To 1. Mr. Syed Ghulam Muhammad Rufai S/o Late Ali Mohammad Mir R/o H. No.

8 Vicharnag (Towheedabad), Nowshehra ,Srinagar 2. Ms. Syed Mudasira Rufai R/o Mr. Syed Ghulam Muhammad Rufai R/o H. No. 8 Vicharnag (Towheedabad), Nowshehra ,Srinagar 3. Mr Syed Masdooq Ul Haq Rufai S/o Mr. Syed Ghulam Muhammad Rufai R/o H. No. 8 Vicharnag (Towheedabad), Nowshehra ,Srinagar 4. Mr. Syed Inamul Haq Rufai S/o of Mr. Syed Ghulam Muhammad Rufai R/o H. No. 8 Vicharnag (Towheedabad), Nowshehra ,Srinagar 5. Mrs. Syed Asima Rufai w/o Mr. Shameem Ahmed Zargar R/o Kathi Darwaza, Rainawari, Srinagar, Kashmir. 6. Mr. Shameem Ahmed Zargar S/o Habeeb Zargar R/o Kathi Darwaza ,Rainawari , Srinagar FROM:Mr. Noor Ul Mushtaq (Father of minor Peerzada Mufeer Mushtaq) S/o Mr. Haji Peerzada Gh. Mohd. Shah R/o Chrari Nambal, Chai Dub, Safa Kadal, Srinagar, Kashmir, BE (Electronics & Communication) (Bangalore University), MBA (MS University), Managing Director (Al Taaraf Group of Companies, Dubai) DEFAMATION NOTICE

Under the instructions of my aforesaid client, and after going through the documents , paper cuttings , notices pasted on the walls , photographs , tickets , account statements ,Hospital documents , bank records , legal files ,Passport Visas & Tickets etc I serve upon you the following legal notice for causing defamation, insulting and lowering down the image and creating disrespect to my aforesaid client on the following facts:1. 2. That my aforesaid client is a respectable, peace loving citizen of Jammu and Kashmir State, India. That my client is the man of fame in his professional life which can be found from various international magazines & publications (Proof available) and newspapers (proof available), awards (proofs available), having good Reputation, soft spoken & well settled and is financially sound, a qualified

Graduate Engineer ,Business graduate and working as Chief Engineer & Managing Director for a well known International Business Group in Dubai . 3. That my aforesaid client has vast and good reputation and estimation in the society and is holding great respect, regard, reputation and the family is known by their integrity, honesty and character in the society and amongst the neighbours & relatives. That my aforesaid client and his family hail from respectable background and have deep rooted social, economical goodwill and estimation in the area and are being regarded as one of the well educated, social and among the noblest families of the valley and area, respected by all the natives of area and are being taken into high estimation and respect. That my client has shown me the paper cutting( Rising Kashmir page no-1 , front page , bottom) notices pasted in the mohalla, and I also met some persons who are witnesses to various incidences and other incidences for which my client have shown sufficient proofs /evidence to establish its circulation in general public and at open places.

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5. That the news Dated Oct 21, 2009 was published in English Daily Rising Kashmir that Nasreen, who completed her Ph.D in commerce and Management from Kashmir University last year, died on March 4 this year due to torture from her husband and in-laws. Married to Noor-Ul-Mushtaq about three years back, she was tortured while her husband was working in Dubai, her family members said. (Ref Rising Kashmir) The news was refuted by my client as he always suspected that you are holding his son deliberately against his will to take control over his properties including locker and are using these pre-planned tactics But in fact my client have filed case against you to get his son back after you have not agreed to follow Muslim Shariah & did not handover the child to police after my client approached police to get his son from you Even as she was with her husband in Dubai for several months last year, her tale of woes did not end there, her family members alleged. They added that tortured Nasreen came here along with her husband from Dubai on January 27 and was admitted to the SMHS hospital. She later died on March 4, while her husband fled leaving no information about his whereabouts. Their son, Abdullah Nasreen, then only nine months old, has been with his maternal family in the Nowshera locality of Srinagar. The proud family wants justice, as the police had earlier refused to file an FIR for death due to torture. Nasreen was to join as a college teacher as she had been selected by

