IN THE COURT OF SENIOR CIVIL JUDGE, LAHORE

Suit no………..2019

Ali Hassan son of Muhammad Ahsan, resident of Model town, Lahore

..Plaintiff

Versus

Ayesha Siddiqui daughter of Siddique Ahmed, resident of Defence, Lahore

..Defendant

SUIT FOR COMPENSATION OF RUPEES 2,00,000 FOR DEFAMATION UNDER

SECTION 9 OF DEFAMATION ORDINANCE, 2002

Respectfully Sheweth,

1. That the plaintiff is the Vice principle of Lahore university and having immaculate reputation
in his career.

2. That the plaintiff as law-abiding citizen and have great respect among the locality and in the
eyes of relatives and friends as well as in University
.
3. That the defendant is a girl who applied for admission in university on 10 th February,2019
without required qualification and get rejected on the basis of merit.
4. That on the 25th February,2019 the defendant has leveled allegation against plaintiff and for
reasons not known has accused the plaintiff that he was abused his position and demand
 bribe for admission. She also accused that no one in university get admission on merit,
everyone pay a high bribe to get admission.

5. That the cause of action arose where the defendant on 1 st March,2019 alleged on media
that plaintiff demand bribe from students for admission. She has also malafidely accused
that plaintiff harassed her during the process of admission.

6. That the allegations were baseless, however, the same is derogatory and published in a
newspaper, having very high circulation in the country.

7. That on the allegations, the principle of the university take action and made a committee
for this matter. In the committee, many investigations were happened and the plaintiff was
suspended for a temporary period.

8. That the plaintiff was interrogate on baseless charges, the same was ended in favor of the
plaintiff and all this was malicious without reasonable and probably cause.

9. That the defendant have no legal justification and proof for support her points. The
interrogation upon the allegations made by the defendant cause continuous mental torture to
plaintiff.

5. That due to the false statement by the defendant and publication of a false, frivolous and
baseless news, without any basis on malice the reputation of the plaintiff has been damaged
in such that there could not be repaired. The credibility built by the plaintiff during span of
time was shattered.

6. That the defamatory statement by the defendant was having a tendency to injure the
reputation of the plaintiff i.e. to lower him in the estimation of others and also injured his
profession.
7. That these allegations not only cause damage to reputation of plaintiff but also cause the
mental and physical torture which effect his health and job. During the interrogation period
he was suspended from his job which cause him financial loss. He was not able to submitted
the admission fee of his daughter which effect his daughter career.

5. That the plaintiff claim damages on account of mental torture, agony, financial loss and
injury inflicted to his reputation, honor as well the detail of the same are mentioned as
under:

 General Damages
1. Injury/ loss to reputation as a person   =   1,00,000/-
2. Mental torture and physical agony      =   Rs. 50,000/- 
 Legal Assistance
a. Legal assistance & General                   = Rs.   50,000/-
       Total                              = Rs. 2,00,000,/-

14. That the plaintiff contacted the defendant and sent her a legal notice on 5 th March,2019 and
demanded above-referred amount as damages but the defendant flatly refused to accede to
the legitimate and legal demand of the plaintiff. The defendant has also extended threats for
dire consequences to the plaintiff . Hence this suit was initiated on 10th March,2019.

14. That the cause of action firstly accrued on the false, frivolous and baseless statement and
publication of news and finally on the refusal of the defendant to pay the above said amount
as damages and is still continuing.

14. That the parties are residents of Lahore, hence this Honorable Court has the jurisdiction
to entertain the matter in hand.

14. That the value of the suit for the purposes of court fee and jurisdiction is fixed as Rs.
2,00,000 and the requisite court fee has been affixed on the plaint.
Prayer:
a. In view of above, it is most humbly prayed that the suit of the plaintiff for recovery of Rs.
2,00,000 as damages, may kindly be decreed in favor of the plaintiff and ordered to
defendant to pay these damages.
b. That the defendant be directed to published a complete and unqualified apology to the
plaintiff and retraction of the allegations made in media, in such form as this Honorable
Courts directs.
c. Any other relief, which this Honorable Court deems fit and proper may also be granted to the
plaintiff.

Plaintiff
Through

Counsel(s)
Advocate High Court
Lahore.

Verification:
The plaintiff Ali Hassan, do hereby solemnly declare that what is stated in paragraph 1 to 16
of the foregoing Plaint are true and correct as per his own knowledge and as per information
received.