SHUJRA, FAROOQ & HASHMI

Advocates and Legal Consultants

Malik Sohail Ashiq Shujra Muhammad Ali Farooq Zeeshaan Zafar Hashmi
Advocate High Court Advocate High Court Advocate High Court
Barrister-at-law (Lincoln’s Inn) LL.M. (London) LL.M. (Harvard)
LL.M. (Cardiff), G.D.L. (UOL) LL.B. (Hons.)(London) LL.B. (Hons.)(London)

WITHOUT PREJUDICE
By courier
22 October, 2021

Maqsood Ahmed Al-Haj Automotive (Pvt.) Ltd.

Owner/Proprietor Main National Highway
Proton Apollo Motors Zulfiqarabad, Karachi
PAF Base, Shahrah-e-Faisal
Faisal Cantonment, Karachi

Subject: Legal Notice under section 29 of the Sindh Consumer Protection Act, 2014

We have been instructed by Syed Owais Ali (“Our Client”) to address the instant Legal
Notice to you with respect to your non-delivery of his Proton Saga ACE motor vehicle (“Proton
Saga”). Our Client booked the Proton Saga with you on 05.04.2021 upon payment of Rs.600,000/-
and as such was one of the first customers of the Proton Saga car in the country. Our Client’s PSO
number is 4000000-0348-21 and you promised to deliver the Proton Saga to him earliest by July,
2021 and latest by September, 2021. However, it is now near the end of October, 2021, and Our
Client has received no intimation regarding the delivery of his booked Proton Saga despite
numerous inquiries and entreaties made to your offices; therefore, he was constrained to instruct
us to send you the instant Legal Notice.

2. Our Client is a respected professional documentary filmmaker. Our Client even made a
documentary about purchasing his first motor vehicle in Pakistan and reviewed many motor
vehicles currently available in the Pakistani market on his YouTube channel which has 43,000
subscribers. In particular, Our Client reviewed the Proton Saga in two of his YouTube videos
titled “Proton Saga in Pakistan - Worth It?” dated 05.04.2021 which received over 86,000 views
available at <https://www.youtube.com/watch?v=jpG_Xm6zk5A&t=2s> (last visited
22.10.2021) and “ALSVIN vs SAGA - Which is Better Value?” dated 09.04.2021 which received
over 58,000 views available at <https://www.youtube.com/watch?v=P_bzNtFfnmM&t=495s>
(last visited 22.10.2021).

3. In the aforementioned videos, Our Client had nothing but complimentary things to say
about the Proton Saga and recorded his entire journey and thought process behind booking the
Proton Saga with you. His videos received tens of thousands of views and helped convince many
other customers to book the Proton Saga vehicle with you, thereby increasing your business and
revenue. However, you have in response treated Our Client with utter contempt and disregard

Multan Lahore Islamabad

2nd Floor, Shujra Tower Office No. 1 House No. 4
Near High Court 4th Floor, SAF Centre Street No. 12
Ghous-ul-Azam Road 8-Fane Road Sector F-7/2
SFH 2

by not even deigning to send any written communication in any form whether print or electronic
to intimate Our Client as to the delivery status of his Proton Saga. Our Client has been completely
at sea with respect to any knowledge or information related to the delivery of his Proton Saga.
Your representatives give conflicting claims orally as to the status of delivery of the Proton Saga;
sometimes stating that it will be delivered in October, 2021 or November, 2021 and at other times
stating that the Proton Saga cannot be delivered to Our Client before December, 2021 or even
January, 2022 despite the fact that Our Client booked the Proton Saga on the very first day it was
made available for booking i.e. 05.04.2021. Till date you have not provided Our Client with any
reasons or communication in writing to explain these massive delays.

4. In light of the foregoing, you are guilty of unfair practices and misrepresentation under
the Sindh Consumer Protection Act, 2014 as well as under the general contract, tort, and criminal
law of Pakistan. Your lackadaisical and contemptuous attitude towards your customers has left
Our Client distraught. Our Client was one of the pioneering customers of the Proton Saga and
was in fact a cheerleader of the Proton brand as a new entrant in the Pakistani automotive market.
But due to your unprofessional and mendacious approach, Our Client has been constrained to
purchase another car (Toyota Yaris) earlier this week to fulfil his transportation needs due to the
indefinite and unexplained delays in delivery of the Proton Saga. Furthermore, Our Client faces
mental and moral anguish over promoting the Proton Saga and exhorting others to buy the
Proton Saga whereas it seems you are yourselves not interested in selling the car.

5. Therefore, you are hereby called upon to make delivery of the Proton Saga and pay
damages in the amount of Rs. 10,000,000/- (one crore rupees only) within fifteen days from
receipt of this Legal Notice to cover the cost of the car (Toyota Yaris) that Our Client has had to
purchase earlier this week, the cost and inconvenience of being without a form of
conveyance/transportation for since 05.04.2021, inflation, and the mental and moral anguish and
torture you have occasioned to Our Client over the past more than ten months. If you fail to abide
by the above terms, Our Client has instructed us to avail all legal remedies against you in this
behalf under civil as well as criminal law, including but not limited to remedies under the Sindh
Consumer Protection Act, 2014.

Zeeshaan Zafar Hashmi

LL.M. (Harvard)
Advocate High Court
For Shujra, Farooq & Hashmi
Advocates and Legal Consultants
Ph. 042 - 37114211
Cell: 0345-4237040

A copy of this Legal Notice has been retained by our office for the purposes of record.

Multan Lahore Islamabad

2nd Floor, Shujra Tower Office No. 1 House No. 4
Near High Court 4th Floor, SAF Centre Street No. 12
Ghous-ul-Azam Road 8-Fane Road Sector F-7/2