ou IN THE COURT OF DISTRICT JUDGE LAHORE nance 2002) ction under Defamation Or (In exercise of juris CIVIL SUIT NO.983 OF 2014 IN THE MATTER OF:- NAJAM AZIZ SETHI VERSUS IMRAN AHMAD KHAN NIAZI WRITTEN STATEMENT/REPLY TO THE SUIT FOR DEFAMATION UNDER SECTION 4 OF THE DEFAMATION ORDINANCE 2002 READ WITH ALL OTHER ENABLING PROVISIONS OF LAW FOR GRANT OF PERMANENT. INJUNCTION, DEMAGES AND COMPENSATION ALONG WITH ALL OTHER RELIEFS, ON BEHALF OF RESPONDENT/DEFENDANT RESPECTFULLY SUBMITTED PRILIMINARY OBJECTIONS A) That the Suit is liable to be dismissed Zor breach of the mandatory requirement of notice under section 8 of the Ordinance which w mn the correct address fer properly serve: of the defendant. B) That the Suitis liable to be dismissed for the non joinder and misjoinder of necessary parties to the Suit as the actual originator ofthe alleged defamatory statement aie intentionally not ‘made the party to the suit and even otherwise no action has been brought against those who Defendant, had originally leaked and informed ©) That the suit is against the Constitution, provisions of Islam and the interest of Justice. D) That the Suit is bared by time. That the suit lacks territorial jurisdiction and the court fees is not atached, That the Suit is hit by the principle of Estopple and not maintainable. ‘That Suit is not filed in accordance with the law and is not verified hence is liable to be dismissed.siming to gain technical advantage against the will of the people and spirit of democracy 1) That the suit is aiming to discourage the freedom of speech and expression jnformation by intimidating the Defendant (a public property) from being able o express the 1 Pak true sentiments of tanis which undermines the idea of democracy. 3) That the Suit is based on t by reser ing only partial facts, as the complete con + and background scene in which the alleged defamatory statement was made has been ‘cunningly not included in the Plaint and the evidence presented is not present sd in acomplete picture. . K) That the evidence presented has not been lawfully verified and cannot be relied on as wus ‘defamation’ as defined under the Section 3 of the Defamation Ordinance 2002 defines defamation and its forms: “any wrongful act or publication or circulation ofa false statement or representation rade orily or in written or visual form which injures the reputation of a person, tends 10 lower him in the estimation of others or tends to reduce him to ridicule, unjust entiism, dislike, con comp or hatred shall be actionable as defamation. Defamation is of two forms nam (@ Slander and (ii) Libel Any false oral statement or representation that amounts to defamation shall be actionable as slander, ‘Any false written documentary or visual statement made either by ordinany fom or expression or by electronic or ot shall be act ‘modem means or devices that amounts to defamation able as libel, M) = That the person has a defence if he shows that:- ction 5 of the same Ordinance provides that “In defamation proceedings & } ‘The mater commented on is fir and inthe public interest and isan expression of opinion ‘is based on truth and was made for public good; or N) That the alleged contemnory statement is fai and bonafide comments based completely on od faith and on the back drop ofa very serious public issue/ interest of the public; out come of which is going to shape the destiny of 200 Million Pakistanis. Instant matics $ of such serious and grave nature that Judicial intervention has already taken place during the© 6 ng, Hence this present Suits by the Law of Sine Dine tll the final ou cial Commission. Even other wise the recent decision of Election Tribunal is provi fulness of the alleged contemnory statements and the whole picture is joining into pieces. 0) That the Defendant may rely of any or all others lawful objections atthe tin of the arguments, PRELIMINARY SUBMISSIONS: 2) That the Defendant's isa highly successful Pakistani who's credibility is uunshakable and the riyof the educated Pakistanis any where in the word fully support the Defendant | leader. The det fendant has unmatched international recognition and lea 2 stest growing and largest national political p in Pakistan, who has stood fast against rapt practices and seriously dented the entre electoral system by exposing the comuPt and powerful status quo players in polities, media and judiciary. Most recently his movement of Go Nawaz Go had been historically recorded as both by Youn: ‘who stood by him in all weathers and pain justo getridof the present political system wht has only imposed slavery upon our great nation by the co erupt regime and its allies under imerna tional pressures to deprive the poor Pakistanis from their Fundam: tal Rights aranteed by the Constitution, Synopsis ofthe brief awards/achievement ofthe Defendant follows: at Aitchison College in Lahore and 01 Worcester in ne Royal Grammar and, where he excelled at cricket. In 1972 he enrolled in Keble College, Oxford where he read Philosophy, Politics and Eeonomics, graduating with 15 ty of Oxford's Hall of ours in and has been an honorary fellow of College. 