Press Council of Pakistan · Press Council of Pakistan Ordinance 2002
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TO THE HONOURABLE PRESS COUNCIL OF PAKISTAN
Complaint No. _____ of year
complainant_name, son/daughter of complainant_father, resident of complainant_address CNIC No. complainant_cnic ... Complainant
VERSUS
respondent_publication_name through its Editor respondent_editor_name, respondent_editor_address, located at respondent_publication_location ... Respondent
COMPLAINT AGAINST PUBLICATION FOR VIOLATION OF CODE OF CONDUCT FOR NEWSPAPERS AND NEWS AGENCIES 2007
Most respectfully submitted:
1. That the Complainant files this complaint before this Honourable Council against the Respondent newspaper for flagrant violation of the Code of Conduct for Newspapers and News Agencies 2007 (hereinafter referred to as 'the Code') in publishing a false, defamatory, and unsubstantiated article.
2. That the article in question was published on article_date on article_page_number of respondent_publication_name under the headline 'article_headline'. The article contains false_statement_description which is entirely false, misleading, and malicious.
3. That the Complainant is a complainant_status and the publication of the aforementioned article has caused serious damage to the Complainant's reputation, professional standing, and personal integrity. harm_caused.
4. That the article violates Clause 10 of the Code, which requires accuracy and impartiality in reporting. The Respondent has published the article without conducting any independent investigation, without verifying facts from reliable sources, and without giving the Complainant an opportunity to respond.
5. That the article further violates Clause 16 of the Code, which provides for the right of reply. The Complainant was not provided any reasonable opportunity to present his side of the story before the article was published.
6. That accuracy_claim. The article is devoid of any factual basis and has been published with reckless disregard for the truth and with the intention of causing harm to the Complainant's reputation.
7. That the Respondent has violated code_violation of the Code. These violations represent a serious breach of journalistic ethics and professional standards.
8. That the Complainant, on retraction_request_date, formally requested the Respondent to publish a retraction and apology in the same prominent manner as the original article. retraction_response.
9. That the Respondent's failure to issue a timely retraction and apology demonstrates an utter disregard for the principles of responsible journalism and the obligations imposed by the Code.
10. That this Honourable Council is empowered under the Press Council of Pakistan Ordinance 2002 to investigate complaints against newspapers and to issue directions for the publication of retractions, apologies, and corrections.
11. That the Complainant has exhausted all available remedies before approaching this Honourable Council. The Respondent's refusal to rectify the damage caused by the false publication necessitates the intervention of this Council.
12. That this complaint is filed in good faith and in the interest of protecting freedom of the press while ensuring that such freedom is exercised responsibly and within the bounds of the Code.
13. That the publication of the false article has caused irreparable harm to the Complainant, and justice requires that appropriate action be taken against the Respondent to ensure compliance with the Code and to prevent similar violations in the future.
PRAYER
It is, therefore, most respectfully prayed that this Honourable Press Council may be pleased to:
(a) Hold an inquiry into the complaint and find the Respondent in violation of the Code of Conduct for Newspapers and News Agencies 2007;
(b) Issue a direction to the Respondent to publish a retraction and apology of equal prominence as the original false article within a specified period;
(c) Issue a direction to the Respondent to pay compensation to the Complainant for the damage caused to reputation and standing;
(d) Impose such disciplinary action against the Editor and the publication as this Honourable Council may deem appropriate under the Ordinance;
(e) Issue appropriate directions to make certain that the publication adheres to the Code in future reporting; and
(f) Pass such further or other order as this Honourable Council may deem just and proper in the circumstances of the case.
VERIFICATION
Verified on solemn affirmation 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, and nothing material has been concealed.
_____________________________ complainant_name Complainant CNIC No. complainant_cnic Through: _____________________________ counsel_name Advocate for the Complainant
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