Rashid Naseer v Adil Farooq Raja [2025] EWHC 2565 (KB)

October 20, 2025

High Court Judgment: Social Media Libel in Pakistani Political Dispute

On 9 October 2025 the High Court (King’s Bench Division, Media and Communications List) handed down judgment in Rashid Naseer v Adil Farooq Raja [2025] EWHC 2565 (KB). The case was heard by Richard Spearman K.C., sitting as a Deputy High Court Judge, and concerned a libel claim over a series of social media posts made in June 2022. The claimant, Mr Rashid Naseer, is a former Brigadier in Pakistan’s Inter-Services Intelligence (“ISI”) who at the time was head of ISI’s Punjab intelligence sector. He sued the defendant, Mr Adil Farooq Raja, a former Pakistan Army Major turned blogger living in England, for defamation in respect of online publications accusing Mr Naseer of meddling in Pakistani politics. The High Court applied English defamation law, despite the overseas context, and ultimately ruled in the claimant’s favour on most issues, ordering damages and extensive remedies as detailed below.

Factual Background

Parties and Context: Mr Naseer had a long military career, retiring as an ISI Sector Commander for Punjab. Mr Raja left the Pakistan Army in 2017 and reinvented himself as an independent journalist and commentator; by 2022 he had a significant social media following, particularly among the Pakistani diaspora in the UK. In April 2022, Pakistan’s government changed and by-elections were scheduled in Punjab that summer. Against this backdrop, between 14 and 29 June 2022 Mr Raja published a series of statements on Twitter, YouTube and Facebook accusing Brigadier Naseer and another ISI officer of orchestrating election rigging and other misconduct. The posts, originally in Urdu, quickly spread online garnering thousands of retweets, likes and comments, and reached readers in England and worldwide.

Mr Naseer strenuously denied the allegations. He brought a libel claim in London, asserting serious harm to his reputation in this jurisdiction. Mr Raja defended the claim on multiple grounds, including truth (justification) and publication on matters of public interest under the Defamation Act 2013.

The Defamatory Publications and Their Meanings

At a pre-trial hearing in 2024, the Court had determined the natural and ordinary meaning of the words complained of. One publication was found not to refer to Mr Naseer and was not defamatory (the originally pleaded “fifth” post). The remaining nine publications, labelled first, second, third, fourth, sixth, seventh, eighth, ninth and tenth, were the subject of the trial. The content of each publication, English translations agreed in evidence, and the meanings found by the Court can be summarised as follows:

First publication – 14 June 2022 (Twitter)

“The reasons why the elections were not proceeding as they should was because the Claimant had taken complete control of the Lahore High Court.”

Second publication – 19 June 2022 (Twitter)

“The Claimant had allegedly had several meetings with Asif Ali Zardari during his stay to discuss election manipulation.”

Third publication – 19 June 2022 (Twitter)

“The Claimant is a disgrace (black sheep) in the ISI and Pakistan Army who will be eliminated at the right time by soldiers working covertly leaking information about the actions and movements of such people.”

Fourth publication – 19 June 2022 (YouTube and Twitter) and 22 June 2022 (Facebook)

1. The Claimant has set up an election cell in the Sector Headquarters in Lahore tasked with gathering daily progress reports of PDM and PMLN candidates, summoning local influencers and pressurising and bribing them into casting votes against PTI candidates.
2. The Claimant is part of a meticulously contrived process set up by military and intelligence officers to rig elections in Pakistan.
3. The Claimant has been abusing his position, using huge unaccounted funds to ensure the victory of PDM and PMLN and manipulating elections in Pakistan.
4. The Claimant will be abusing his position and power to use the Police and Dolphin Force to harass PTI supporters during the PTI election campaign.
5. The Claimant has sinned and destroyed his chances of a promised life in the hereafter just to serve one person.

Sixth publication – 29 June 2022 (Twitter)

“The Claimant had caused the police to do his bidding by making a baseless allegation of bribery against the Defendant.”