1m 1976 and 1980, Khan was awarded The Cricket Society Wetherall Award for being the ading all-rounder in English first-class cricket. In 1983, he was also named Wisden Cricketer of the Year i In 1983, he received the president's Pride of Perform: ce Award Sussex Crieket Society Player of the Year n Cricket Cricketer of the Year Kistan's civil award, the Hilal-i-Lmtiaz for being the only Cricket ¢ 2004 Asif Forel Jnead for many international charities and working hard In 1992, Khan was giv‘ Captain who Jed us in World Cup vie On 8 July 2004, Khan was awarded the Lifetime Achievement Award at Awards in London, for "acting as a fig -raising activities." On 7 December 2005, Khan wa appointed the fifth Chancellor of the University of Bradford, where he is also a patron of the Bom in Bradford research project On 13 December 2007, Khan received the Humanitarian Award at the Asian Sports Awards in Kuala Lumpur for his efforts in setting up the first cancer hospital in Pakistan. On $ July 2008, he was one of several veteran Asian cricketers presented special silver jubileejonal Cricket Counci .entennial year celebration, Khan was one of fifty inducted into the ICC Hall of Fame. Jinnah Award. 012, d an honorary fellowship by the Royal College of Physicians of Edinburgh in recognition of his s for cancer treatment in Pakistan, Center, seven out of ten Pakistani respondents offered favourable opinion about Khan. The survey also revealed that Khan enjoys popularity among th. /s Person of the Year 2012. In December 2012, Global !Post ranked him third in alist of the top nine world leaders. Publications/Books Khan, Imran & Murphy, Patrick (1983). Jmran: The autobiography of Imran Khan. Pelhiam Books, Khan, Imran (1989). Imran Khan's cricket skills. London: Golden Press in association with Hamlyn Khan, Imran (1991). Indus Journey: A Personal View of Pakistan, Chatto & Windus. Khan, Imran (1992). All Round View. Mandarin, Khan, Imran (1993). Warrior Race: A Journey Through the Land ofthe Tribal Pathans. Chatto & Windus. Khan, Imran (2011), Pakistan: A P nal History, Bantam Welfare activities Duri 1990s, Khan also served as UNICEF's Special Representative for Sports and promoted Pakistan, Sri Lanka and Thailand. While in et char health ar immunisation programmes in Banglades also works with the Lord's Taverners, a cricl London, bi Shaukat Khanum Memorial Trust; Khan founded first and only cancer hospital, constructed ‘and running off international and national donations/charity collections with unprecedented history of success. Namal Knowledge City; Khan established a technical college in the Mianwali District called st (M yT), anil is an associate e. It was built by the Mianwali Development ¢ University of Bradford in December 2005.which has provided an oppurtunity to the poor most Pakistanis to earn a degree of United Kingdom only on merits which will hugely shrink the gap between the rich and the poor. 0% Pakistan. It has provided help to flood victims in Pakistan, Buksh Foundation has partnered with Imran Khan Foundation is another welfare work, which aims to assist needy pe ion to light up villages in Dera Ghazi Khan, Mianwali and Dera ismail lish several Solar the Imran Khan Fo Khan under the project ‘Lighting a Million Lives’. The campaign aims to Charging Stations in the selected off-grid villages and will provide villagers with solar lanterns, which can be regularly charged at tations b) That due to the honesty and dedication towards his political cause the Defendant has gained° 8) 2 vptnesed an unprecedented voters trnut, Surprisingly the results came afr 21008 delay va hese was hus and cries of serious mismanagement and rigging every Wherein Pakistan by the members of ll politcal pans aross the board This act of treason against the people of Pakistan was challenged in the Cours of Law and El jon Tribunals along with complete politcal analysis by renowned Journalists and ote namely Mubashit Lueman, Dr Shahid Masood, Hassan Nisar, Nizami and many others. Furthermore the entire political seisis was supported by video evidence and eye witnesses, It had become @ common knowledge of whole of Pakistan when the Defendant and his Par éemanded recount with NADRA verification of the thumb impression of Four Constnuencies which was denied ‘without any just exeuse and st ipjected to lengthy procedural delays of our Judicial system. Thereafter left wit no other choice and