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1 Director Deputy FIA Cyber Crime Lahore Dated: 20.07.2019 Subject

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1 Director Deputy FIA Cyber Crime Lahore Dated: 20.07.2019 Subject Director Deputy FIA Cyber Crime Lahore Dated: 20.07.2019 Subject: COMPLAINT & SUBMISSION OF PROOF ON BEHALF OF MR. ALI ZAFAR EVIDENCING THE PERSONAL VENDETTA OF CERTAIN INDIVIDUALS TO MALIGN HIM ON SOCIAL/PRINT MEDIA IN APPARENT VIOLATION OF THE PREVENTION OF ELECTRONIC CRIMES ACT, 2016 (“ the 2016 Act”) It is respectfully submitted that: 1. The Complainant, Mr. Ali Zafar, is a renowned celebrity and an internationally acclaimed artist and as part of the performing industry he is heavily reliant on his professional and personal reputation. He is recipient of numerous national and international awards and is a respectable, law abiding and responsible member of the society. He has a huge fan following out of which many consider him as their idol. The fame that he has received in Pakistan and worldwide is the result of years of hard work. The Complainant strictly believes in the highest of professional standards. 2. It is pertinent to note that the Complainant, despite having been in the entertainment industry for over 20 years, has never been faced with an organized attempt to tear down his public image by spreading untrue and false information about his character or demeanor towards women. 3. Only recently, he has been made a target of a severely misleading social media campaign which attempts to accuse and portray Complainant as a sexual predator, and has disseminated to the public-at-large phony stories of Complainant’s conduct. The said campaign has now continued for over a year now which has multiplied in magnitude and caused Complainant and his family irreparable emotional, psychological and financial harm. 4. If the record as reproduced herein is perused, it becomes apparent that the social media accounts are part of a systemized and collective effort to defame and damage Complainant’s reputation and livelihood by continually posting derogatory, insulting, inciting and insinuating remarks against the Complainant and his character on various social media forums such as Twitter, Instagram and Facebook. The language used in such posts/comments 1 is extremely vulgar evidencing the ulterior motives of certain individuals to malign Complainant to the extent of public shame. 5. To the best of Complainant’s knowledge, this campaign had taken root from a comment posted on Complainant’s Manager, Taha Sadaqat’s social media account on Instagram on 02.02.2018. A user by the name of ‘sana_samir_91’ made the following threatening comment: "And I must say you are going to have a lot of work on your hands when we all take your pervert client to the cleaners close to his movie release. Enjoy"1. The aforesaid comment visibly demonstrates that perpetrators of this social media campaign had at a very strategic time – release of Complainant’s anticipated film – decided to smear his reputation. This was followed by appearances of other such fake accounts, such as nehasaigol1, that carried on a planned narrative of threatening and labeling Complainant as a harasser and pervert. 6. On 19.04.2018 Ms. Meesha Shafi, to further the cause of the baseless campaign, made patently false and bald allegations on Twitter against the Complainant alleging sexual harassment. Her first tweet did not contain any details of the incident but on 21.04.2018 in an interview published in the ‘InStep Today’ (The News) Ms. Meesha Shafi claimed to have been sexually harassed by the Complainant twice. Again, no further details were given of the alleged first incident but in respect of the alleged second incident it was claimed to have taken place during a jamming session at Lahore. However, on 23.06.2018 the Complainant categorically denied said allegations as being patently false and announced to pursue his legal remedies against Ms. Meesha Shafi for defamation. On 23.06.2018, the Complainant instituted a suit against Ms. Shafi before the learned District Judge, Lahore wherein vide Order dated 23.06.2018 the learned Court restrained Ms. Shafi from making any derogatory remarks against the Complainant. The case is pending adjudication. 1 2 7. In response to the defamation suit, Ms. Shafi discreetly preferred a complaint against the Complainant before the Federal Ombudsman for Protection against Harassment of Women at Workplace which was subsequently dismissed. 8. Notwithstanding the dismissal of Ms. Shafi’s complaint by the Federal Ombudsman, her sympathizers and accomplices continued to make derogatory remarks against the Complainant, his family and colleagues in an extensive social media campaign, in direct contradiction to the injunctive order dated 23.06.2018 and provisions of the 2016 Act. It is rather critical to note that the narrative used to defame him was repeatedly endorsed and propagated with the help of a number of fake accounts and few bloggers. The said accounts have collectively managed to post thousands of tweets against the Complainant while tagging important people and publications. Moreover, many tweets posted by such accounts were then quoted in prominent and credible national and international publications. It is also noteworthy that few prominent journalists have also been a part this false narrative sketched out against the Complainant. 