Bakhtawer Khan

Attorney At Law

Office Address

Contact No. _____________ Email Address: bakhtawerkhanashraf@gmail.com

No__________ Dated: July-24th-2022

On behalf of,

Muhammad Iqbal Sher S/o Sher Muhammad,

Muslim, Adult,

R/o House No. 12, Street No. 02,

Bahria Housing Scheme, Lahore

To,

Aryan S/o Muhammad Shayan,

Muslim, Adult,

R/o House No. 90, Street No. 08,

Saddar Karachi.

Subject: LEGAL NOTICE

That I have been instructed by my client namely Muhammad Iqbal Sher S/o Sher
Muhammad, Muslim, Adult, R/o House No. 12, Street No. 02 to serve upon you the reply
of legal notice for defamation on the following legal grounds

1. That my client is a respectable citizen of this country. He is enjoys a good reputation,

command, and great respect amongst the family, friends, colleagues, and locality as well
as the community. My client is having great respect, dignity, and prestige in the area and
also having a blot-less career throughout his life.
2. That my client Muhammad Iqbal Sher is an anchorperson of a renowned political
talkshow. On 20 July, 2022, during live transmission of his talkshow, Muhammad Iqbal
Sher alleged that “Aryan is a corrupt politician as he misappropriated the public funds
 and thereby breached the trust of his voters.” As a journalist it is his duty to furnish and
publish any authentic statement is said for the benefit of the public. By issuing such
statement he only performed his duty.
3. That my client denies the allegations against him in para No.3-6 of legal notice dated July
24th ,2022.
4. That the statement issued by Muhammad Iqbal Sher was actually an exercise of his duties
and was issued in the public interest. A free press can inform citizens of their leaders'
successes or failures, convey the people's needs and desires to government bodies, and
provide a platform.
5. The freedom of media literally translates as “the right of newspapers, magazines, etc., to
report news without being controlled by the government”, If my client faces defamation
on mere exercise of his obligations. It will be against the principles of natural justice.
6. That the Imputation of truth which public requires to be made or published: It is not
defamation to impute anything which is true concerning any person if it be for the public
good that the imputation should be made or published. Whether or not it is for the public
good is a question of fact.In this case my client stated the obvious truth and is willing to
prove that.
7. Furthermore, my client is facing continuous mental torture, harassment, and fear from
Mr Aryan and his followers. My Client was only following his professional conduct, and
any statement made to Public conduct of the public servant does not amount to
defamation.

8. That my client is mental torture, agony, financial loss, and injury inflicted to his
reputation, the political pressure on my client’s employer caused him to lose his job and
no other news channel is willing to hire him. In an attempt not to anger Mr. Aryan.

9. That my client acted in fairness and had not malice by issuing that statement.

That in light of foregoing, you are hereby called upon to recall your legal notice dated
July 24rth, 2022 as the complaint of your client is not lawful.

Bakhtawer Ashraf Khan

(Counsel for Plaintiff)