COPY OF THE LEGAL NOTICE SEND TO PAKASTANI MEDIA

Re: - 149/INDIL/RV/2012

To, November 22, 2012

The Nation News Paper

Mr. Majid Nizami

(Managing Director)

(Nawaiwaqt Group of Newspaper)

Having address at NIPCO House,
4 Shaarey Fatima Jinnah
Lahore, Pakistan

Also at

Khayaban-e-Shamsheer

Phase-V, Defence Housing Society

Karachi, Pakistan

Also at

Nawaiwaqt House, Zero Point

Islamabad, Pakistan

Also at

Nawaiwaqt House, Abdali Road,

Multan, Pakistan

Dear Sir/s,

We are concerned for our client MR. VEERAJ KUMAR VERMA @RAJAN VERMA, having address at 301, 3^rd Floor, Building No. 4-A, New Mhada Colony, Lokhandwala, Andheri (West), Mumbai, India- 400 053, upon whose instruction and behalf, we have to serve following notice upon you;
That our client is a law abiding and peace loving citizen of India and is an actor by profession having acted in various feature films which has been proved blockbuster on the box office and some films are going to be released very soon and considering the same, our client is having a very good reputation within the society as well as within the entertainment industry at large, whereas, you no. 1 is a leading newspaper of Pakistan having a very good reputation within the international media and thus in routine course, whatever the news is being published by you, the same is being treated as a most trusted and truthful news not only within Pakistan but also at international level and thus, it is your bounden and mandatory duty to check the authenticity of any news before you publish the same in your news paper. Our client further states that you no. 2 is the Managing Director of you no. 1 and is actively involved into the day to day affaires of you no. 1 and thus, are very much liable and responsible for the acts and deeds done by you no. 2 for and on behalf of you no.1.
That our client in routine course of the business, had produced and acted into a film i.e. Hindi Feature Film titled “Ashok Chakra”, which was intended to give a tribute to the martyr and victim of the inopportune tragedy of the attack done by the terrorists on 26/11/2008 at our financial capital Mumbai. Our client states that the said film was completed well within time and was released worldwide and was very much appreciated by the people at large. Our client further states that in the said film, our client had played the lead role of “Kasab”, the only surviving terrorist, who after trail before the Hon’ble Court at Mumbai, was sentenced to death.
You are also aware that the said terrorist Kasab, pursuant to the judgment and order of the Hon’ble Court and pursuant to rejection of his mercy plea by the Hon’ble President of India, the said Terrorist was hanged till death on 21/11/2012 at Yarwada Jail, Maharashtra, India and the said news came to be reflected everywhere in India as well as at International level via print and electronic media. That our client was very much shocked and surprised to go through a news on internet published by you no. 1 through you no. 2 in your news paper in it’s 21/11/2012 edition wherein the news regarding the judicial hanging of the said terrorist was published however, it was more surprising that instead of Photograph of Kasab, the still photograph of our client (procured from the said film wherein our client is carrying a weapon into his hands) is being published in the said column in your newspaper. Our client states that by the said act, you have made an attempt to pretend as if our client is the real Kasab and terrorist who have killed various innocent people on the said fateful day and also, you have made an illegal and unjustified attempt to declare our client as one of the dreaded International Terrorist.
That due to your aforesaid acts and deeds and willful default, the reputation and dignity of our client has been badly hampered within the society as well as at the international level at large. At the same time, it has also caused security concerned of our client and his family members at any time and place as, after the said news being published, a prudent man will carry an impression that our client is a real culprit of the said attack on Mumbai and mass killing of the innocent people of our country and foreigners.
Further, due to your aforesaid illegal and unjustified acts and deeds and due to publication of the photograph of our client in your news paper which is being published and distributed worldwide, our client shall face various problems in immigration, Visa, security check etc., while his visits to abroad and it is quite natural that he could be refused to provide Visas for the Country like America and in that case, our client shall not only face a tremendous mental and physical torture but also, shall face a huge and irreparable monitory losses as, in routine course of his profession, our client is required to visit outside India most frequently for the purpose of shooting of his films.
That it is quite regretful and surprising that the photograph of Kasab is easily available and specially for the media like you and the photograph of our client cannot be procured that much easily however despite the said fact, the photograph of our client has been affixed instead of Kasab which clearly indicates towards your selfish motive and design best known to you and the said fact itself indicates that the reputation of our client has been intentionally hampered by you at International level.
In the circumstances, our client have instructed us to address you the present notice which we hereby do and call upon you to compensate our client to the tune of Rs. 10,00,00,000/- (INR Ten Crores Only) for the mental and physical trauma and financial losses faced by our client and at the same time, you are also called upon to tender your unconditional written apology in your newspaper in prominent place within one week from the date of receipt of the present notice failing which, our client shall have left with no other option but to initiate necessary Civil and Criminal proceedings against you as per provisions of the Law of the land and in such event, you shall alone be responsible for the entire risk as to cost and consequences thereof, which you may please take note well in advance.

Thanking You

Your’s truly

For INDI LEXUS

Neeraj D. Gupta

Advocate