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Respectfully Sheweth: -
Preliminary Objections: -
1. That the plaintiff has no cause of action to file this suit against
the defendants.
2. That plaintiff has no locus standi to file this suit against the
defendants.
4. That on the face of it, the suit is vexatious and frivolous and
liable to be dismissed.
6. That the ingredients of tort are missing in the suit, hence, the
suit is liable to be dismissed.
12. That the suit is filed just to pressurize and harass the
defendants.
13. That the defendants are entitled for special costs under section
35-A C.P.C.
ON MERITS: -
3. That contents of this para No. 3 do not need any reply, the
plaintiff has to prove the same.
4. That contents of this para No. 4 do not need any reply, the
plaintiff has to prove the same.
5. That contents of this para No. 5 do not need any reply, the
plaintiff has to prove the same.
6. That contents of this para No. 6 do not need any reply, the
plaintiff has to prove the same. But the same was also a way
to defraud the people.
7. That contents of this para No. 7 do not need any reply, the
plaintiff has to prove the same.
8. That contents of this para No. 8 do not need any reply, the
plaintiff has to prove the same.
9. That contents of this para No. 9 do not need any reply, the
plaintiff has to prove the same.
11. That the contents of para No. 11 are false and not admitted.
The plaintiff has levelled allegation only and miserably failed
to substantiate these allegations. Whatever is published that is
proved even by the contents of plaint itself. However, the
news item dated 24th of April 2002 is misquoted.
12. That the contents of this para are incorrect and not admitted,
upto the extent to harm or cause any injury to the reputation,
good-will and business of plaintiff. The news were not
published also to degrade the plaintiff in the society, business
community or anywhere else. These were published in due
course of professional responsibilities of the defendants.
However, the news items published in papers dated 6th and 7th
of May 2002 have their own history; and prima facie were
proved.
13. That the contents of para No. 13 are incorrect and not
admitted. Detail reply is given in the foregoing para.
14. That some of the contents of para No. 14 are incorrect and not
admitted. Some contents of this para need no reply and
plaintiff has to prove the same. The publishing of news items
was in due course of professional responsibility. However, the
claim of plaintiff is imaginary and not sustainable on the legal
and actual aspects.
15. That the contents of para No. 15 are incorrect. The defendants
had not acted illegally and no defamatory material was
published, so there is no responsibility upon them for any type
of damages/compensation.
16. That the contents of para No. 16 are incorrect and not
admitted. The plaintiff never approached the defendants to
give his version. If the plaintiff is ready, the defendants are
ready to publish his version in due course of their professional
responsibilities. However, as soon as the restrictive order of
this Hon’ble Court was received by the defendants, then there
was no further publication, even having the ample material.
17. That the contents of para No. 17 are incorrect. The plaintiff
has no cause of action against the defendants.
18. That para No. 18 needs no reply being a legal one.
Defendants,
Verification: -
Verified on oath that the contents of
this written statement are true and
correct to the best of our knowledge &
belief.
Defendants
Through: -
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176
IN THE COURT OF CH. ANWAR ALI, CIVIL JUDGE,
MULTAN.
Respectfully Sheweth: -
Preliminary Objections: -
ON MERITS: -
2. That the contents of para No. 2 are incorrect and not admitted.
The respondents published news items in due course of their
professional responsibilities and the applicant miserably failed
to point out any type of malice and dishonesty on the part of
respondents.
3. That the contents of para No. 3 of the application are
incorrect. The applicant has not mentioned any reason or
quoted any material in this regards.
Defendants,
Through: -
Sheikh Muhammad Faheem,
Advocate High Court,
28-District Courts, Multan.
C.C. No. 20176
IN THE COURT OF CH. ANWAR ALI, CIVIL JUDGE,
MULTAN.
AFFIDAVIT of: -
DEPONENT