NAIMATULLAH ACHAKZAI

ADVOCATES SUPREME COURT OF PAKISTAN

Office No.100, 3rd Floor, Baldia Plaza, Meezan Chowk, Quetta.
Cell # 0345-8305319, 0300-3862565

Dated: 29-04-2024

To,

1. Saad Bin Asad, Deputy Commissioner, Quetta

2. Khalid Shams, Assistant Commissioner Saddar, Quetta
3. Muhammad Jan, Extra Settlement Officer, DC office, Quetta
4. Jan Achakzai, Ex-care Taker Interior Minister, Government of
Balochistan, Quetta

Subject: LEGAL NOTICE.

R/Sir!
As per instruction of our client, Mr. Mahmood Khan
Achakzai S/O Shaheed Samad Khan Achakzai (Herein after referred to
as our client), R/O Quarry Road, Quetta. We do hereby serve you with
this following legal notice:

1. That our client is the Chairman of Pashtoon Khuwa Milli Awami

Party, Pakistan and was Candidate for the Election of President of
Pakistan held on 09-03-2024.

2. That on 03-03-2024 an illegal raid was conducted on the house of

our client by you the addressee No. 2 alongwith other officials of
District Administration and when the same illegal act was
condemned bothationally and internationally, you the addressee
No. 2 through your Gun man illegally and unlawfully lodged FIR
No. 40/2024, wherein issued defamatory statement to the extent of
our client and his family members by making the following
defamatory statement against our client and his family members by
alleging that:

“they went to the alleged Government plot located beside the house
of our client in order to restore the illegal possession, which was
illegally occupied by our client and his family members”

3. That there after you the addressee No. 1 to 4 illegally and

unlawfully made a press conference/given press statement on 03-
03-2024 against our client and illegally and unlawfully made a
defamatory statement by making the following defamatory
statement against our client:
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“That the reclaimed land, an area of 2.5 Kanals encircled by a
boundary wall was occupied by the PKMAP Chief (our client)”

4. That on 11-03-2024 another illegal FIR No. 43/2024 was lodged by

you the addressee No. 3 by making following defamatory statement
to the extent of our client and his family members by alleging that:

“Residential Land measuring 48610 Sq. Ft, which has been

illegally occupied by the family members of our client”

5. That the above mentioned statements are defamatory in nature, as

our client has no concern or connection with the subject Plot/land.
In fact the subject land/plot is in possession of one Faizullah S/O
Fazal Muhammad and the said Faizullah has filed Regular First
Appeal No. 34/2021 before the Hon’ble High court of Balochistan,
Quetta and the Division bench of the Hon’ble High Court of
Balochistan has passed an order dated: 13-12-2021, whereby
directed the parties to maintain status quo with regard to possession
of the suit land. Therefore making above mentioned false and
defamatory statements against our client and his family members
has highly injures the reputation of our client and his family
members nationally and internationally and you the addressee No.
1 to 4 through your defamatory statements have shown our client
as land grabber, land mafia and a criminal person and tried to
disgrace and defame him in the whole society particularly in the
eyes of General public in Pakistan including party members of
PkMAP and also tried to falsely establish our client as land grabber,
land mafia and a criminal person in the International community in
order to defame him especially at the time when the international
media was also covering the election of the President of Pakistan
and presidential candidature of our client and your above mentioned
defamatory statements were widely circulated in print, electronic
and social media nationally and internationally.

6. That your above mentioned wrongful act of issuing defamatory

statements against our client in tribal society tendered our client
lower in the estimation of the whole society, family members, and
other political parties and also tend to reduce him to ridicule, dislike
and hatred and caused great mental agony and torture to our client
and his family, which also effected the presidential candidature of
our client and played even a role in his defeat.

7. That since our client is not only the most seasoned and principled
politician of the country, but also a member of well renowned
political family, who have played a vital role in the independence
movement of the sub-continent under the leadership of Khan
Shaheed Abdul Samad Khan Achakzai, the father of our client and
further our client has remained the Parliamentarian for long period
comprising of decades and also the head of Political party i.e.
PkMAP and due to your above mentioned wrongful act of issuing
and making defamatory statements against our client, you
committed an act of slander and libel and due to your above
mentioned wrongful acts my client is entitled to compensatory
damages of Rs. 5000000000/- (Five Billion Rupees) and special
damages as under:
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i) Damages for injuring the Reputation of my client Rs.
10000000000/- (Ten Billion Rupees),

ii) Damages for mental torture of our client Rs. 3000000000/-

(Three Billion Rupees),

iii) Damages of the mental torture

Of the family of my client
Rs. 2000000000/- (Two Billion Rupees)/-

Total: Rs. 20000000000/- (Twenty Billion Rupees).

Therefore, you are finally hereby called upon to make a press
conference within 07 days of receipt of this legal notice by taking backing
all the above mentioned defamatory allegations made against our client
and publically make an apology through press conference and in case of
failure, your are hereby call upon to pay the above mentioned amount of
Rs. 20000000000/- (Twenty Billion Rupees) within clear 14 days from
receipt of this legal notice, otherwise our client has clear intention to
initiate legal action against your defamation and in case of failure on your
part our client has directed us to approach competent Court of law for his
grievances and redressal wholly on your risk and cost.

SIGNATURE (HABIBULLAH NASAR)

OF THE CLIENT Advocate Supreme Court of Pakistan

(NAIMATULLAH ACHAKAZAI)
Advocate Supreme Court of Pakistan

Copy of the instant Notice is kept in our office for record.