1. There is no defamatory matter aired by the Defendant No.

1 to invoke
the jurisdiction of this learned Court as no “wrongful act or publication or
circulation” as used in Section 3 has been established by the Plaintiff. There
was nothing in the Plaint that was actionable as “Defamation” under Section
3. The instant suit is, therefore, barred by Section 3 of the Defamation
Ordinance 2002.
2. That the Plaintiff has impugned an episode of ARY News TV Program
named “Zimmedar Kaun” (“Program”), which was aired on 14th May, 2017,
thereby, alleging that the said Program is “defamatory” and “derogatory” in
nature and that it was made with a purpose of “destroying the reputation” of
the Plaintiff and the credibility of his Hospital. At the very outset, all the
allegations of the Plaintiff as leveled by him in the Plaint under reply are
denied as framed for being incorrect, false and misconceived. In fact, the
team of the said Program exposed the illegal business of a fake/unregistered
Hospital which is being run by quacks under the supervision of the Plaintiff.
The so-called Charitable Hospitals such as his are exploiting poor people
through profiteering practices and playing havoc with their health and lives
in the name of health Services under the garb of Trust and NGO. As part of
their journalistic duties, the team of the Program was merely performing its
duty to expose such illegal businesses.
3. present Suit has been filed against the Defendants with the malafide
intention to take revenge from the Defendants for exposing and airing a fact
based program to expose the social ills and a filthy business in the garb of
health services, in which the Plaintiff is a trustee and partner in crime.

4. That the Plaintiff has not annexed with the Plaint any cogent evidence
of the damages suffered & the quantity of amount claimed by the Plaintiff.
The Plaintiff cannot rely on the basis of general, vague and scanty evidence.
5. That the Plaintiff has filed the Suit based on mere frivolous allegations
as he has not annexed any cogent evidence that the Defendant intentionally
published defamatory matter. It is pertinent to mention that all the programs
aired by our channel exposing the illicit businesses are based on true and
fair comments and are aired in sheer public interest..

That the Plaintiff has approached this Hon’ble court with unclean hands,
having no locus-standi, frivolous plaint and concealing plethora of facts.
Hence, this suit is liable to be dismissed with compensatory cost.