the State Public Service. The death on March 4 came only three days before she could have joined the Islamia College of Science and Commerce a lecturer, moaned her brother Masdooq-ul-Haq (Ref Tribune India).It is to mention that my client never knew about her Job application or Interview made at Islamia College or Public Service Commission, which he is very curious to know when the application was made at Public Service Commission & by whom if she was in Dubai. hence suspects a conspiracy. 6. That it was mentioned by Shameem Ahmed Zargar in Mohallah committee (Chai Dub) in front of all Mohallah heads that the deceased have transferred amount of Rupees 2.85 to my client which is totally false as she (Deceased) have transferred as credit to her sister Ms. Syed Mudasira Rufai even my client never had any knowledge about this amount or transfer (ref JK Bank records & Witness). And is the property of son of my client as Parental properties are properties of children as per Muslim personnel law. That it was always and again mentioned by Syed Ghulam Muhammad Rufai that she was killed by torture & injuries as per allegations made in Mohallah (Written documents available) & in paper also and are always claiming that my client has killed her but the fact is that she died of Cardiac arrest caused by Intellestetial Lung Disease (ILD) as mentioned and reported by SKIMS records (Medical Record file # 546088) & several hospitals in Dubai have diagnosed the lung disease .The ILD treatment was done in Dubai & it was my Client to admit her in hospital at Ward 5P ,SKIMS, Kashmir. (Ref Mohallah committee / Hospital/Medical Records) That it is again mentioned by Syed Ghulam Muhammad Rufai that my client is opposing recitation of Holy Quran but the fact is that my client had performed Umrah (On May 27, 2008) exactly after birth of his son and even before birth of his son when deceased was in Dubai, they were invited for Umrah but could not go due to her pregnancy, (Ref Woman Commission, Invitation from prince of Jeddah, Dubai hospital Maternity records). That it has been mentioned several times that my client is drug addict, Alcoholic etc in child custody case as well as in several occasions including Mohallah ,despite the fact he does not even smoke a cigarette (Ref Court /Mohallah/Witness). That it was mentioned by you in court case for operating of Bank Locker that my client fraudulently registered locker in his name but the fact is that Locker was registered exactly after marriage on account of my clients NRI bank account NRE 111 SB Canara Bank, Srinagar & keys remained with deceased forever till her death & my client has never operated it as it is

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property of his Son Peerzada Mufeer Mushtaq (Ref court case, Woman commission). There are some personal items of my client as well in Locker & he never had any intention in grabbing or taking locker otherwise despite being in his ownership , he never asked for key in 19 Months of marriage union nor applied for duplicated keys in absentia or proxy nor stole the keys from deceased wife nor used any method to operate the locker but has cancelled Power of Attorney only when his deceased wife told him that her Elder Sister is forcing her to operate the locker in his absence after reporting the keys are lost & my client even never cared about locker despite the fact that you have maintained status quo for the locker despite his nomination for Son Peerzada Mufeer Mushtaq after expiry of his wife. & my client have recently successfully evaded the ex-parte decision as was never informed about status quo as my client was in Dubai & no notice was served at all which is confirmed by court records. 11. That the name of the son of my client in Tribune India , Greater Kashmir , Kashmir Times , Hindustan Times Dated Oct 21 ,2009 is shown as Abdullah Nasreen & Abdullah Syed, on your saying which clearly Humiliates my clients Son and my client as Bastard under Islamic Law as my client has never denied paternity nor has given any consent to any one dead or alive to change name of his Son, which is baseless and absolutely false & phony as such defamatory . This name Abdullah Nasreen as proposed by you is been confirmed by Greater Kashmir in reply to my clients e-mail. It is worth to mention that my client have registered his sons name Mufeer That it has been repeatedly said that my client has grabbed the Life Insurance of his deceased wife & has insured his Son with the intention to kill him which is totally defamatory. (Ref Mohallah, Court etc) as no such Insurance ever existed for which my client was a nominee nor any such Insurance was ever planned nor is existing. That with the name of the deceased wife of my client it has been mentioned in death certificate that she is widow, which is baseless and absolutely false & phony as such disparaging. (Ref Death Certificate) so my client claims it as Intentional mental distress caused by you for suppressing my client & his revered family. That again it has been mentioned in Mohallah that my client has illict relationship with different women (Ref Mohallah heads & written documents), which is baseless and absolutely false & phony as such insulting. That it has been repeatedly uttered by you that my client has married in china & has two children there, which is baseless and absolutely false & phony as such slanderous. .