following the build up on the media and other evides ce coming in through various other sources the Defendant launched his historical movement of GO NAWAN GO with compete success which was a repeat of Independance movement when Majority of the Muslims rallied behind M. A Jinnah later named as Quaid e Azam. “The alleged contemaory statement were made in the publi interest 15% fair manner and in mo way were assertions of facts. In fact the same were made 0 safe guard the interest of the general public, It was aimed to highlight the dishonesty of Status Qua forces in the light of the evidence being show through various modes and mediums ‘That the Defendant gained Knowledge throu different modes of media and following the top political analysts of Pakistan both Journalist and others henee with the back drop of eoowledge with his role as a Public Figure, being a Chairman of a strongest Political party iB the onus was on sm to inform the public honesly of what be has eared wi the sanction sf slam and the consttton, Its pertinent to menton that the Defendsnt afer learning biter th tha the entire sytem of Pakistan was in contol of the StS (Qua forces was left vin hee coe than o rely on he Mediaan he people ofPakisin, Howey: by doing sohe did notintend ultany ones integrity apart from the individuals olin! Character ‘as a public office bearer only. ‘That in various recent Judgments passed by the Election Tribunal the version o Defendant has been acknowledged and proven however the ‘Appellate Court is yet adjudicate upon it “That the demands of the freedom of speech and expression along witheigtt of information, are a Fundamental Rights which is to allow Political Leaders/Public interest groups, to have right to Free Speech and no law should be allowed to intimidate any public figure. As the Defendant is in active politics himself Chairman of the fastest growing Political Party of Pakistan. On the other hand the Plaintiff do not enjoy an angelic reputation (fact as stated by Dr. Shahid Masood oring his TV show forming pert of this instant plaint).» “That the Plaintiff was not commented upon in his capaci asa Joumalist but when e pl snot suffered in any manner ashe is running a successful TV he was appointed as a Care taker Chief Minister; holdin a public of not hide or immune himself against political erticism 0S stated in Even otherwise sow and his magazines along with an additional gift charge of Pakistan Cricket him by the present PML N regime; to Board Management has been entrusted up\ Honour his Neutral and Honest role as a Caretaker CM Punjab or fo rthe reasons mation no adverse affect has best known to them. Albeit due to the alleged def been caused to his reputation or finances nor has the plaintiff presented any tax sn on loss of income as alleged in the plaint. More over in English Common Law Case of 1866 (Kelly vs Sherlock LR.1 0. B. 689 it lds urns to substantiate his ter of Public interest “the public conduct of one Wh was observed that Mi or position of trust, ‘One who undertakes 10 fil a public or seeks a public of office offers himself to public attack and criticism, and it is now admitted and recognised that the public interest requires that & man's public conduct shall be criticism’ defendant does not comprise of the necessary nation. ed on by the defendant who has a keen has ssues of Pakistan for obvious reasons. The Plaint nti Pakistani agencies (the RAW ete) and his historically been acoused of h ja matter of common knowledge which he has Rever officially role in Balochist denied and his mysterious claim of having an informer (meri Chyria) is also « of the secret agency best known to, the plaintiff. commonly known to be 0: Furthermore, neither the words of the statement made by. the Defendant are ner, There is ample amount of evidence defamatory nor derogatory in any mi which could show the conduct of the Plaintiff in generating opinion for or against any one of his own choice, forthe reasons Best known to him. The defendant on rood by what he has believed to be true and this is the the other hand has always sole reason why he has gained a sjature of Pakistan at this time. “That the Suit is lible to be dismissed as it has been filed on the basis of personal grievance st the Defendant. It is nothing more than a feeble atemt to inte chnicality. The Defendant is a shining | and malice reer of the Defendant on a mere the politi ation and the most powerful and respected leader oF the Beacon of Hope for this youth of Pakistan which comprises of more than 50% of the total population as anyPakistan, 5) That the presen cases against he spirit ofthe Article 10 A, the Fig of Fair Trial will not be guaranteed as no Sexret Agency has een made the party 10 this Suit whom BS 1 possession of the entire fe history and gains of th Paint inching the Tex evasions of Overseas properties and dealing et. x) That comparatively in most developed countries, a combination of discouragement 10 “enaious gation and sometimes formal defnition ofa sategc lawsuit aginst pub pantipation, sent fo it politically motivated ibe suis, Many attorneys aise strongly against fling any suit against ries with poiieal motivations, The MeLibel ease is usually cited as libel lave backfiring. 