To,

Bilal Munir & Associates,

0ffice No.35,

2nd flour, Sadiq Plazza,

The Mall, Lahore

Reply to the legal notice under section 28 of the Punjab Consumer Protection Act 2005

Sir,

With due reverence, reference is had to your legal notice dated 03.12.2019 which has received us on
10.12.2019, whereby , your client has tried to lug my valuable client in to spurious ; phony; façade
frolicsome and illegal snare of assertions.

Without prejudice to the generality of the reply and right to contend and quote the incidental and
consequential question of law and fact, the reply is as under:

1. That ‘Airlink Communication’ is a law abiding Public Private Limited Company and paying the
highest tax to the government about 4 billion per anem; never violates the law of Pakistan.
2. That as per our record, your mobile has been repaired by swapped motherboard with new IMEI
867668044296065.
3. That my client being a professional and law abiding company cannot sale its product without
prior permission from the authorities. That our client has already provided the trail of IMEIs to
the Pakistan Telecommunication Authority for their kind perusal and registration.
4. That this act of PTA cannot be preserved faulty services by my client.
5. That your legal notice has no cause of action against my client and even though this matter does
not fall the ambit of the sections provide in the Punjab Consumer Protection Act 2005.
 6. That the section 4 of the Punjab Consumer Protection Act 2005 is reproduced as following;

4. Liability for defective products:-

(1).The manufacturer of product shall be liable to a consumer for damages proximately caused by
a characteristic of the product that renders the product defective when such damage arose from
a reasonably anticipated use of the product by a consumer.
(2). A product shall be defective only if,
a. it is defective in construction or composition as provided in section 5;
b. it is defective in design as provided in section 6;
c. it is defective because an adequate warning has not been given as provided in section 6;
d. it is defective because it does not conform to an express warranty of the manufacturer as
provided in section 8.
Therefore, your mobile was blocked by the PTA and that issue cannot be treat as fault by my
client. In addition, it is not right case for calming damages under Consumer Protection Act from
my client (Company).
7. I hope you will understand the law and situation. Though, you should approach the right forum
to serve your notice for redress and will refrain from expensive and time consuming litigation.

NOTE: The copy of this reply is retained in my office for my record and reference.

Thank you

Abdul Qayyum Khan

Advocate High Court