On behalf of

Imtiaz Ahmed Bhutto,

Executive Engineer Local Government,
Department Government of Sindh.
To,

1. Chief Executive officer

Sindh TV News Karachi.

2. Nazeer Panhwar, Bureau chief Sindh TV News Mirpurkhas.

3. Naseer Nohrio, District Reporter, Sindh TV News District

Tando Allahyar.

4. Aijaz Bhatti, Cameraman Sindh TV News.

5. Jan Muhammad Samejo , Camera man Sindh TV News.

6. Bilal Bhatti, Editor Sindh TV News.

SUBJECT: LEGAL NOTICE.

Dear Sir,

Under the instructions of my above named client I do hereby serve

the instant legal notice to you as under:-

1. That my above named client is a bureaucrat and honest official who has
been rendering his services for betterment of various municipal districts of
Hyderabad, Tando Allahyar and Karachi East and because of his Laurels in
his department he has been awarded various shields for his best
performance. Therefore he has prestigious honour and dignity among
public servants and in society as well.

2. That in this regard a malicious propaganda was managed by your channel

and the above said staff for conspiring and causing defamation of my client
by the documentary prepared by and aired on 12th June 2021 on your
channel by highlighting the issue of demolished Rehman shopping centre
which was demolished officially by the orders of Sindh Building Control
Authority according to law on 7th June 2021. (https://m.youtube.com/watch?
v=U00Z5IfArkg

3. That the documentary was prepared on the instance of the respondent No.3
(Naseer Nohrio) the so-called reporter who has been engaged in yellow
journalism and the extortion activities demanding from the trading
communities of Tando Allahyar city and also getting gratifications and gifts
from government officials by blackmailing and harassing the public
servants as well as the other peaceful citizens and tarnishing the image of
Journalism .

4. That The respondent No.3 has not only misused the news item of
demolishing the Rehman shopping Center but also used the social media as
tool and by managed posts tried to defame my client by calling him the
Malik Rieaz of Tando Allahyar and aired his pictures and misused the

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 documentary by yellow journalism and media hype in order to defame not
only my client but the legal acts of the state and Judiciary as enshrined U/A
4 of Constitution of Pakistan.

5. That the news report was so illogical that it did not took the point of view of
my client nor discussed the legality of the demolishing order which was
passed by the Regional Director Sindh Building Control Authority as well
as the Civil suit which was filed with the title of Dhallo and others in the
Honourable Court of 1st Senior Civil Judge Tando Allahyar and the
appellate order of District Judge Tando Allahyar and The Constitutional
Petition No.782 of 2021 filed by tenants of the Rehman Shopping Centre
which were dismissed and thereafter the legal action was taken by the
SBCA U/S 14 of SBCA Ordinance 1979. Thus spread of false and fabricated
news causing libel to his reputation.

6. That this false, fabricate news report was aired in order to blackmail and
defame my client and demanded Rs.1.5 million from my client on 6 th June
2021 at midnight for not airing the news before the witnesses and on the
refusal he along with other staff aired the fake , fabricated and managed the
illegal documentary report on the said subject for defaming my client.

7. That not only this but the infamous news report was aired and without his
permission used his personal photos, which were directly taken from his
Facebook wall which is unethical and against PEMRA code of ethics.

8. That the commentary on news report was highly provoking, which tried to
defame my client socially and publically.

9. That my named client’s life and reputation has been severely damaged
caused defamation because of this news report, which was aired with
above-mentioned agenda to harm her life, reputation and causing character
assassination.
10. That It is against the PEMRA’s code of ethics the is notified on 19 th august
2015, where in schedule A, rule no 2 (j)

“Propaganda” means dissemination of any doctrine, rumor, or

selective information to promote one sided views in any controversial
issues, except in public interest and of public importance”

Moreover, the Defamation Ordinance 2002 defines the word

“Defamation” in section 3 as “Any wrongful act or publication or
circulation of a false statement made orally in written or orally or visual
from which injuries of the reputation of a person, tends to lower him in the
estimation of others or tends to reduce him to ridicule, unjust criticism,
dislike, contempt or hatred shall be actionable as defamation.

11. That as per definition that news report is undoubtedly coming in the
domain of propaganda news, hence it is very much against Media Ethics &
PEMRA Regulation, as well as Defamation Ordinance, as your Chanel aired
one sided views, without any authenticity, no name of any teacher was
mentioned who demanded action against my above named client as they
reported.

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12. That my above named client has suffered defamation, mis-reputation and
mental trauma.

Therefore I do hereby serve the instant legal notice to you and advice you to offer
apology to my above named client and pay damages of Rs.10 Million within the period of
15 days with receipt of instant legal notice, else I have definite instructions from my above
named client to sue against you in competent court of law either in Civil or Criminal
Jurisdiction and the same will be your own cost and risk.

Please take notice

ADVOCATE HIGH COURT

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