,

several Email messages were sent to PTI top leadership on behalf of our clients

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jointly or severally wherein they had volunteered themselves for an unbiased

inquiry for the purposes of investigating the accusations made by you against

them through a committee consisting of neutral and impartial and respectable

citizens. Our clients also volunteered to face questions by such committee and

explain their position if so required. It was also stated that in case the proposed

committee is able to dig out anything blameworthy or culpable, then your party

will have one hour of prime time on their TV channel to share any such adverse

findings with the viewers. However, your party did not take this offer. Instead of

taking this unprecedented offer of self-accountability by our Clients, you

continued with your malicious campaign against them

18. Notwithstanding anything contained in the above paragraphs, cause of

action of the present legal Notice is emanating from the following defamatory

statements and the material:

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19. That as a result of your recent representations, statements and expressions

on electronic and print media and other forums and the resultant impressions,

innuendoes and insinuations that have followed, grave defamation of our Clients

has been committed by you before an audience of millions of viewers and readers

both in Pakistan and abroad. The allegations are completely false and unfounded

and evidently motivated. Your expressions have personal and ulterior motives and

objectives, have malice in its construct and portray your biased bend of mind

towards our Clients. It has caused serious damage to reputation and social stature

and businesses of our Clients besides causing severe mental distress, pain and

agony. Consequently, your actions have incurred you, liability for aggravated

defamation that is actionable under civil as well as criminal law.

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20. Considering the seriousness and the damage that your expressions,

statements and representations have caused and will continue to cause to the good

name and businesses of our Clients, we are under instructions to signify their

intent to initiate an action against you for damages in Court of law unless you

tender an apology and pay damages.

21. You are hereby urged to tender an unconditional apology to our clients

jointly and severally and withdraw all the allegations made by you and publish

and circulate the said apology with equal prominence and though the damage

caused by you cannot be compensated in terms of money however as a token you

pay a sum of Rupees One Billion by way of damages. Failing this we have

definite instructions to initiate appropriate proceedings against you entirely at

your risk and cost.

22. Finally, your attention is drawn to the urgency attached with the instant

matter and our Clients expect that you should meet their demand within a period

of 14 days. If no reply is received from you, our Clients would be constrained to

knock at the doors of court of law in accordance with law.

Your truly,

AMIR ABDULLAH ABBASI

Advocate High Court Islamabad
aaaadvocates & Associates

NOTE : Three original sets of this legal notices have been prepared, of which two are sent to your above mentioned

addresses and remaining one is retained in my office for further proceedings, if need be

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