Seventh publication – 29 June 2022 (Twitter)

“The Claimant is directly involved in political interference.”

Eighth publication – 29 June 2022 (Twitter)

“According to my sources, this FIR has been registered against me by Brigadier Rashid Naseer, Sector Commander ISI Punjab, who did so through IG Punjab in order to block my identity card and my passport so as to defame me because I have exposed his role rigging plans in by-elections. This is the reality of the fraudster from Lahore.”

Ninth publication – 29 June 2022 (Twitter)

“When nothing else worked, then they registered a fake case against me on an old date at a fake location and arrested my brother-in-law from my home. According to my sources, the ISI is directly involved in this fraud and this case was registered on the instructions of Brigadier Rashid Naseer and Faheem Raza.”

Tenth publication – 29 June 2022 (Twitter)

“The Claimant played a prominent role in regime change and his corrupt practices have made him a billionaire.”

Legal Framework: Libel, Serious Harm, Truth and Public Interest

Under English law, a claim for libel is established by proving that the defendant published to a third party a written statement referring to the claimant that bore a defamatory meaning. Since the Defamation Act 2013, the claimant must also show that the publication caused, or is likely to cause, serious harm to their reputation (s.1(1) of the 2013 Act). If these requirements are met, the burden shifts to the defendant to prove a viable defence.

In Mr Naseer’s case, serious harm was a live issue since the publications were in Urdu and much of the audience was overseas. The Court, however, found the threshold satisfied. The posts were widely disseminated, including thousands of readers in England, and their content was highly injurious to the claimant’s reputation.

Truth (Defamation Act 2013, s.2)

Truth is a complete defence to libel. In this case, Mr Raja initially advanced a defence of truth for each of the nine allegations, but he faced evidentiary difficulties. He did not call any first hand witness who could substantiate the serious accusations against Mr Naseer. By the second day of trial, the defendant withdrew or did not pursue the truth defence. The judge noted that there was no reliable evidence to support the truth of the various claims, for example, no proof emerged that Mr Naseer had rigged elections or amassed illicit wealth, and accordingly the defence of truth failed.

Public Interest (Defamation Act 2013, s.4)

Section 4 of the Defamation Act 2013 provides a defence of publication on a matter of public interest. To succeed, the defendant must show: (1) the statement complained of was on, or formed part of, a matter of public interest; (2) the defendant believed that publishing the statement was in the public interest; and (3) that belief was reasonable, having regard to all the circumstances. Mr Raja relied on the public interest defence for all the publications, given that they concerned alleged political interference in Pakistan, a topic arguably of public interest, at least to the Pakistani community. The Court therefore had to scrutinise Mr Raja’s sources and his efforts, if any, to verify the claims, as well as the overall circumstances of the publications, in deciding whether this defence applied.

Serious Harm to Reputation in England

The first issue was whether the publications had caused serious harm to Mr Naseer’s reputation in this jurisdiction. Although the claimant is based in Pakistan, he testified, and the Court accepted, that he has a personal and professional reputation to protect in England, not least among the Pakistani diaspora and international security circles. The posts were communicated via global social media platforms and, significantly, were admitted to have reached a large audience. The defendant’s own pleadings acknowledged substantial engagement: for example, the first tweet was retweeted over 9,450 times and liked by over 21,000 users, and even the less viral posts had hundreds or thousands of retweets and likes each. Some of the content was also posted on Facebook and YouTube, where view counts in the hundreds of thousands, and in one case over a million on Facebook, were recorded.

Mr Raja argued that only a small fraction of these readers were in the UK. The claimant claimed around 6.7% of the YouTube viewers were UK based. The judge drew the inference that, even if the UK readership was relatively small in percentage terms, the absolute numbers would still be significant given the very large total readership and viewership. Moreover, the serious allegations would likely have a grapevine effect, being circulated and discussed within the close knit Pakistani community in Britain, thereby amplifying the reputational harm.

