the Chief ExeoutiveDvecors ‘channel 24 Pakistan our Ref: 2/160235/018K {46 November 2018 Dear Sits preraction wetter for intended legal ithe Claimants in YOUr ‘material defamirgd we rave been insted BY Me te the Yor broadcasting meter’ me atents of which Wer ut were also mat and. unsuPl arifcted in the syle and fone (etamatory material we are required by the CX Dofamation before ifestly malicious: the, aloo yas adopted By your anor ynite conveying tM Procedure Rules 19 OTL, ‘Rouing a claim therefore wye claimant 10 1s8U° & not only Denning Solicitors, Dace se ‘eer Fi ‘os ara Pod freee E18 SP) a oo 9503 18 1 Soise 1255 1h Srp eas 20, eigen roceedings for broadcasting untrue program titled 4 ‘yhara Sach” dim for compensation Tectually nacourate Malice was marifestty for for ea werey you ave ven = totunty to sate Remar “tho material posted On YON webs on evar your enity 188 $06, ‘opretrship of & CEOC nated tat Pakisian Elen Media Reg sive permission 1 2 ‘FE pat mamtaned bythe Fon, the Wtaored a a eens Ne rans aaress. Kindly ‘assistance as © 1M ody however SPEMRA' does tse meala name of Mi ijjtgwes that MS ron- corporate We is, etwork (Pvt) for Ihe ‘purpose of ral SSatering true dently OF + Cezsant (yourself rosPeSN® ‘aim erm Perec‘though you have pasted that you have offices in Washinglon DC, New York, {London and Dubai; yet no information as to the address ofthese claimed offices are supplied therefore It is concluded that you have posted false and misleading information on your website. Kindly correct us if you have not led on your webpage and has an office in the UK. Broadcast belng compiained “The program tiled as “khara Sach” broadcasted on 12 November 2015 by your TV channel contained the fallowing incorrect, defaming and unsupportve materia: ‘Transcript of Broadcast, ‘Amjad Khan London mal Kebabo ki dukan chalatein hain aur unn ki East London mai barr [pause] mai kya kahu kesl reputation hai aur unnhe PTI k lye kafi logo nai kaha k bad debt aur unehe PTs funds jama keme ki activity sai mana kiya aya lekin alk fund raiser sai iho nai party chairman k saath tasweere banwane par £25000 lye tasweere lal gay lekin unho nal pese jama karwane sal inkaar kar diya" ‘The anchor while stating the above kept his head on the table pretending to be reading the internal audi eport. Extracts of Transcript related to both Sahibzada Jahangir and Amjad Khan ‘Soniyaifan nai perty ra... aur Kuch b sabit nahi hua; unnho nai sahibzada aur ‘Amjad khan k saath mi kar media mai muamia uchhala aur party ko kefi badnam kiya” Our Clients complaints: We agree with out uli thatthe above allegations were false and wore not port of the internal aut report of the PT The said audit report being @ public document ‘can easily be accessed and read, The same has been supplied to us and no words ‘whatsoever, not even the name of our client, as allegedly quoted by your anchor are recorded in the document ‘Therefore your anchor knew he was making 4 false statement when he was both referring tothe infernal audit report and pretending to be reading the report. n 13" November 2015, PTI published the following response in thelr webste: “The so-called anit report as caimed by ancher person was In fact a management ller givenIntemally and could certaily not be regarded as an auc report that was falsely claimed by en" ‘Our client has also read this letter and instructed us that his name or anything falsely aitributed towards him ie not quoted in the letter. The anchor was merely making it up and misleading the public through broadcasting inthe territories of Pakistan under Pema License and broadcasting globally Uirough putting the recording of program (on channel 24 website, sharing it on youtube and facebook to reach the people in ‘Middle East, Europe and other continents. COurciont responds the folowing to the spectic allegations made in the broadcast: Amjad Kian London maikebabo ki dukan chalatein hain Your anchor, having met with him and dined In one of his restaurants, is fully aware that Mr Khan Is one of the directors of the company known as Kebabish Original Limited and Kebabish restaurants and takeaway limited. The business isin operation {for over 20 years and has brand value above the sums of £1,000,000. The company has boon franchising the business for over 16 years and has considerable presonce In the UK and Europe. ‘Your anchor statement alsin innuendo as it suggests that Mir Khan enjoys no status ‘and no identiy of his own: this leads the viewer to concelve that every sentence following this statement fs to be accepted as proven, ‘ur unnh ki East London mai barr fpause] mal kya Kahu kes! reputation hal ‘This Is @ classic example of innuendo to frame Mr Khan in a picture of “a person bbeing very notorious’ the gesture of your anchor are remarkable and the way he ‘nodded his head, portrayed his facial gesture and shifted his body clearly gave a ‘message that an unpleasant porson with negative intogrty is being mentioned. ‘aur unnhe PTI Kliye kafitogo nai kaha k bad debt ‘This is completely untrue and made up sentence by the anchor. Mr Khan being the president of PTI labour wing UK is much respected amongst the members and office ‘bearers of the PTI, This sentence Is not documented anywhere but constructed by the anchor.