Ss ROWN LAW CHAMB! Abdul Qadir Patel, Minister of National Health Services, Regulations and Coordination of Pakistan Pakistan Secretariat, Islamabad 29 May, 2023 SUBJECT: LEGAL NOTICE UNDER SECTION 8 OF THE DEFAMATION ORDINANCE, 2002 We act for and on behalf of Mr. Imran Ahmed Khan Niazi, (“Our Client”), who has instructed us to serve upon you the following legal notice under Section 8 of the Defamation Ordinance, 2002 (the “Ordinance’) on account of dissemination and circulation of wrongful, baseless, false, misleading, erroneous, malicious and defamatory information/facts made against Our Client by you vide your Press Conference, dated 26.05.2023 (the “Press Conference”). The Press Conference was watched in Pakistan as well as all over the world through electronic media channels, YouTube and various other Social Media platforms. Moreover, the details regarding the Press Conference were also published in ‘Newspapers nationally as well as internationally. Few links to the Press Conference are as follows: [hups:/www.youtube.com/watch?v=CGLIO-Fad, Autps:/iwww.youtube,comwatch? v=nyv5 VuCm-wA, Jups:/www.youtube.comhvatch?v=qEgq'RUHw31] 2. Through the Press Conference, you have falsely, erroneously, dishonestly, unfairly, unethically and ‘maliciously, asserted/alleged the following: etd SB AS 2 Ap) SS AS Ke 1) WES Se yy tl ab Ae Dongen Symes OS Sct ol 8 alla | Sip iS ce at S02) = 18) le Sap SIS tls ey ee net aS Sah cop aw Rut YS he YS Soe Stalag ly pm Sb Ll ty 3! gS) Se hn AS AY Sh a 8 erat ie WI AS IS IES A pS ce 08) SY as Son one Aleit SN pe od PD hp Nl ay! cole A ales me il to olen come gy te tg Sin pal tay Shay hy Sine Sy SMES od ee a ue yyy 0g a | ond ei Lay Shin LS Urine Sample S wha 4 EEN nS ih SEC lS IS GA tp an 9 21S OSS oy) Ot ee tonic ate se initial HEE GS Slt 1 US W Urine sample StS 2 tt 398 Seaben BS a 33 Ge Sy) ISS Se eS tl SN Sy Scott JE el om eb el st st S hom Sh oS Sis Tonic se S S$ ou et The Mental Stabiliy ts Questionable. There was some apppropriat | Lao Ofice: 256A, Upper Ma, Lahore. Phone: 482-42 957807702 Islamabad Office: House No.11-A, Street 23, Ema: info@ thecrownlaw.com Web: www thecrownlaw.com ‘Sector F-8/2, Islamabad. Phone: +92 51 2656127-8CROWN Sif How can Alcohol and Cocaine consumption can be traced throng u Urine Test? vit Our Clint incurred head injury on the day’ of his egal arrest lawever, the medical report has failed to mention the same. ix, The reportemphasizesalot on mental state of Our Client; however. no details of mental State examination have been provided Assessing team consisted of orthopedic doctor yet there are no details ofa fll trauma ‘examination. sly. willingly, deliberately and maliciously which act ishighly irrational and negates te principles of ethics 13.1 may be pointed out here that the comments/remarks were made by you knowingly. con ‘and morals prescribed by all stretch of standards. Furthermore, your remarks/comments are also in violation ofthe standards and ethics which member of Fedral Cabinet must possess and display. 1e and liable forthe above-said defamatory circulation and dissemination which 14, That you are responsi hhave caused a loss to the Our Client's good will, injury to his reputation and have adversely affected ‘Our Client’s honor, Likewise, you have also caused emotional trauma, mental agony, anguish and distress to Our Client IN VIEW OF YOUR FALSE, DISPARAGING, MALAICIOUS AND DEFAMATORY STATEMENTS/REMARKS/COMMENTS, WE, THEREFORE, THROUGH THIS NOTICE, hereby call you to do the following: in whieh you made them in the First 1. Retract your statements in the same mode and manne place; b, ‘Tender an unconditionally apology and admit that you have misstated; ce. Pay Rs.10 Billion for defamting Our Client and levelling false allegations against Our Client, ‘which will be donated to Shaukat Khanum Memorial Cancer Hospital and Research Centre 4. And refrain from repes (Client in future. ing and making any further defamatory comments/remarks against Our TAKE NOTE that in case of your failure to do the needful within 15 days, Our Client woul be compelled isk as 10 consequences thereoF shall be institute legal proceedings, the costs of such proceedings and the ly on your account c. R Ow N a Jel 6 sine iacia sate Crown Law Chambers