Importantly, the inherent gravity of the accusations was extreme: Mr Raja’s posts painted the claimant as a corrupt military officer undermining democracy, branding him a traitor to his duties. Such charges would plainly tend to make right-thinking members of society shun or think less of the claimant. Given the wide publication and the nature of the allegations, the Court had little difficulty concluding that serious reputational harm had occurred. Spearman K.C. found that each of the publications had caused serious harm to Mr Naseer’s reputation in England and Wales. The threshold in s.1 was therefore met for all the defamatory statements at issue.

The Public Interest Defence (s.4) – Analysis and Outcome

The central battleground of the trial was the public interest defence under s.4 of the Defamation Act 2013. As noted, the subject matter of the posts, alleged election rigging and military interference in governance, was undeniably political and capable of being in the public interest. The High Court accepted in abstract that exposing election misconduct is a matter of public interest. The crux, however, was whether Mr Raja’s belief that publishing these particular allegations was in the public interest was reasonable, given the scant evidence he had and the way he went about publishing them.

Lack of Supporting Evidence: The judge scrutinised what sources of information, if any, the defendant had for each allegation. Mr Raja had claimed to have confidential informants in the military and political establishment. However, he did not disclose any documents or contemporaneous records from June 2022 that substantiated the detailed claims he was tweeting and vlogging. He also did not call any of these supposed “silent soldier” sources to give evidence, nor provide a convincing explanation of the steps he took to verify the stories they allegedly told him. In many instances, his Defence and witness statement contained only general or conclusory assertions that he had reliable sources or that he made strenuous efforts to verify the information. Under cross-examination, it became apparent that Mr Raja had not sought any comment from Mr Naseer prior to publication; for example, he never contacted the claimant to get his side of the story. This failure to undertake basic journalistic steps was a factor weighing against the reasonableness of any public interest belief.

The Court’s Findings, One Post Protected, Others Not: After a publication-by-publication analysis, the Court upheld the s.4 defence for only one of the nine posts, the seventh publication (the tweet about the two ISI brigadiers in “C Wing” involved in political interference). For the other eight publications, the public interest defence failed.

Seventh Publication (tweet about ISI “C Wing”): The judge found that this tweet was relatively limited in its allegation and that Mr Raja’s belief in its importance was reasonable. The tweet did not name Mr Naseer directly (referring only to “both brigadiers”) and made no explicit accusation of specific criminality by him. It stated that both officers were members of a particular ISI division and that that division was engaged in political interference, something widely reported and believed at the time. Crucially, the first part of the statement, that the claimant was in ISI’s internal wing, was true (Mr Naseer was indeed an ISI officer in that wing). The second part, alleging the wing’s involvement in political meddling, was an allegation about the organisation rather than a personal attack, and evidence showed this was a matter of public contention and debate in Pakistan (i.e. contemporaneous reports suggested many people believed the ISI was interfering politically). The judge was in little doubt that Mr Raja genuinely believed this to be true at the time, and given how widespread such suspicions were, that belief was deemed reasonable. Furthermore, the tone of the tweet was measured; it did not launch a personal tirade at Mr Naseer but conveyed information in general terms. The Court concluded there was no obvious reason Mr Raja should not have considered the public had a right to know this information. In all the circumstances, the essentially factual nature of the tweet, the partial truth it contained, the public importance of the topic, and the defendant’s state of mind,  it was reasonable for him to believe publication was in the public interest. Accordingly, the seventh tweet was protected by the s.4 defence, and Mr Naseer’s libel claim failed in respect of that one publication.