1) That also in other common law history, foriegn jurisdictions have established such difficult tests for application of libel law to political statements, even exemPHDE specific types or processes of criticism, that any specifically or overtly political comment has been effectively exempted from tort law, Following is a short summary of international law of defamat American cours reformed libel law to protet fee speech on matters of Pub ic interest, where plsins bear ons of proving falsehood, fault and damage All aterenis of opinion are immune from liability. This includes almost all political statements. In Australia the traditional common law was deemed to be ‘wilted too far against free communication.” and courts recognized privileges for politcal discussion and eventually @ new 2006 uniform Defamation Act in Australia. {1 2001, the British House of Lords recognized in Reynolds v Times Newspapers Lida new test for a case-by-case privilege for publications which, though otherwise actionable, dealt with ami of public concem in a manner which was easonable and alan ed in all the circumstances. They recognized an obligation to protect journalism | New Zealand's Defamation Act includes @ qualified privilege Jor non-reckless and non- sentimental statements about political figures. Inc historical casw of McDonald's Corporation » Steel & asthe MeLibel case” was an English lawsuit for libel fied by MeDo Corporation senvizoamental activists Helen Steel and David Mortis (often referred 1035 "The MeLibe! Two") over a pamphletertial ofthe company. Each of twohearings in English cours found some of the contested clams to be libelous and others t9 be tue. The partial nature of the victory, the David- veGoliah nature ofthe ease andthe drawn-out iigaton embarrassed MeDonalds. AS it seam te longest runing cas inthe hist of English Legal Syste, Finslly ie EU on the 15 rebeuary 2005, the European Court of Human Rights ruled het the oFiina case had breached aciaan ign en Sin id Aetele 1h dca Dla tape? of the European Convention on Human Rights and ordered thatthe UK government PSY Stee] and Mortis £57,000 sn compensation. In their ruling, the ECHR criticised the way in which UK laws had filed tothe enviro ney also ruled that the trial was bias use of the defendants’ comparative they believed were complex and oppressive UK libel laws. “ty particular the Court held that in a democratic soeiety even small and informal campaign groups, such as London Greenpeace, must be able to carry on their activities effestly ely and that there exists a strong public interest in enabling such groups and individuals outside the mainstream to contribute to the public debate by dissemin: .g information and ideas on matters of general public interest such as health and the environment" (para, 89). "The safeguard afforded by Article 10 to journalists in relation to reporting on issues of general interest is subject to the proviso that they act in good faith in order to provide accurate and reliable information in accordance with the ethics of journalism (..), and the same principle rmust apply to others who engage in public debate." (pars. 90) - "Iti true that large public companies inevitably and knowingly lay themselves open to close serutiny of their acts and, as in the case of the businessmen and women who manage them, the limits of acceptable criticism are wider in the case of such companic n Pakistan no reported case against political leaders under defamation law was found In Pakistan no reported case against political leaders under CSTamANOR SSS however the Supreme Court view on Constitutional rights is as follows: 1m) That in Pakistan the Honourable Supreme Court of Pakistan in 2014 PLD 367 has some fendant was tried as the what taken a similar view as mentioned above wherein the same Def Contemnor where the proceedings of Contempt of Court was i INSTITUTION the Honourable Judge took a linent view and held ‘that the word (used by the alleged contemnor was prima fi , uttered by him in a different sense and context which was viewed as a derogatory and insulting remark for the judiciary as an tution a Alle ‘and duly elected member of the Natior contemnor was a public figurs Assembly, who had been ly involved in politics for a long time and was also the Chairman ofa politcal party and in such circumstances, while considering his conduct, the Court could not lose sight of the provision of Article 19 and 66 of the Coritiution relating to Freedom of Speech and Privilege of the Member of the Parliamer —' Supreme Court also admitted the immunity ofan action against the Public figure but also wamed against the added responsibilty of watching out forthe integrity ofthe Institutions of Pakistan. 