Aga Khan Lawsuit



Nagib Tajdin's


- May  2012 -


  •  His Highness Prince Karim Aga Khan
  •  His Highness' Solicitors;
  • His Highness' Agent;
  • Norton Rose;
  • Ogilvy Renault;
  • His Highness' Aide;
  • His Highness' appointed Institutional Leader
  • Parties Not Involved in the Lawsuit



Nagib Tajdin's Responding Affidavit was sworn in Montreal on 8th May, 2012. This sworn affidavit is replete with malicious lies, slander, outright fabrications and deceit aimed at His Highness The Aga Khan and all those mentioned above. This affidavit is presently displayed on Nagib Tajdin's website ( - a website condemned and forever boycotted by the Ismaili Community as it displeases His Highness. Following points and suggestions are extracted from this Responding Affidavit. With respect to His Highness' Court Discovery conducted in Toronto on Oct 15, 2010:


1) Defendant Nagib Tajdin openly and clearly suggests that His Highness vindicated and strengthened him and his co-defendant Alnaz Jiwa who insist that the solicitors of Norton Rose and Ogilvy Renault have allegedly committed a fraud on the court of Canada;


2) Nagib Tajdin asserts that during the discovery, His Highness rejected legal documents which have been issued to the Federal Court of Canada under his name "His Highness Prince Karim Aga Khan". The documents Nagib Tajdin named or alluded to are His Highness' Statement of Claim; His Highness' Affirmation notarized in the presence of one of the best American solicitors in Boston, Mr. Daniel Gleason; His Highness two letters He wrote to Nagib Tajdin. Implicit in Tajdin's grave allegation is the notion that all documents Norton Rose and Ogilvy Renault have so far submitted to the Court of Canada are forged;


3) Also implicit in Nagib Tajdin's venomous attack is the suggestion that the Supreme Court of Canada is currently examining the alleged forged legal documents which bear the name of His Highness Prince Karim Aga Khan. Simply put, Norton Rose is carrying out this alleged fraud through its solicitors Mr. Brian Gray, Ms. Kristine Wall, Sally Gomery and others. This is a direct attack on Norton Rose & Ogilvy Renault LLP;


4) Nagib Tajdin asserts that His Highness' senior Aide Dr. Shafik Sachedina and Mr. Mohamed Manji (President of His Highness Prince Karim Aga Khan Council for Canada) engaged in an alleged criminal conspiracy by initiating the lawsuit under the name of His Highness The Aga Khan. And Mr. Brian Gray is not carrying out the instructions of His Highness but Sachedina and Manji;


5) To hide these alleged fraudulent activities orchestrated by Norton Rose's solicitors, agent(s), employees, aides and Institutional Ismaili leaders - His Highness came to the court and took a false oath as the sole Plaintiff.

            Ref: Responding Affidavit, paragraphs 38, 39, 42, 43 & 33

One of the posts displayed on Nagib Tajdin's website maliciously attacked His Highness and presents His Highness' senior solicitor Mr. Brian Gray, His Highness' Leaders International Forum, His Highness' senior Aide Dr. Shafik Sachedina and Mr. Mohamed Manji, the current President of His Highness' Council for Canada as criminals. This post reads:


"[...His Highness] did not want to create a fuss at the Court because saying he was not the Plaintiff would have landed the LIF, MM, SS and Gray into troubles you have no idea of." - Nagib Tajdin's, February 3rd, 2012 (emphasis added)


Nagib Tajdin's

Venomous Attack Against His Highness' Solicitor Mr. Brian Gray

1) One of the top ranking solicitors of Norton Rose, Mr. Brian Gray, "can not be trusted" as Gray "has failed to act ethically as an Officer of the Court."


2) Gray circulates "forged documents" bearing His Highness' name;


3) Gray is "not acting in the interest of justice" and "bad faith can be inferred by the Court". Nagib Tajdin asserts that Gray told the Court that Nagib Tajdin "lies all the time" and that "Mr. Tajdin is a very 'cunning' person".


4) Gray is "misleading the Court";


5) Gray is "inciting violence against the defendants [Alnaz Jiwa & Nagib Tajdin] in the press";


6) The very cunning and serial liar Nagib Tajdin tells the Court that "Mr. Gray has enlisted the help of websites such as and to make inflammatory comments about the defendants"; (p. 8-9)


7) Gray is the source of why tens of thousands of His Highness' followers despise Nagib Tajdin and Alnaz Jiwa!


8) Gray is unethical solicitor who works for Norton Rose;


9) Gray is not following His Highness' instructions provided during His Highness' discovery - Tajdin blatantly lies as Gray has time and again asserted that he is only following His Highness' instructions;


Ref: Responding Affidavit of Nagib Tajdin






"If anything, the Defendant's allegations of forgery may be considered slander and defamation against the Plaintiff [His Highness The Aga Khan] and his aides. The Plaintiff reserves the right to pursue any and all legal remedies concerning these allegations made by the Defendant. [Nagib  Tajdin]"


 Source: His Highness' Reply to the Statement of Defence of Nagib Tajdin, P. 43, May 25, 2010



Defendant Nagib Tajdin

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