All Other Publications: By contrast, the Court rejected the public interest defence for the first, second, third, fourth, sixth, eighth, ninth and tenth publications. The judge’s consistent theme was that Mr Raja had no reliable foundation for the specific and serious allegations he was making in those posts. For example, in the fourth publication (the lengthy video), Mr Raja accused Mr Naseer of running an illicit election cell, bribing and coercing officials, and so on, yet he produced nothing beyond his own say so to support those claims. His witness, Mr Sehbai (a journalist who testified on the defendant’s behalf), could only say that such allegations “correspond with common knowledge” or rumours, which fell far short of justification. The judge noted that Mr Raja’s own evidence misstates the true position and was difficult to reconcile with the plain language of what he actually published. For instance, Mr Raja tried to downplay one tweet (the eighth publication) by saying that calling someone a “fraudster from Lahore” was not meant specifically about Mr Naseer, but the judge found it inescapable that the tweet was targeting the claimant. In general, the Court found Mr Raja had embellished and sensationalised serious allegations without performing due diligence. He did not have or seek solid evidence, did not give the claimant an opportunity to respond, and even at trial he showed no real remorse, in fact, his pleaded case boasted that he “will continue to publish” the same allegations regardless (a stance the judge found telling). Given these failings, Mr Raja could not demonstrate that his subjective belief in the public interest of publishing these accusations was reasonable. The s.4 defence was therefore disallowed for eight of the nine publications. In short, except for the narrowly framed seventh tweet, Mr Raja’s posts were judged to be irresponsible and unjustified communications of unverified allegations, removing any shield of the public interest defence.

Damages and Aggravated Factors

Having found Mr Raja liable for libel in relation to eight publications, the Court turned to the appropriate damages. Notably, Mr Naseer had chosen to limit his damages claim to £50,000. The judge agreed that £50,000 was at least the sum warranted, and indeed indicated that absent the self imposed cap, a higher figure would have been justified. The award of £50,000 was therefore made in full, to cover all eight defamatory publications as a single cumulative award.

In reaching that figure, the Court considered the seriousness of the libels and several aggravating features.

• Gravity of the Allegations: The posts accused Mr Naseer of extremely serious misconduct, effectively treachery and corruption by a senior military officer. Such allegations struck at the heart of his integrity and could scarcely be more damaging in his line of work. Comparisons were drawn to other cases; even by libel standards these accusations were exceptionally grave, involving electoral fraud and betrayal of national duty.
• Extent of Publication: The scale of publication was vast, spanning multiple platforms and reaching a worldwide audience. The defamatory statements remained online and accessible well beyond their initial posting. The viral nature of the posts (retweets, shares and media coverage) meant that the claimant’s reputational harm was amplified.
• Actual Impact: Mr Naseer gave evidence that these allegations caused him significant personal distress and professional harm. Although details were not public, it was said his standing among colleagues and in the community suffered greatly. The Court accepted that impact as severe, noting that one purpose of libel damages is to provide vindication to counteract such harm.
• Aggravating Conduct by Defendant: The judge found Mr Raja’s conduct aggravated the damage. He never retracted or apologised for his claims; on the contrary, he doubled down. In his pleadings he maintained a false defence of truth almost until trial, only abandoning it at the last moment. He also admitted he had not removed the defamatory posts and, astonishingly, asserted in his defence that he “will continue to publish… the same or similar allegations”, dismissing the effect of any court order because it would “only” stop publication to the UK Pakistani diaspora. This defiant stance and failure to mitigate the harm (for example, by issuing a correction or trying to limit the spread of the material) were taken by the Court as evidence of malice or at least a cynical attitude, warranting a higher damages award. Additionally, Mr Raja’s failure to give Mr Naseer a chance to respond before publication was noted as falling short of responsible practice (although this factors into both liability and aggravation).

Considering all these factors, the Court concluded that a proper compensatory award including aggravated damages would have exceeded £50,000 in ordinary circumstances. However, since the claimant had capped his claim at £50,000, that sum became both the maximum and the awarded amount. The £50,000 is intended not only to compensate for the personal distress and reputational injury but also to vindicate Mr Naseer’s reputation in the face of the false charges.

Further Reading

• High Court examines public interest defence in Clarke v Guardian News & Media Ltd [2025] EWHC 2193 (KB)
• Defamation Solicitors (Libel and Slander)