1) That a similar view was taken by the Supreme Court 2012 CLC 714 wherein is held that Ast 19- Freedom of Spees vrecion at merely to protect as, conduct and views hat one may approve offGSeo and especialy, to protect views with which one may disagree or which even find unpleasant or unacceptable ---~Expression of views ata political meeting is one for of Speech and aniele 19 of the Constitution not only protect Speech that the listener may approve of or agree with, but also speech that he may disagree with or even hate ¢) That n-2010 SCMIR 1849 it was held on a similar tone while interpreting the Aries 19 Role Weight = and infremtion=- Flectronic media~expression and of press as guaranteed by Art. 19 of the Constituion ~Equally important, if not more, the right of every citizen to have access to information in all matters of public important as guaranteed by provisions aof Art. 19-A of the Constitution p) That in the Preambles of the Constinti 1 it appears that “Dedicated to the preservation of democra achieved by the unremitting struggle of the people against oppression and tyranny,” Therefore to decree this suit in favour of the Plaintiff i against the Law of this Country q) That the injunctions of Islam provides Honesty to be the most important element of its believerifollowers and impose worst consequences for those who are dishonest therefore it is common knowledge forall thatthe elections were rigged and Cheif Minister holding a public office cannot hide away from the critical consequences ofthe out come of his duty 10 the nation. PARAWISE REPLY ON MERITS ‘That the contents of the para under reply are neither denied nor admitted due to want of knowledge andthe plaintiffs required to prove the same. Its further stated thatthe contents are merely self appraising and not relevant to the instant suit. Its a matter of fact that the plaintiff claims to have an informer who leaks some times confidential information and tries to formulate public opinion and curb same in favor of one or the other political party or group for the reasons bet known to the plaintiff, himself as claimed by his counter parts, Furthermore he has an history of being accused as an agent working against our national interests hence his credibility as a patriotic Pakistani has @ big question mark, rhis fact has been propogated by his fellow journalists. “That the contents of the para under reply are neither denied nor admitted for want of knowledge the same may be required to be proved by the plaintif. “That the contents of the para under reply are denied nor admitted for want of knowledge and the plaintiffs required to prove the same. It's pertinent to mention here that defendant has politically he luxuries, the life offered him for the betterment 14 for almost two decades leaving all of the poor people suffering Pakistanis citizens, hence his entire struggle has been against the highly corrupt and discriminatory system of goverament which has bestowed so graciously decorations of honour upon the plaintiff who is one of the most powerful journalist cont influencing the entire system, “That the contents ofthe para under reply are neither denied nor admitted for want of knowledge for the reason reiterated herein above. “That the contents of the para are denied being false and incorrect, That as mentioned above in the preliminary submissions the defendant is himself a world celebrity and connected tothe rich andthe world contribute towards the social causes and political causes he is pursuing, © That the conte ofthe para under reply are denied except that he had served in the public offices appointed by the partis of the status quo whom against the defendants has raised the strongest voice in the contemporary political history of Pakistan and is humbly not be the test of iniegrity in a country which is ranked highest in comruption by international observers. Admitted, However the plaintiff has narrated a very conservative view of the success of the defendant in his individual capacity and as a social worker and politician. “That the contents of the para under reply are vehemently denied being false and incorrect e5 the defendant has no personal grudge against the plain, cis fact is evident from the past as the defendant and his party had raised no objection fr the appointment ofthe plaintiff sa caretaker chief minister of the Pinjab