Feb 19

Legal Notice to Imran Khan

Posted on Wednesday, February 19, 2014 in Legal notice

17 February 2014

Mr. Imran Ahmed Khan Niazi
2 Zaman Park

Legal Notice

Dear Sir,

  1. This legal notice is issued on the instructions of our Client Mr. Najam Aziz Sethi (the “Client”) who is a senior political analyst, publisher and the Editor-in-Chief of a Lahore based political weekly called ‘The Friday Times’ in the following terms:
  2. The notice is served upon you in response to the contents of baseless, malicious and defamatory remarks made via (i) tweet on your Twitter Account on 04 February 2014 (ii) in the press conference you held within the precincts of the Honourable Supreme Court on 11 February 2014 (iii) during Geo News talk show ‘Capital Talk’ with Mr. Hamid Mir on the eve of 11 February 2014 and (iv) a talk show ‘Zer e Behas’ on Samaa TV with host Mr. Arif Nizami on 17 February 2014.  Henceforth all the four statements / remarks shall collectively be referred to as the “Publications” and the transcripts of the relevant extracts are attached herewith as Annex A/1 to A/4.
  3. The Publications are allegedly based upon the so-called “information” received from unidentified and unacknowledged sources and has utterly been unsubstantiated.  Our Client has taken serious notice of these completely false and scandalous Publications that render a distorted and fictitious travesty of facts about our Client with the malicious purpose to defame and disgrace him.  Hence all the baseless, fictitious and malicious allegations made in the Publications against our Client are vehemently denied.
  4. Our Client is a very well read scholar holding a Masters degree from Cambridge University, UK.  In 2011, Clare College Cambridge University, UK nominated him as Alumni of 2011 and conferred the Eric Lane Fellowship on him.  He is a dignified member of journalist community commanding great respect for his integrity, courage and professionalism.  He is founder editor in chief of Daily Times and Daily Aajkal.  In 1999 Newsweek International lauded our Client’s political weekly as a ‘crusading paper’.
  5. Our Client is the only journalist in the South Asia who has been recipient of three top international awards for journalist courage and professionalism in a decade.  In 1999 he was awarded ‘International Press Freedom Award’ by Committee to Protect Journalist New York and ‘Courage in Journalism Award’ by Amnesty International.  In 2010, he was honoured with the ‘Golden Pen Award’ by the World Association of Newspapers Paris, which is the apex body of global media.  Our Client was the first journalist in Pakistan who was decorated with ‘Hilal-e-Pakistan’ in 2011.  In 1996 – 1997, our Client was appointed Advisor for Political Affairs & Accountability, with the rank of a minister, in the caretaker federal cabinet of Pakistan.  He served as national consensus Caretaker Chief Minister of Punjab from March-May 2013.  Our Client is the Chairman of the Pakistan Publishers and Booksellers Association and the Secretary-General of the Lahore International Book Fair Trust.
  6. The reasons for campaign of vilification, malicious and scandalous allegations levelled in the Publications are given hereunder:
    6.1  Since our Client appears as a permanent guest analyst in a current-affairs programme on Geo News called “Aapas Ki Baat, Najam Sethi Kay Sath”, which is one of the most watched shows and is liked because of our Client’s honest and impartial analysis in his candid and original manner.  Thus our Client is acknowledged as the leading authoritative, credible and independent voice of journalism in Pakistan, according to the Credibility Index published online.
    6.2  Our Client being a public spirited citizen and analyst has been rendering his duty to raise public awareness about current geo political national and international situation through his independent political critique.  During the discharge of his journalistic duties you, your party, your policies and your decisions have often been subject of our Client’s frank analysis done in his usual businesslike manner in the same way he evaluates all other political parties and figures.  However the fact is that neither you nor your followers could ever digest our Client’s professional criticism positively.  Resultantly a campaign of vilification to malign our Client and his views has long been going on in print and social media.
    6.3  Then frustratingly unbearable for you is the satirical column ‘IM the Dim’ that is published in ‘The Friday Times’ under the editorship of our Client.  Not only is this column received very well in Pakistan, it is popular in the UK among your English friends, who often embarrass you, as you have told our Client requesting him to stop publishing the same.  Upon his consistent denials, hence, these Publications.
  1. The contents of the aforesaid Publications are utterly preposterous and misinformed.  The Publications imply that our Client was made Caretaker Chief Minister of Punjab to rig elections in favour of PML (N).  Whereas in March 2013, our Client’s name was presented for the Caretaker Chief Minister of Punjab by the PPP and its allies and was accepted by PML (N) and its opposition allies on basis of our Client’s unmatched credibility, independence, neutrality, integrity and high esteem, which he holds in Pakistan and in the International community.  It is a matter of record that neither you nor your party raised any objection on the nomination of our Client.  Indeed, you personally welcomed our Client to your house in Islamabad and expressed support for his neutral administration.
