IN THE COURT OF MR.

NADEEM KHIZAR RANJH,

CIVIL JUDGE, MULTAN.

Javaid Ali Shah Vs. Zia Shahid etc.

SUIT FOR DAMAGES.

WRITTEN STATEMENT.

Respectfully Sheweth: -

Preliminary Objections: -

1. That the plaintiff has no cause of action to file the suit against
defendants.

2. That the plaintiff has no locus standi to file a suit for damages
in respect of defamation .

3. That the plaintiff never contacted with the defendants for

filing a counter version and to deny the news published so
being waiver of right cannot claim any damages.

4. That no prior notice is given to the defendants before filing

this suit.

5. That the suit is filed on the wrong facts and liable to dismiss
on the same ground.

6. That the suit was filed after about six months of publishing the
news item, so at this belated stage, the plaintiff cannot file the
suit on the pretext of defamation.
7. That the defendants are entitled for special cost under section
35-A C.P.C.

ON MERITS: -

1. That the contents of para No. 1 are admitted upto the extent
that the plaintiff was posted as S.P. (C.I.A.) sometime at
Multan, but the remaining para is not admitted to be correct
because some of the contents are related to the personal
abilities/qualities of the plaintiff and others are related to the
departmental matters of the plaintiff. However, the plaintiff
spent some period of his service at Multan and there are so
many matters related with the plaintiff.

2. That the contents of para No. 2 have no need to comment,

because the news item was brought by the respondent No. 2 in
discharge of his duties. However, plaintiff did not approach
the respondent No. 1 for clarification or to refute/deny the
news item.

3. That the contents of para No. 3 are incorrect. Only allegations

are levelled against the defendants without substantiating the
plea taken by the plaintiff.

4. That the contents of para No. 4 are mostly incorrect and for
the remaining para, there is no need to reply, because that
relates to the personal abilities/qualities of the plaintiff.

5. That the contents of para No. 5 are incorrect. Neither the

plaintiff came forward to refuse or deny the news item
published nor he sent any clarification to the defendants.

6. That the contents of para No. 6 are incorrect. Plaintiff has no

cause of action against the defendants.

7. That the contents of para No. 7 are legal.

8. That the contents of para No. 8 are legal.

 Keeping in view the above-mentioned
circumstances, it is respectfully prayed that the suit in
hand may please be dismissed with costs.

Any other relief which this Hon’ble Court deems

fit, may also be extended in the interest of justice.

Humble Respondents,

Dated: _______

Through: -
S.M. Shakeel Haider,
Advocate High Court,
135-District Courts, Multan.
C.C. No. 20959
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176

Verification: -
Verified on oath at Multan this ____
day of September 2002 that the
contents of the above-titled written
statement are true and correct to the
extent of our knowledge and belief.

Defendants