Cr. Complaint No 61/2011

Ms. Atiqa Odho

Wife of Javed Akhund

Muslim, Adult,

Office at F-3, Plot No.7-C,

Zamzama Commercial Lane-2,

Phase-V, Defence Housing Authority,

Karachi.................................................................................Complainant

Versus

1). Iqbal Aftab – TV Anchor,

Journalist & Column Writer

C/o. Geo TV Network

2). Mumtaz Gohar Wattoo

Director of Khabarnak

C/o. Geo TV Network

3). Azhar Abbas

Managing Director,

Geo News

4). Imran Aslam

President Geo TV Network

5). Shahbaz Safdar Ali

Senior Producer of Khabarnak

C/o. Geo TV Network

6). Mir Shakil ur Rehman

Founder: Geo TV Network

Office at: 7th Floor,

Landmark Plaza,

I. I. Chundrigar road,

Karachi......................................................................Accused Persons

Cont’d.............P/2

P/2

COMPLAINT UNDER SECTION 499, 500 & 509

OF THE PAKISTAN PENAL CODE 1860.

It is respectfully submitted on behalf of the Complainant above named as under:-

1). That, the complainant is a media personality, businesswoman, social activist and political reformer. She has been a household name in Pakistan since 1991, is a media personality. She is currently CEO of two companies under the Odho banner: Odho Productions & Odho Cosmetics. Furthermore, recently, the Complainant has joined a political party by the name of All Pakistan Muslim League as Communication Adviser.

2). That, the complainant has an established name and prestige within and outside the Pakistani community as a respectable woman who has been and continues to work for the betterment of her home country and its people. A summary of her countless contributions defining her idiosyncratic personality to date are as follows:-

(a) In the year 2008, she launched her own people's movement, "Our Country Our People-OCOP" which has worked for the Swat cause, 2010 flood relief efforts and has in February 2010 launched the Jacobabad revival project.

Cont’d.............P/3

P/3

(b) Ms. Odho's production house, Odho Productions has been producing television programming / software for all Urdu speaking mainstream terrestrial / satellite television networks airing within and outside of Pakistan. The products developed and aired by Odho Productions are focused on strong social messages with the consideration to reform media towards becoming the true social conscience of Pakistani society as it is meant to be.

(c) Besides her media work, Ms. Odho has travelled extensively all over Pakistan to promote the values of financial and emotional empowerment of women through many public gatherings by socially networking career women with younger ladies wanting to come into the work force.

(d) In the year 2006, Complainant started to support the Shaukat Khanum Memorial Cancer Hospital (SKMCH) in its fundraising efforts and became its breast cancer awareness program's (wings of hope) Brand Ambassador a year later. The SKMCH breast cancer awareness campaign is active each year in October (International breast cancer awareness month). The complainant contribute her services for awareness and fundraising activities for the cause each year full priority in the hope of saving as many lives as possible by educating people about the disease as Pakistan has the highest incident of breast cancer in Asia.

(e) Besides SKMCH, Complainant has supported the Fatimid Foundation, national Polio awareness program, Green Star family planning project and is now endorsing Pfizer in its fight against pneumonia in children (the forgotten killer).

Cont’d.............P/4

P/4

(f) The Complainant has been the brand ambassador for many multinationals by endorsing their products through advertising as well as hosting their television and live shows for the last two decades. Some of the company names are, Uni-levers, Nestle Pakistan, Telenor, Suzuki Pakistan, PTCL, Pfizer, Citibank.

(g) In 2009, she was asked to and wrote the media and broadcast paper for the Planning Commission of Pakistan, 10th- 5 year plan.

(h) The Complainant is invited to many international business and media related forums (Saarc economic forum / Ficci Frames, WISE) as a guest speaker from Pakistan to share her years of experience as an entrepreneur and media icon. She attends such forums with great pride as she represents her country as its ambassador.

3). That, the complainant after her countless social contributions, became a political activist and quote “For years I worked in the social sector not realizing that I was dealing with the symptom of bad governance in Pakistan. Today, I step into the world of politics hoping to prevent the ills that our society suffers from through empowering the political arena to do what it must, serve the people-Atiqa Odho." Thus the quote clearly shows the candid intentions and high moral values of the complainant mentioned herein.

Cont’d.............P/5

P/5

4). That, the accused persons herein are part of a TV show named ‘Khabarnak’ that is aired on Geo news channel every Saturday and Sunday at 11:05pm and repeated at 04:05am and 2:05pm. On 23/01/2011, the show ‘Khabarnak’ was aired as scheduled on 11:05pm. In this so called veritable “gossip column of talk shows”, at 11:23pm, the accused persons, despite being aware of the complainant’s contributions to this country and her maintained goodwill, crossed the limits by making a personal attack on the complainant’s esteemed and reputed personality. The conversation between the anchor and the dummy Pervez Musharaff was going as a comic until it got derogatory and an aspersion was made on the complainant’s integrity as a political activist. The comments followed by an actor present at the show were purely personal attacks. For the convenience of this Honb’le Court, its Urdu version is reproduced hereunder:-

Cont’d.............P/6

P/6

5). That, the life of Complainants family has been disturbed and their privacy invaded by the comic T.V show aired by the Accused persons representing the Complainant as a downgraded woman having an unchaste personality. Furthermore, the Accused persons portrayed the Complainant’s political life as ‘Personal Property’ of the party head. Due to this, the Complainant have been going through immense mental tension and pressure as she is unable to reconcile the bad image depicted by the Accused persons and is thus unable to face her family, friends, international forums and the society at large with dignity/integrity which is a major trait of the Complainant’s personality.

T.V show promotional advertisement is annexed as ‘A’

6). That, the freedom of expressions adopted by accused persons has crossed the limits of decency and morality. The accused person violated the rights of a woman recognized by law and principles of Islam. Furthermore, the words used in the TV Show have offended the dignity of person /man which is a fundamental right of every citizen of the Country. Right to good reputation is supreme in Islam.

7). That, the State has failed to discharge its constitutional responsibility to protect the complainant in particular and women at large from the naked invasion on their rights perpetuated by accused persons.

Cont’d.............P/7

P/7

8). That, it is submitted on behalf of the complainant that the accused persons have committed criminal defamation as stated under Section 499 of the Pakistan Penal Code. Not only was defamation committed but was also broadcasted to millions of viewers around the globe. The complainant also submits that the accused persons have insulted her modesty as a woman by uttering words that intruded upon her privacy and damaged her reputation and integrity at local and international level which is also an offence punishable under Section 509 P.P.C.

PRAYER

It is therefore prayed that this Honb’le Court be pleased to take cognizance of offence and punish the accused persons as per law.

Complainant

KARACHI

DATED:01.02.2011 ADVOCATE FOR COMPLAINANT

V E R I F I C A T I O N

I, Atiqa Odho W/o. Javed Akhund, Muslim, Adult, resident of Karachi do hereby state on oath that whatever has been stated herein above is true and correct to the best of my knowledge and belief.

D E P O N E N T

Identified by me.

A D V O C A T E

Solemnly affirmed on Oath before at Karachi on this 1st day of February, 2011 by the Deponent above named who is identified to me by Mirza Tauseef Ahmed Advocate, who is personally known to me.

COMMISSIONER FOR TAKING AFFIDAVIT

Atiqa Odho Cr. Complaint