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16. That as per news published in Rising Kashmir Dated 21 Oct 2009, that she was buried as she willed by Mr. Syed Ghulam Mohammad Rufaibut in State Womens Commission you said no one from In-Laws joined her last riots, but in fact the funeral was joined by Father In law & two brother in laws despite the fact Mr. Syed Ghulam Mohammad Rufai & all informed no one from in laws about her death, hence defamatory. By burying her in Syed Ghulam Muhammad Rufai s graveyard was done forcibly as my client was never informed about her death at all as my client still claims for the dead body of deceased under Shariah laws. And my client stresses upon the fact that his deceased wife was carrying three credit cards, Three Golden Sets (Worth Rs 3 Lakhs), Pair of Tag Huear watch (Worth Rs 56000) Video Camera & various Valuables and he sets the claim for these under Oath and claims it to be the property of his son Peerzada Mufeer Mushtaq. 17. That the deceased wife of my client was suffering from Intellestetial Lung Disease (ILD) & she got treatment in various hospitals in Dubai and died of Cardiac arrest caused by ILD so how come my client killed her, besides it is alleged that the deceased tried to contact Police or authorities but my client threatened her as per you to kill the child. The fact is that my client was not 24 hours in home but leaving home at 09:00AM for office and coming home after finishing office, she was having pre-paid Mobile Phone 00971 50 293 0 659 , Landline, Internet she would have called authorities in his absence, ,which is as such baseless and absolutely bogus & mock as such libellous. Again it is worth to mention that my client have record of complete telephone bills from the mobile of deceased to her Sister , Brother & her maternal home landline almost the call is made every day from Mobile hence my client claims it as conspiracy from your part. And it was deceased who was with my client at Consulate General of India located at Dubai while getting his passport renewed. That Shameem Ahmed Zargar called my client as a Christian in public & in Mohallah when he is a devoted Muslim having performed Hajj two times and Umrah 90 times & the last umrah was performed on May 27th, 2008 after the birth of his Son, As per Shariat, No Muslim can be considered as non-Muslim and religion being a very sensitive issue and cannot be used as a tool for defence and it can cause effect on life and dignity as well. You have blamed my client of torring holy Quran which happens to be total lie as my client never did it as he has great respect for Quran for being a Muslim as my client presented 15 sets of Holy Quran as gift to the above all family on his first visit which is clearly mentioned by deceased on shopping list written by her.

