Cyber Defamation Complaint (Dignity of Natural Person)

COMPLAINT TO THE DIRECTOR, CYBERCRIME REPORTING CENTRE Federal Investigation Agency C.O.D. Headquarters, Islamabad

Date: complaint_date

Complainant: complainant_name, son/daughter of complainant_father, resident of complainant_address, CNIC No. complainant_cnic Against: accused_person_name/accused_username (accused_address / Online Identity)

VERSUS

COMPLAINT FOR CYBER DEFAMATION UNDER SECTION 20, PREVENTION OF ELECTRONIC CRIMES ACT 2016

Sir/Madam,

1. I respectfully lodge this complaint against accused_person_name for committing the offence of cyber defamation under Section 20 of the Prevention of Electronic Crimes Act 2016.

2. That I am complainant_profession and reside at complainant_address. My reputation and honor are of paramount importance in my professional and social life.

3. That accused_person_name, either personally or through online account(s) on platform_names with user ID/handle accused_username, deliberately and maliciously published false, defamatory, and derogatory information regarding my character, profession, and conduct.

4. That the said defamatory content was published on publication_platform on publication_date, and remains accessible at url_or_account_details.

5. The content in question stated as follows: 'defamatory_statement', which is nature_of_defamation.

6. That the above statement is completely false and fabricated, designed to harm my professional credibility and social standing. No such alleged_conduct has ever been committed by me.

7. That the accused acted with intent_or_recklessness, knowing the statement to be false or showing gross indifference to its veracity.

8. That impact_on_complainant, causing severe emotional trauma, professional damage, and loss of reputation in my community.

9. That scope_of_publication, multiplying the harm to my reputation and character.

10. That I have requested accused_person_name to remove the defamatory content and issue an apology, but the accused has response_to_request and continues to harbor the offending material online.

11. That the false information has been shared and commented upon by other users, further amplifying the harm and making complete removal impossible.

12. That this conduct falls squarely within Section 20 of PECA 2016, which criminalizes the intentional public exhibition or transmission of false information regarding a natural person that harms reputation.

13. That I have preserved evidence of the defamatory content through evidence_preservation_method and possess screenshots and archival records.

14. That accused_person_name is accused_identification and accused_location_or_contact.

PRAYER

I, therefore, request this Honourable Agency to:

(a) Register a First Information Report (FIR) under Section 20 of the Prevention of Electronic Crimes Act 2016 against accused_person_name;

(b) Direct removal of the defamatory content from platform_names and all archival services;

(c) Investigate the false allegation and ascertain the accused's identification and whereabouts;

(d) Secure the account and digital evidence before it is deleted or altered; and

(e) Take all necessary steps to apprehend the accused and prosecute him/her to the fullest extent of law.

VERIFICATION

Verified on oath at verification_place on this _____ day of _____, year, that the contents of the above complaint are true and correct to the best of my knowledge and belief.

_____________________________ complainant_name Complainant Date: ______________ Through: _____________________________ counsel_name Advocate (if applicable)