‘ur unnhe PTI's funds jana keme ki activity sai mana kiya gya This statement is factually and technically incorrect. This is technically incorrect bocause the funds collecting authory is vested with the funds collacton section of PTI. Mr Khan never claimed to be part ofthis section. Mr Khan and other PTT office bearers are always requested by the Funds collection sections to raise funds by arranging events however the funds are collected only by the authorised personals. ‘The statement is factually Incorrect bocause Mr Khan nover attempted to collect any funds. When he did not make an attempt, no consequential directions. would ‘naturally be required to be given to him. ‘This statement is clearly defamatory because it shows Mr Khan to be unreliable person who would not be trusted to deal with funds for PTI. Whereas he is respectable business ferson who has always been donating money for the chaftable causes and giving funds to the PTI Iekin alk fund raiser sai inho nai party chairman k saath tasweere banwane par £25000 lye tasweere lil gay lekin unho nal pese jam Karwane sal inkaar kar diya This is entirely untrue and no incident is ever reported in any document. Me Khan never asked any person to donate funds to the claimed sums for a photo shoot hich is otherwise avaleble to anyone who attends the party's events. Nevertheless the allegation is serious enough to make public believe that Mr Khan cannot be trusted with finances ani money matters. This statement where affects his social standing it also raises eyebrows of his franchisees and business associates. ‘Transcript related to beth Sahibzada Jahangir and Amjad Khan *Soniya irfan nal party mal... aur kuch b sabit nahi hua; unnho nai sahibzada aur ‘Amjad khan k saath mil kar media mai muamia uchhala aur party ko kefi badnam kiya ‘This statement reflects the position which is contrary to the actual fact. It was in fact ‘Me Khan & Mr Jahangr who rescued tho party's position by way of effective ‘communication; this was appreciated by the PT!'s leadership.Actions you are required to take ‘You are invited that you disclose the internal audit report or any document that would record the narrations given on the program broadcasted on national channel and abovementioned social media If you, upon making erquiry, come to the findings that you have broadcasted a ‘statement without making appropriate enquiries and the statements cannot stand, as It would not, then you are required to broadcast a fll program highlighting the errors demonstrating that your source, highlighting the source, had produced you an incorrect document which was rushed into broadcasting without investigating, It you are to maintain that your broadcast reflected the true position, and the anchor id not make deliberate attempt to defame our clonts by falsely claiming to bo reading a document, then give us a response within 14 days of the date of receipt of this leer which is deemed to be served upon you on 19" November 2015, lt you fal to take required steps within specified time then a claim to the sums of ££1,000,000 for the claimant would be Issued in the Queen's Bench Division, High Cours of Justice and the summary disposal of the matter would be sought. The Defamation Act 2013 gives, the High Court of England & Wales, jurisdiction to take ‘cognizance of the matter where the broadcaster is not based in the UK but the ‘damage ls caused to the English subjact(s). We have instructions to report this matter to the complaints council of PEMRA, because you have also breached the conditions of your license as contained in the Pemra Rules 2009 and Code of Conduct and a complaint to this affect would also be ‘made to the Pemra. In particular you have breached Section 1 (d) & (h) of the ‘Schedule A of Pemra Rules, subparagraph (I, (k) and (I) of paragraph of Code of ‘Conduct and sub-paragraph 7 of paragraph 4 of Code of Conduct We look forward to hearing from you. Yours faithfully Danning Solceclors Denning Solicitors