& The Chief ExecutiverDirectors Denning Solicitors | ‘Channel 24 veer 47-N, Gubborg I tonne Gurumangat Road aed Lahore, ‘branes aace Pakistan vn Delivered by Post and by Hand on Our Ret: 21502340183 16" November 2015, Dear Sirs Pre-Action letter for intended legal Proceedings for broadcasting untrue ‘material defaming the Claimants in your program titled as “Khara Sach” broadcasted on 12 November 2015 Mr Sahibzada Jahangir—v- Yourself We have been instructed by the above claimant to issue @ claim for compensation for broadcasting the material the contents of which were not only factually inaccurate ‘and unsupportable but were also manifestly malicious; the malice was manifestly Feflected in the style and tone that was adopted by your anchor while conveying the ! defamatory material Wee are required by the Civil Procedure Rules to comply with the Pre-Action protoco! for Defamation before issuing a claim therefore this letter is being sent under the protocol whereby you are given an opportunity to sotle the matter. The material posted on your website and on the social media does not provide much assistance a8 to the nature of your entity i.e. a sole propriatorship or corporate however we understand that Pakistan Electronic Media Regulatory Authority “PEMIRA" does not give permission to a non-corporate entity, The futher search on {he ist maintained by the Pemra discloses that M's Central Media Network (Pvt. Lt is registered as a license holder at this address. Kindly confirm that the Channel 24 {is the media name of M/s Central Media Network (Pvt) Ltd. for the purpose of entering true identity ofthe Defendant (yourself for prospective claim, spree ecco ae $ Pome cne) Pertierra eevee Scere‘Although you have posted that you have offices in Washington DC, Now York, ‘London and Dubai; yt no information as to the address ofthese claimed offices are ssuppliod therefore it is concluded that you have posted false and misleading information on your website. Kindly correct us if you have not lied on your webpage ‘and has an office in the UK Broadcast being complained ‘The program tiled as “Khara Sach" broadcasted on 12 November 2015 by your TV channel contained the following incorrect, defaming and unsupportive material ‘Transeript of broadcast While stating previous office bearer Ch Sadiq had police record, the anchor stated “Sab sai Important, | am very somy to take this name but | have to sahibzada Jahangir sahib, woh alk aisa hee character hal, yeh khud ko chaiman ka qareebi dost show karte hai, baland © bang daawe karte hain aur phir muntahib logo ko knulam khula discredit karte hain sab ko batate phirte hal k chonke yeh imran k dost hain tau uss ki kehi huge baton pal yeh amal kara rahe hain elected memberan ko ciscredit karte hain inn pai b fund raising k hiwale sal kuch lzamat hain” ‘The anchor continued to look dawn on the paper “claimed audit report Extracts of Transcript related to both Sahibzada Jahangir and Amjad Khan “Soniya ifan nai party mal... aurkuch b sabit nahi hua; unnho nai sahibada aur ‘Amjad khan k saath mil kar media mai muamla uchhala aur party ko kafi badnam kiyer Our Clients complaints: We agree with our clint that the above allegations were false and wore not part of the internal audit report of the PTI. The said audit report being a public document ‘can easily be accessed and read, The same has been supplied o us and no words whatsoever, net even the name of our cient, as allegedly quoted by your anchor are recorded in the document |“Therefore your anchor knew he was making a false statement when he was both referring to the intemal ausit report and pretending to be reading the repor. (On 13" November 2016, PTI published the following response in their website: "Tho so-called audit repert as claimed by anchor person waa in fact @ management letter given intomaily and could certainly not be regarded as an aut repor that was falsely claimed by im. ur client has also read this letter and instructed us that his name or anything falsely attributed towards him is not quoted in the letter. The anchor was merely making it Up and misleading the public through broadcasting Inthe tertories of Pakistan under era License and broadcasting globally through putting the recording of program fon channel 24 website, sharing t on youtube and facebook to reach the people in Middle East, Europe and other continents, ‘Our client responds the folowing to the spexifcallogations made in the broadcast While stating previous office