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WRITTEN STATEMENT.
Respectfully Sheweth: -
Preliminary Objections: -
1. That the plaintiff has no cause of action to file the instant suit,
to be dismissed.
2. That the plaintiff has no locus standi to file the instant suit
3. That the suit is bad for the non-joinder of the parties, hence
journalistic duties.
9. That the defendants are entitled for the special costs under
ON MERITS: -
requirements of law.
clear version. The news item was not against the company but
of legal notice, but at the same time, this legal notice was
the remaining part is not correct, because the news items were
individuals.
5. That the contents of para No. 5 are correct upto the extent of
news items.
the defendants, but the plaintiff may forget it that all these
9. That the contents of para No. 9 are not correct rather this
news items published were not against the company, but were
10. That the contents of para No. 10 are repetition of para No. 7
12. That the contents of para No. 12 are incorrect and it is again
13. That the contents of para No. 13 are incorrect and seem to be
already given.
14. That the contents of para No. 14 are incorrect or even in line
16. That the contents of para No. 16 are not in the knowledge of
plaint for the perusal. Same was also not annexed with the
substantiated properly.
17. That the contents of para No. 17 are incorrect and self-
atmosphere as well.
19. That the contents of para No. 19 are incorrect. The plaintiff
20. That the contents of para No. 20 are legal and need no reply.
21. That the contents of para No. 21 are legal and need no reply.
Verification: -
It is therefore prayed that the suit in
Verified on oath at Multan this hand may please be dismissed with cost.
6th day of June, 2003, that all the
contents of the above-titled Any other relief which this Hon’ble Court
written statement are true and deems fit & proper may also be awarded
correct to the best of our
knowledge and belief. to the defendant in the interest of justice.
Dated: _________
Through: -
Hammad Afzal Bajwa, Sheikh Muhammad Faheem,
Advocate High Court, Advocate High Court,
28-District Courts, Multan. 28-District Courts, Multan.
C.C. No. 20959 C.C. No. 20176