KHAN & CO.
ADVOCATES AND LEGAL CONSULTANTS
20-F, Main Gulberg, Lahore
SALMAN AHMAD KHAN NOMAAN AHMAD KHAN
M.A. (Camtab), LL.M (London) LL.B (Hons) Barrister-at-Law
Jdvocare Supreme Court Advocate High Court
Prof. Dr Ikhalq Ahmad
House No. P-104
staff Colony
University of Engineering & Technology, Lahore
Dated: 10-05-2016
Subject: Legal Notice
Dear Sir,
I act for Dr Sajjad Haider Professor Environmental Engineering, UFT, Lahore
(hereinafter the Client) who has instructed me to send you this Legal Notice (the
Notice) on his behal€
1. That you have sent an abnoxious, nasty and baseless email dated May 09
2016 to the Client. in the email, inter alia other baseless allegations, you have
accused my Client of mental, moral and ethical infirmity and have called into
question his professional integrity and soundness. It is also clear from the
reckless contents and demeanor of your email that you have not only
insulted the Client but also intimidated and threatened him
2. That the above email has been circulated on the UET server. All faculty
members including Lecturers, Assistant Professors, Associate Professors and
Professors of the UET can access and read the email sent by you. it needs not
be said that the Client will be looked down upon by all the faculty members
as a result of the baseless accusations and allegations leveled by you
Moreover, the aforesaid allegations and accusations will become a source of
mental affliction and torcher for the Client and cause him mental agony, pain.
And irreparable loss of reputation and credit
3, That by your act of aforesaid commission you have committed various
serious crimes, detail whereof is as below:499. Defamation: Whoever by words either spoken or intended to be
read, or by signs or by visible representations, makes or publishes any
imputation conceming any person intending to harm, or knowing or
having reason to believe that such imputation will harm, the reputation
of such person, is said except in the cases hereinafter excepted, to
defame that person
500. Punishment for defamation: Whoever defames another shall
be punished with simple imprisonment for a term which may extend to
two years, or with fine, or with both
503. Criminal Intimidation: Whoever threatens another with any
injury to his person, reputation or property, or to the person or
reputation of any ane in whom thet person is interested, with intent fo
cause alarm to that person, or to cause that person to do any ect
vihich he is not legally bound to do, or to omit fo do any act which that
person is legally entitied to do, as the means of avoiding the execution
af such threat, commits criminal intimidation,
506. Punishment for criminal intimidation: Whoever commences
the offence of criminal intimidation shall be punished with
imprisonment of either description for a term which may extend 10 {wo
‘years or with fine or with both
504. Intentional insult with intent to provoke breach of the peace
Whoever intentionally insults, and thereby gives provocation fo any
person, intending or knowing it to be likely that such provocation will
cause him fo break the public peace, or {0 commit any other offence,
shall be punished with imprisonment of either description for a term
which may extend fo two years, or with fine, or with both.
4, ‘Through this Notice, you are required to tender an apology for the email sent
to Client and withdraw all accusations; this should be done through an email,
fon the public domain, to all those who are in receipt of your previous
derogatory email. in case of your failure or neglect to do the needful within
ten days of receipt of this Notice, | have clear instructions to initiate criminal
as well as civil proceedings for damages against you on your own risk and
cost.
5. 1am retaining one copy of this Notice at my office for necessary action if
need be, In addition, your derogatory email, sent from your official email iD
drakhlaq@uet.edu.pk has also been retained to be later present to the court
as evidence. You are advised in your own best interest to act as suggested in
this Notice.Very Truly Yours
Khan & Co