1. The “Guardian” (News Paper) through its Publisher,Kings Place, 90 York Way,
London N1 9GU, United Kingdom.
2. The chief editor of the “Guardian”,
Kings Place, 90 York Way,
London N1 9GU, United Kingdom
3. Decian Walsh (the reporter/author)
Kings Place, 90 York Way,
London N1 9GU, United Kingdom.
SUBJECT:
Sir/Madam,
Under the instructions of All Pakistan Muslim League through its Secretary General Barrister Muhammad Ali Saif, having its office at House No.1 Street 37, Sector F-6/1, Islamabad, Pakistan (here in after referred as my client) I do hereby serve upon you this legal notice to the following effect.
1. That it is to be read as the legal notice issued in context and reference of a news item published in the news paper namely Guardian on the 9th day of May 2011 (copy of the internet version is enclosed herewith).
” between the Ex-president of Pakistan and now head of APML, Mr. Pervez Musharraf and former president of USA Mr. George W Bush somewhere in 2001. permitting a US operation against Osama Bin Laden on Pakistani soil similar to the last week raid, that killed the Al-Qaida leader”. Further that “2. That in the said news item it has been alleged that “USA and Pakistan had
3. That the said news item is believed to be absolutely false, frivolous, and fabricated and published as part of the vilification propaganda campaign aimed to harm, defame, and denigrate the reputation of my client, by publishing false and fabricated news item against its head Pervez Musharraf, the Ex-president of Pakistan.
4. That the said news item has been published without corroboration and counter checking of the facts and on the basis of foul remarks passed by some unknown US and Pakistani serving and retired officials.
5. That the falsehood and fabrication of the news item is so evident that even the ranks of these so called officials have not been disclosed what to talk of names and their designations.
6. That the said news item has been published with malafide intention to malign two former presidents including the head of our party to achieve malicious objectives of the enemies of Pakistan and world. It would be benefiting to mention that any person of common prudence would know that every state work within the ambit of certain national and international law(s) that provide certain modalities and mechanisms for the creation of agreements and treaties between the sovereign states and there is no room for any individual personality or personalities to enter into verbal secret deals on behalf of their states. Further this news item has not only damaged my client’s reputation but it has also established a ridiculous impression that as if Pakistan and USA both states work beyond the sphere of their domestic laws as well as the international law.
7. That the publication of the said news item, without verification and without getting clarification or counter comment from my client or from the offices of respective presidents named in the news item, amounts in irresponsible, unprofessional, and willful illegal act. It is pertinent to mention here that neither the reporter/author nor the editor or publisher, checked the varsity and authenticity of the substance and the source(s) and proof(s) of the news item as published in the Guardian on 9th of May 2011 and willfully ignored their prime most responsibility to give credible information to their readers.
8. That the said news item is published to threat, damage and defame my client to decrease his popularity and damage his reputation to the extent of worst. The publication of this news item is a gross insult to the standards of professional journalism as well as the Defamation Ordinance 2002.
9. That this news item was published as leading story all major Urdu and English News papers in Pakistan and all major news channels aired programmes and talk shows on this false and fabricated news item. The publication of this false and fabricated news item has indeed provided an open chance to the political opponents to initiate disparagement propaganda against my client and its leader as well as fierce criticism and hate from public at large within and out side Pakistan.
10. That my client’s political philosophy pivots around the slogan “Pakistan First” whose members hold nothing prior to Pakistan and they always be even ready to sacrifice their lives for Pakistan. The publication of the said news item caused immense damage to the reputation of my client as a patriotic and dedicated Pakistani political party.
11. That this news item has been reported by Mr. Decian Walsh from Islamabad, Pakistan, therefore he is primarily responsible being “author” of this false and fabricated, defamatory news item that consequently damaged the reputation of my client as a political party headed by Mr. Pervez Musharraf.
12. That my client insists from the Guardian to publish an un-conditional public apology on the first page, for publishing false, frivolous, and fabricated news item against head of All Pakistan Muslim League, Mr. Pervez Musharraf and consequently damaging the reputation of my client.
13. That my client demands 5 Million US dollars as compensation for damaging its reputation by publishing false, frivolous, and fabricated, news item against its head and consequently damaging the reputation and lowering the popularity of my client with in Pakistan and in the world at large including United Kingdom.
14. That my client reserves legal right to initiate action under the law in the Court of competent jurisdiction in case of non compliance of above mentioned demand.
All Pakistan Muslim League
Through;
FAISAL FAREED HUSSAIN
Advocate High Court
[email protected]
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