In a strongly worded nine-page response to a show-cause notice issued to him by the Pakistan Tehreek-i-Insaf (PTI), Hamid Khan — one of the founding members of the party — said that he would not quit PTI "under any circumstances".

On Sunday, PTI suspended the basic party membership of the senior lawyer and issued to him a show-cause notice for "defaming and maligning" the party through his statements on print and electronic media. The notice, however, did not go into details of the statements.

Khan, who is stated to be a member of the team which had written the PTI’s first constitution, invited the wrath of the party leadership when he accused PTI of playing into the hands of the "establishment" during a TV show recently.

The show-cause notice, issued by PTI secretary general Amir Mehmood Kiyani, asked Khan to explain his position in writing within seven days.

In his response written to Kiyani, dated December 3, Khan said: "Let me make it loud and clear that I will not quit the party under any circumstances.

"The party is my sweat and blood. I have spent thousands of man hours (sic) to give it its thought and direction. No opportunist, turncoat, land grabber and sugar or other corrupt mafias can force me out of the party."

He added that he would do everything possible, within the limits of the law and the Constitution, to "protect and defend" his party membership.

"I will stand by my fellow party workers through thick and thin, come what may, I will be their voice. I will not abandon them to be victimised by outrageously evil elements that have entered the party."

Khan also took an issue with how he was informed of the notice, saying he had learnt through the media about it.

"It is strange that though the matter concerns [the] internal working of the party, yet you have chosen to release it to the media, print as well as electronic. It is a highly improper conduct on your part," he said, adding that since Kiyani had gone to the media, he too had the right to release his response.

Referring to Kiyani as the "purported secretary general" of PTI, Khan said that he was surprised to learn Kiyani had become the party's secretary-general and Arshad Dad had been replaced.

"In any case, I have no issue with you becoming secretary-general of the party because you are a senior member."

However, Khan said he was "sad" to learn that Kiyani was under inquiry on "serious corruption charges" that had arisen during his tenure as health minister.

"I hope that you have cleared yourself of such charges because you should not be serving in such an important capacity within PTI, being yourself under cloud. It can embarrass the party. So, for the good of the party, you should have yourself cleared at the earliest."

'Vague, ambiguous and unintelligible allegations'

With regards to the show-cause notice, Khan said: "It is indeed objectionable that before service of the so called [show-cause notice] SCN, I found it being displayed on the social, economic and print media which obviously is a malafide act on your part, meant only to tarnish my image."

He added that show-cause notices are required to be "specific and detailed".

"Nevertheless, I do not hold you responsible for that. If the entire legal of the government could not draft a proper notification for appointment of COAS [chief of army staff], as observed by the Honorable Supreme Court, how can I blame you for not being able to draft a proper show-cause notice."

The disgruntled founding PTI member said "vague, ambiguous and unintelligible allegations" had been made and details of where he had made the remarks, for example, had not been specified.

"When did I malign/defame the party which I love more than you do?" he asked.

"It is not possible to respond to such a vague, ambiguous and preposterous SCN, based on unfounded allegations."

Khan said that he believed his opinions about the "legality and constitutionality of the extension of the army chief's tenure and his stance on the accountability of judges had disturbed the sensitivities of those belonging to the powers that be and my party has been pressurised by those quarters to take action against me".

"My impression might be wrong that but it is important to know that who has compelled you and the chairman [Prime Minister Imran Khan] to initiate proceedings against me.

"Such transgressions can cause constitutional chaos which could be injurious to the national interest."

Khan added that his opinion had nothing to do with party affairs.

"These have been expressed and taken in my capacity as a constitutional lawyer," he said.

The notice

“It has been noted by the undersigned and Chairman of the party Imran Khan that you have repeatedly, in the print and electronic media, spoken against and maligned/defamed the party without any justification, and on the basis of fake and false allegations which amount to mala fide,” says the show-cause notice issued to Khan and released to the media by the PTI’s Central Media Department.

Through the notice, Khan has been “charged with having committed misconduct, violated party discipline and party constitution by making fake, false, frivolous and wrong allegations, bringing the party matters in the media for ulterior motives and thereby acting against party interest and also hurting ­feelings of party members and workers".

“In view thereof, your behaviour has badly damaged the cause of the party and attracted a bad image of the party, within the country and outside the country,” says the notice, adding: “You are hereby given a show cause notice to explain your position in writing within seven days as to why action should not be taken against you” under the party constitution, which included expulsion from the party.

Suspending the basic members of Khan with immediate effect “till the final decision” of inquiry, the PTI secretary general also barred him from “speaking, commenting on media (electronic, print and social) against party matters and policy decisions of the party and also against members of PTI”.