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That you are making continuous Accusation of Torture, inspite of the fact that the adequate hospital care was given her in her first presence in Dubai during pregnancy. The honeymoon was celebrated at Taiwan, Hong Kong, China and almost everything was provided as should be. Then she was dropped by my client to Kashmir for delivery of baby and attending the PhD. Viva and the shopping list is written by deceased herself & all purchase proofs are available signed by her as she used the credit card often issue as supplementary card on her name. That my client got his son and wife back to Dubai and all was fine & It was the deceased to apply for the passport of son in absence of her husband after the delivery and my client prepared the Visa for his son .When she started coughing my client took her to doctors and hospitals then back to Kashmir as it was very hard for him there to attend her in hospital as advised by doctors and as well as private job. My client admitted her in SKIMS hospital. (All documentary proof available).In absence of passport of my client, he booked the ticket to & fro from Delhi for uncle of deceased but luckily my client got the passport and accompanied her himself & stayed with Syed Masdooq Ul Haq (Brother 0f deceased) & Zain Ul Abideen (Paternal Cousin of deceased) at Delhi for few hours on January 26, 2008 before boarding flight to Srinagar. And the brother & cousin have seen no sign of torture and her brother left for Calcutta from Delhi & he and his wife was not present at hospital at all till second day of death of deceased. But he attacked two brothers of my client at Shariah court in order to abstain my client from taking the custody of Peerzada Mufeer Mushtaq under Muslim law & FIR was lodged. (Witness Mohallah heads) Ms. Syed Mudasira Rufai have taunted the wife of my client in court & have tried to create the conflict between the happy couple by informing the wife of my client that he is alcoholic & same words were uttered by Mr. Masdooq Ul Haq Rufai by calling my client as drug addict. However the wife of my client remained silent as she happens to be from reputed family of Kashmir & have been happily living with him and found no error in character of my client.Similiary Syed Inam Ul Haq have made defamation by informing his colleagues at college that my client have refused to go for medical test regarding the drug of abuse , but the fact is that my client was never asked to do so and my client have no such menace & is ready for any medical test at any place assigned by court of law. That in view of the aforementioned facts you have levelled baseless , defamatory , insulting, offensive, slanderous, libellous, derogatory, defamatory allegations on my client and have maligned and defamed my clients in the eyes of general People .

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That the notices pasted in the streets of mohalla, news paper was read by the general public of the state and on line by the people working with my client and knowing my client across the world including the relatives, neighbours, friends colleagues, department and other sections of the society. That you have levelled baseless , defamatory , insulting, offensive, slanderous, libellous, derogatory, defamatory and malicious allegations without showing the source and has shown number of serious baseless malicious allegations, as mentioned above including to relate them with some acts which are beyond any truth . That your actions have lowered down the status of my client in the eyes of society, relatives general public and besides lowering his image have subjected him to mental torture and harassment . That from all the circumstances and facts mentioned and the language used by you at several occasions it is clear enough that you have levelled baseless , defamatory , insulting, offensive, slanderous, libellous, derogatory, defamatory allegations without any proof, evidence or material, solely intending to cause injury to the reputation of my client and his family and exposed my client and his family to ridicule, public, contempt public hatred, prejudice and risk to their life and property. That the several acts by you and circulated in the General Public, my client and his family has been maligned by the above said false, libellous and malafide allegations without any reasonable and just justification, therefore for the act of yours ,I seek the indemnification of my client for the harm, risk and agony caused to him and his family. That through this legal notice I seek and ask for the source, reasons and motive of writing and levelling said baseless, malicious libellous, allegations and also seek and claim rupees Fifty lakhs (Rs.50,00,000/-) on behalf of my client as damages (though priceless) besides publishing the apology in the same manner as the notices were circulated in mohalla and also in the news papers where the same was published .

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In view of the facts and circumstances mentioned above I impress upon you to do the needful as said above including payment of damages to the tune of Rs.50,00,000/-( Fifty Lacs), disclosing the evidence and ask for the source, reasons and motive of writing and levelling said baseless, malicious libellous allegations and also to Circulate the apology in the same manner or on the front page of News Paper on your behalf, and he same is impressed upon you to be done within 90 days from the serving of this notice failing which I

stand instructed to initiate appropriate legal proceedings including in the nature of civil and criminal against you . I, once again impress and hope for the response within 90 days, otherwise you will be responsible for the proceedings against you. Copy of the notice is retained for the follow up necessary action and requisite notice fee of Rupees 30,000/- at your cost received. Sincerely yours (Sajad A. Geelani) Advocate