bearer Ch Sadiq had police record, the anchor stated ‘Sab sal important, | am very sorry to take this name but | have to sahibzada Jahangir ssahib, woh alk alsa hee character hal, By stating Mr Jahangir has similar character; your anchor alleged that Mr Jahangir has a police record ie. he had been arrested for an offence, charged and convicted. This is very serious allegation against a person who Is very well respected in local and Intemational community due to his family background and longstanding struggle he has had engaged for the charitable and social causes. He has been directors of various commercial entarpises and had been asked by the UK government on two occasions to lead a trade delegation to Pakistan. He has been instrumental in holping Pakistan economy by taking investments worth Blions of Pounds trom the UK, ‘The allegation of having criminal record is untrue, baseless, unsupportive and dofamatory, yeh khud ko chairman ka qareebi dost show karte hai ‘As a malter of fact Mr Jahangir is close friend of chaliman. Kindly demonstrate the tevidence to the contrary demonstrating that Mr Jahangir is merely making false representation of boing a fiend and is nota fiend in realitybland o bang daawe karte hain aur phir muntahib logo ko khulam khula discredit karte hain ‘This statement is innuendo that gives the meaning that Mr Jahangir takes or attempt to take unfair advantage of his fiendship. ssab ko batate phirte hai k chonke yeh imran k dost hain tau uss ki keh huee baton pal yeh amal Kara rahe hain elected memberan ko discredit karte hain ‘his statement is innuendo that gives the meaning that Mr Jahangir tells false propaganda and lies. inn pai b fund raising k hivale sal kuch iizamat hain” ‘This defamatory statement is completely untrue, Mr Jahangir had always been trusted in the social civle. He has always donated huge sums of money for the charitable causes and to the PTI. He is so trustworthy that he was, in 1993, made Chairman of Iman Khan Cancer Appeal to organize funds raising for Shaukat ‘Khannum Cancer Hospital. There had never been suspicions let alone allegations on him. In any event the way in which the statement is expressed gles viewers and listeners {an impression as if the fund raising Is an unwanted and undesired activity that within short span of previous statements gives false impressions, when taken in context, of funds’ embezzlements particularly when the statement is finished with the words sccusations, Extracts of Transcript related to both Sahibzada Jahangir and Amjad Khan ‘Soniya ifan nai party mai... eur kuch b sabit nahi hua; unnho nal sahibzada aur ‘Amjad khan k saath mil kar media mai muamla uchhala aur party ko kafi badnam kiya ‘Tris statement reflects the postion which is contrary fo the actual fact. t was in fact Mr Khan & Mr Jahangir who rescued the party's position by way of effective ‘communication; this wes appreciated by the PT!'s leaderships.‘Actions you are required to take You are Invited you disclose the intemal aucit report or any document that would record the narrations given on the program broadcasted on national channel and abovementioned social medi. If you, upon making enquiry, come to the findings that you have broadcasted a statement without making appropriate enquiries and the statements cannot stand, as itwould not, then you are required to broad cast a full program highlighting the errors ‘demonstrating that your source had produced you an incorrect document which was rushed into broadcasting without investigating. Ifyou are to maintain that your broadcast reflected the true positon, and the anchor did not make deliberate attempt to defame our clients by falsely claiming to be Teading a document, then give us a response within 14 days of the date of receipt of this letter which is deemed to be served upon you on 19” November 2015. If 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 Courts of Justice and 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 is caused to the English subjects). We have instructions fo report this matter to the complaints council of PEMA bacause you have also breached the conditions of your license as contained in the oma 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 (4) & (h) of the ‘Schedule A of Pemra Rules, subparagraph (0), (k) and (I) of paragraph 3 of Code of ‘Conduct and sub-paragraph 7 of paragraph 4 of Code of Conduct \We look forward to hearing from you. Yours faithfully Denning Seleettors Denning Solicitors,