9. Given that social media has been abused from the very outset to spread false information about the Complainant causing intimidation, loss of reputation, and invasion of privacy, the same amounts to a clear violation of Section 20 and Section 25 of the 2016 Act. In view of above it is imperative that FIA not only investigates violations of the 2016 Act, but also seeks to protect the victim i.e. the Complainant of this smear campaign from being harassed online by taking down such abusive and defamatory social media posts, comments, pages and accounts. An account of the false propaganda against Complainant on social media is appended herewith for your kind perusal. 10. It is hereby conferred that Ms. Shafi’s Lawyer Ms. Nighat Dad is a common connection with other women and a fake account “Neha Saigol1” that made false allegations against Mr. Zafar and were a part of the smear campaign against him. Most of these women or people involved in smear campaign are associated directly or indirectly with Ms. Nighat Dad or her NGO, the Digital Rights Foundation that claims to work for on line digital rights, however is working in conflict with its own mandate. 11. In light of the above, serious action should be taken against the following accounts: i. Meesha Shafi (Artist) https://twitter.com/itsmeeshashafi ii. Nighat Dad (Meesha's Lawyer) https://twitter.com/nighatdad iii. Leena Ghani (Make Up Artist & Painter) https://twitter.com/Leena_Ghani iv. Hamna Zubair (Journalist -Dawn News) 3 https://twitter.com/hamnazubair v. Manal Faheem (Journalist - Cutacut.com) https://twitter.com/ManalFaheemKhan vi. Sephora https://twitter.com/seraphina444 vii. Iffat Omar (Artist) https://web.facebook.com/iffat.umar.1 viii. Ali Gul Pir (Artist) https://twitter.com/Aligulpir ix. Maham Javed (Journalist- NayaDur) https://twitter.com/JMaham x. Jami Azad (Director) https://twitter.com/jamiazaad xi. Hamna Raza (Blogger) https://twitter.com/HumnaRaza xii. PaxFemina (Blogger) https://twitter.com/PaxFemina xiii. Fariha Awan (Blogger) https://twitter.com/Fay_Alif xiv. Haseem Uz Zaman (Blogger) https://twitter.com/haseemuzzaman xv. Faizan (Blogger) https://twitter.com/merabichrayaar xvi. Mohsin Sayeed (Journalist) https://web.facebook.com/mohsin.sayeed.9 12. FIA is also requested to take prompt and serious action against the following fake accounts: xvii. Neha Saigol https://twitter.com/nehasaigol1 xviii. Mehar Hareem (Admin of “Support Meesha Group” on Facebook) 4 https://twitter.com/MeharHareem https://www.facebook.com/hareem.mehar.7370 https://www.instagram.com/hareemmehar017/ https://www.facebook.com/groups/supportmeeshashafi/ xix. PkPopCulture https://twitter.com/pkpopculture xx. Sana_Samir_91 https://www.instagram.com/sana_samir_91/ xxi. Sallzjay22 https://www.instagram.com/sallzjay22 xxii. SaadiaFarooq (Admin of “Support Meesha Group”) xxiii. ZainabJamil (Admin of “Support Meesha Group”) xxiv. Sania Sheikh https://twitter.com/saniash34490923 xxv. RidaHaroon https://twitter.com/ridaharoon3 xxvi. Alia Sharif (Admin of “Support Meesha Group”) https://twitter.com/AliaSharif13 https://www.facebook.com/AliaSharifOfficial212 xxvii. Deenz82 https://www.instagram.com/deeenz82 xxviii. Raisa Chaudhry https://web.facebook.com/100005002113577 It is therefore requested that FIA takes decisive action to prevent dissemination of such false information on social media which has affected Complainant’s reputation and emotional well- being. Looking forward to a positive outcome in this regard. 5 COMPLAINANT Through: Muhammad Ali Raza Advocate Supreme Court 6 [PART-I] INDIVIDUALS WHO HAVE COLLUDED TO FALSELY ACCUSE MR.ALI ZAFAR AND THEIR CONNECTION MEESHA SHAFI – ARTIST 7 Meesha Shafi, who has been friends with Ali Zafar and his wife Ayesha Fazli since many years, accused Ali Zafar of sexual harassment on Twitter at 3:45 pm claiming that he had harassed her several times over the years. This statement is directly in contradiction to Meesha Shafi’s social media accounts - Twitter, Facebook and Instagram – wherein she has posted pictures with Ali Zafar on numerous occasions. Some of these pictures are attached below. 8 This picture was posted by Meesha Shafi on her Twitter account after her latest performance with Ali Zafar. However, the same was discretely deleted a few days before she made the accusation. 9 This picture was posted by Meesha Shafi during Lux Style Awards 2016 where she captions the picture with “These smiles are real” standing alongside Ali Zafar. 10 This picture was posted by Meesha Shafi on her personal Facebook profile taken at Ayesha Fazli’s birthday party. It is pertinent to note that in her reply to Ali Zafar's defamation suit against her, she quotes that one of the incidents where she was harassed was at Ali Zafar’s wife Ayesha Fazli’s birthday party. 11 Thereafter, she posts another picture from the same birthday party on her Instagram giving photo credit to her “alleged” harasser Ali Zafar.
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