1. Nabiha Meher Shaikh, ADDRESS DELETED
2. Ahmad Yusuf, ADDRESS DELETED
3. Urooj Zia, ADDRESS DELETED
BY COURIER, EMAIL, HAND AND PUBLICATION ON THE WEB
SUBJECT: LEGAL NOTICE
I act on my own behalf and address the following legal notice to you:
1. That you are continuously carrying out a malicious campaign of propaganda against me with mala fide intent claiming falsely and without cause that I incited three people i.e. Mr. Ali Azmat, ,Mr. Shemrez Nauman and Mr. Raza Ahmad (Rumi) to indulge in inappropriate and forcible sexual activity i.e. rape or collective zina-bil-jabr with one Nabiha Meher Shaikh. This terrible travesty of the truth has been perpetuated by your good selves through Twitter- a microblogging site-, via mass emails and orally. Evidence is attached herewith as Annex-A to this legal notice. The allegation is – needless to say - untrue and false and what is more that you are well aware that the allegation is entirely untrue.
2. That as a respectable citizen of society, a published author, a lawyer and a consultant, my reputation has been irreparably harmed by your actions and hence this legal notice has been addressed to you.
3. That through this legal notice, under the Defamation Ordinance, 2002, I call upon you within fourteen (14) days from the date of this legal notice to:
a. cease and desist from any and all such claims immediately whether electronically or orally;
b. delete all tweets to this end on the aforesaid microblogging website;
c. publish a retraction and an apology of equal prominence through the aforesaid microblogging site and in writing to me both via email and courier;
d. pay a sum of Rs. 500,000, each, to me as compensation for the mental anguish and loss of reputation (a detailed breakdown of this compensation shall be provided for as and when requested); and
e. inform me why you should not be proceeded against in an appropriate court of law of competent jurisdiction.
Please be advised that all these actions are sine qua non to each other for a settlement outside the court and to be deemed the irreducible minimum to this end.
4. That the failure to do the aforesaid will leave me no option but to proceed with appropriate legal action under the Defamation Ordinance as well as to move the court for any and all remedies, criminal and civil, available to me.
5. That I reserve the right to make Mr. Ali Azmat, Mr. Shemrez Nauman and Mr. Raza Ahmad (Rumi) as parties to any legal proceedings as they are also adversely affected by your propaganda. Any settlement with me as a consequence of this legal notice shall be without prejudice to their rights which have also been infringed upon by your unfortunate and callous actions.
6. That a copy of this legal notice is retained by me in my office for the purposes of further legal action.
Yasser Latif Hamdani
(Advocate High Court)