during the lat general election of 2013 however it is pertinent of mention here that the defendant has much bigger concems than to worry about one local anchor/political analyst. “That the contents of the para under reply are denied being false and self made importance syndrome as the defendant isa highly educated person who has launched his propaganda against the owmer of GEO Mir Shakeel ur Rehman an this instant suit just to harass and intimidate the defendant by scaring him from freely exercising he plaintiff being part of GEO network plotted his ight of freedom of expression and information and infact the arguments Put forward by the Pant are repeated against him by the defendant who i an establish politician and leader of the mases in Pakistan, More over the defendant never defamed plaintiff as a newsman but only in his role as a Chief Minister a public officer answerable to the people of this Country and the defendant being the most favourite and credible leader representing the people of Pakistan has every right to question his office and use decent language like 35 Puncture which is not an abuse o fou its just an expression which suggest that the Plaintiff has his hand diy in the electoral process by misusing his authority in favour of the present regime as suggested by political analysts and other sources as discussed in media etc. “That ihe contents ofthe para under reply, the subject publications artached as A 10 4 are denied being false and non verified an ihe same cant be relied a5 auhenti evidence. More ove hs cemmpet senaro and context ofthe allege statement has been concealed, That the defendans thas no grudge personal as he is not a competitor forthe post of Chairman of PCB therefiong ere ie no cause to undermine the reputation of plaintiff. I is also needful to mention that the protest was raised solely for the purpose of rlsing the voice in the interest of the publica large forthe seca reiterated ersnabove in the prelinnary objections and submission, over the elestoral eam engineered bythe status quo partes n connivance withthe plalntifwhe was maior responsible of facilitating the entire eleetion process being the head of the administration machinery ofthe province Also tat the statement was made with good fith and was 8/8 comment with out any malice as evident now from the recent events leading (0 the establishment1s. fessions of the members of the NADRA and Election Commission with video evidences, ‘That the contents of the para under reply are denied forthe reason stated above the preliminary submissions and objections. In fact the last sentence of this instan ara is an admission by the plaintiff of the hope and con ict of the defendant and the trust he placed in the plaintiff who has contradicted his own case that the defendant had any kind of ill feeling against him as itis a matter of record that the defendant welcomed a honest and credible care taker chief minister till the actual aftermath of the historically rigged elections as evident now from the judgments of the Election Tribunals and Judicial Commission, Further more the entire stance of the defendant is thatthe status qua fordes including all the political parties mentioned in this Para are publically accused by the defendant to be involved in a set up wherein they have exchanged turns to rule and plunder Pakistan, Also it is a matter of common knowledge that the political parties re not free from corrupt practices and have beaten the Judicial system in several cases to hide their corruptions scandals, Hence their appointments may not be solely based on integrity as claimed by the Plaintiff. That the contents of the para under reply are admitted as it is a surprise that a non cricketing person is heading the most important youth sport of this country and as evident from our worst world cup defeat in 2015 that the management has failed in their task and the judicial scandal arising out and challenging the removal of the former chairman further s ;pports the contentions of the defendants where it was observed that the present regime fully backed their decision to support the plaintiff against any eventuality. Also it is a matter of record that the plai basically thought to be failed manager by the PML N in Balochistan conspiracy and now he has become their top most manager for the reasons best known to the plaintiff as discussed by Dr Shahid Masood in the evidence attac .ed with this plaint which may be read asian integral part of this reply.. however the fact that the plaintiff is taking no money for the job'is denied as the plaintiff is required to proof the sa jing his tax returns where in he has been accused evasions in the past that the defendant had the exte at the contents of the paragraph under reply made any malicious