  2. The Publications make a further allegation that our Client was rewarded, in return of his alleged service to PML (N), with the post of Chairman Pakistan Cricket Board.  It would perhaps be surprising for you to know that our Client occupies this office on honorary basis, without a single paisa in remuneration, so much so that he uses his own car and driver for going to PCB office and meetings in Lahore and Islamabad.
  3. The Publications are allegedly based upon so called information gathered in an unidentified and unsubstantiated manner.  The malicious allegation of causing ’35 Punctures’ is vague in its form and content. It is fictitiously suggesting, without any proof whatsoever, that our Client had some role in PTI’s defeat in last general elections.  The fallacy in your allegation is revealed by the mere fact that no evidence whatsoever of the alleged so called conversation between our Client and top leadership of PML (N) has ever been produced by you despite being repeatedly demanded by our Client.  The said allegation represents a gross distortion of the record that is laced with falsehood and rancour to malign our Client on account of foregoing reasons.
  4. Needless to reiterate, all the allegations levelled in the Publications about our Client are absolutely preposterous, absurd, ridiculous and libellous in character.  Each of these allegations mentioned above has been shown to be false, baseless and bogus by reference to facts and record.
  5. So our Client has taken serious notice of the utterly false and scandalous Publications that render a distorted and fictitious travesty of facts about our Client with the malicious purpose to defame and disgrace him.  The foregoing Publications were repeated without obtaining any confirmation or verification from any relevant or affected quarters including our Client.  The falsity of the allegations made in the Publications, their vicious slant against our Client and the repetition of such allegations to the point of revulsion reveals a concerted effort under a malicious plan to malign our Client unjustly, without cause and with the sole purpose of defaming him.
  6. The contents of the Publications are extremely insinuating, disparaging and defamatory attacking on the reputation of our Client.  Not only the words and language used are defamatory in their natural and ordinary meaning but even the ordinary reasonable implications thereof are also defamatory.  Thus these are libellous Publications maliciously motivated against our Client to injure and lower him in the estimation of right and fair-minded people of society, for which you are solely liable.
  7. The wrongs committed through Publications by yourself, for which according to law you are directly responsible, constitute both civil as well as criminal wrongs.  The act of intentionally communicating false allegations that are derogatory and defamatory in effect constitutes the offence of defamation, which has in fact been committed by the Publications in respect of our Client.  The baseless allegations made in the Publications have injured his reputation, lowered him in the eyes of others and exposed him to ridicule and dislike.  For causing such harm, injury and pain, our Client has a right to be fully compensated by yourself as the originator of the Publications.  Although a financial award can never adequately compensate the injury and loss of reputation suffered by our Client on account of the defamatory Publication, however, you are hereby notified that our Client claims an amount of Rs.100/- crores as compensation to partly alleviate his loss and injury caused solely by the illegal actions of yourself.
  8. Without prejudice to the foregoing, in order to acquit yourself of guilt and responsibility for the foregoing illegal actions constituting defamation, libel and slander, you are hereby granted an opportunity by this legal notice to present cogent, relevant, admissible and non-hearsay evidence of the alleged conversation between our Client and PML (N) leadership establishing the veracity, if any, of the allegation of ‘35 punctures’ within three days of the receipt of the instant legal notice failing which the sham nature of your allegations made in the Publications shall be deemed established.  In that case, you may publish a contradiction and an apology for the malicious, fallacious and scandalous Publications herein challenged with the same prominence under headlines with which such Publications had been carried.  Such a contradiction and apology must appear within seven days of the receipt of the instant legal notice failing which our Client may commence, simultaneously or successively, legal actions for civil and criminal remedies against yourself and other persons involved in the commission of such wrongs.
  9. In this case, take this as a notice for initiation of action for defamation under section 8 of the Defamation Ordinance 2002.  Please take note that the contents of the Publications constitute admissions and can be used as evidence against you.

Yours truly,


Usman G. Rashid

P. S. 1:

An original of this notice is retained in our chambers for future reference and reliance.

P. S. 2:

To ensure delivery, original legal notices are also being despatched on your following addresses:

  1. House No.18-D/1, Gulberg III, Lahore
  2. Street No.84, House No.2, Sector G 6/4, Islamabad
  3. Residence of Mr. Imran Khan, Banni Gala, Islamabad

Copy to: Our Client

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