allegations against the plaintiff for the reasons reiterated above. As a matter of fact the matter is subjudice and there has been much more than 35 so called rigging in the ywever the plaintiff is a public figure and has every right to criticize the < ‘That the contents of the paragraphs under reply are denied being concocted and false in factthe provitice of Punjab he conduct of the plaintiff in his capacity of holding a public office. defendant has never received any notice of demand nor has he had any media dialogue with the plaintisf on any news channel. In fact as reiterated in the preliminary objections and submission s suit a fact which is evidence above the plaintiff has not made the real originator as a party to th from the evidence relied up by the plaint ‘That the contents of the paragraph under reply are denied for the reasons stated herein above.19, reputation of integrity and honesty which is a dream achievement of the youth of Pakistan who has sacrificed his family life and luxuries of life for Pakistan's betterment hence he has every right and autho: y allegation of estowed by the people to raise voice against corrupt practice for informing the masses nd changing the corrupt system for the enfor of Islamic Rule of Law, That the maliciousness attributed towards the defendant in this paragraph under reply for the reason stated herein above. The defendan good faith -omment in the interes of the public rights an Constitution to address his political followers and supporters (party members) in a political meeting which in this modern age, with the advancement in technology, may be in his own WhatsApp group , Twitter Group , Face Book Group and or in a street, park, television, telephonic and so on, whether liked or hated by the Plaintiff and his allies (as held by the Superior Courts) ‘That the contents are vehemently denied as the defendant has never heard or knowledge of any Such notice or tis Sutil the time of moving the Application to setting aside Exparte proceedings in this Suit, ‘above mentioned sources as a necessary party to this suit in malice and ulterior motives or with the fear of any other consequence best known to him, ‘That the contents of para under reply are denied vehemently for the reasons stated in the above Paragraphs. In addition it will be inthe interest of justice and fair play to join a8'a party or _ summon the above mentioned and others through cour, or otherwise; to establish the auther of the alleged defamatory statements which in reality is just a fruitless exercise being against the democratic pi iples and constitution which will just hinder the process and create a vacume of serious leadership which has emerged after decades of corrupt hegemony. ‘That the contents of the answering paragraph are denied for the reason reiterated above in this reply. Hence the same must be read as an integral part herein, That the contents of the answering paragraph are denied, being a mere repetition of the above, this reply. Hence the same must be read as & Tregral similary for the reason reiterated above part herein, ‘That the contents of the answering paragraph are denied, being a mere repetition of the above, hence for the reasons mentioned above are reiterated. In fact no injury has been cause to a holder of public office for any allegation of rigging which is presently subjudice and even otherwise in the interest of public, Therefore the entire claim is denied being unlawful, falseagainst public interest and vexatious.the contents of the answeri no causes o} the reasons stated above in this reply De mentioned has been adjudicated in favour of the defendant as stated above, the Superior Judges had initiated a he protection of an institution and infact Political Figure who is re took a lenient view and ex; nting le for th y of this great nation, Hence the outcome of the -ge and is respor dismissal of this present suit, n case only sets a ground f evant. Denied, the Azadi March has passed and this paragraph needs no reply being Denied fant is in Islamabad which is a common knowledge hence this Suit he residence of De! lacks jurisdiction and is liable to be dismissed. required to be The entire praver clause is denied for the reason mentioned herein above, being against the “Antorest of justice, ited TED thatthe Plait ns given above, isn ‘eared Court may be with special y relief sought in the instant suit and snsatory costs in terms of S ANY OTHER ORDER that is Learned Court may deem appropriate under the facts and circumstances of the case may also be passed, \pomutauen estates co pee VERIFICATION; \VERIFIED on oxth at Lahore, n his 2 day of MAY 2015 ht the content of his reply ae fut and correct othe bet of my knowedpe and the 2b are bleed tobe rae upaithe nformation recived