UNFAIR COMPETITION, CRICKET AND SPORT BROADCASTING IN PAKISTAN

By:
DR. MUHAMMAD ABRAR IMTIAZ AHMED KHAN
PhD Law (University of Glasgow, UK)
Toronto, Canada

Keywords: Competition; Cricket; Pakistan; Public Service Broadcasting; Television; Private Broadcasting; Sport

Introduction

Sport is treated as economic activity in international trade. Cricket is a famous sport in Pakistan. In Pakistan, no specific law exists to regulate the siphoning of sporting events. The federal Government controls both electronic media through the Pakistan Electronic Media Regulation Authority as well as intellectual property laws through the Intellectual Property Organisation of Pakistan.

This article focuses on unfair competition in cricket broadcasting in Pakistan, The first part of this article gives an overview of public and private broadcasting and their financial and social consequences. The second part defines the arguments in favour of anti-siphoning sports laws. Thirdly, it discusses the broadcasting environment in Pakistan. Fourthly, it centres on the relationship between the Pakistan Television Corp ("PTV") and cricket tradition. This section also deals with the fact that the private broadcasting industry tries to attract a large audience by buying exclusive rights just for pure economic interest. Finally, this article sets out a recommendation based on public interest.

Overview of broadcasting

The Rome Convention (the Convention) laid the foundation for the idea of broadcasting. The Convention established for the first time the international minimum standard of protection and recognised three beneficiaries, namely, performers, producers of phonograms and broadcasting organisations. The Convention also establishes minimum rights for broadcasting organisations. These organisations are granted three rights: to authorise or prohibit the re-broadcasting of their broadcasts; fixation and reproduction.

There are two kinds of broadcasting, public broadcasting and private broadcasting. The broadcasting market is also well-known by free television viewing (public broadcasting) and pay-TV or pay-per-view TV (private broadcasting). Public broadcasting is free-to-air. The purpose of this broadcasting is to serve the interests of the public in the best possible manner. Public broadcasting serves the interest of general public, because it is financed by the public and controlled by the public. The public interest means people as citizens rather than as consumers while the sole purpose of the private broadcasting is to make a profit. The sole source of finance in public broadcasting is the licence fee. It can also be funded from commercial revenue, advertising, sponsorship, licensee fee, tax reduction and state aid, while the private broadcasting is funded in an almost similar way except the licensee Ice, tax reduction and state aid. Sponsors and advertisers pay the broadcaster more to advertise their product when there is a larger audience.19 In this way, they create competition in broadcasting. The British Broadcasting Corp ("BBC")20 and Independent Television ("ITV")21 in the United Kingdom, Pakistan Television Corp ("PTV") in Pakistan, the Australian Broadcasting Company ("ABC")22 and Special Broadcasting Services ("SBS")23 in Australia are the best examples of the world public service broadcasting organisations. Entertainment Sports Program Network ("ESPN"), Star Spoils, Ten Sports, Fox Sports and Geo Super are sports broadcasting examples of pay-TV.

All forms of broadcasting are ultimately financed by the consumer/citizen, whether it be as a tax payer (state funding), as a consumer of products and services (advertising and sponsorship), as subscriber to a given programme channel (pay-TV) or as holder of a receiving set (licence fee). In each case the consumer/citizen has no choice as he is obliged to pay. Accordingly, if the broadcast is paid for by the public, then the sole purpose of this activity should be for the public.

In the past, PTV dominated the market until the establishment of the Pakistan Electronic Media Regulatory Authority ("PEMRA") which issued licenses to private companies to broadcast in Pakistan. Now, Pakistan operates a mixture of state-controlled and private broadcasting, with little in the way of independent law. These private broadcast companies broadcast through satellite-to-cable and direct satellite TV whereas PTV also transmits through terrestrial broadcasting. Exclusive rights to broadcast any sports event allow creation of a monopoly which is against a fair competition in the market.

Though a balance should always be sought between a broadcast right and the public interest but the problem is the exact definition of the word public interest in sports. It may be defined as "a program in which a large part of the audience is interested". In other words, it means something in which the public at large have some interest or by which their rights or liabilities are affected, but it does not mean the interest of a particular person. To understand this concept, there is a need to consider the background.

In a 1960 policy statement, the Federal Communications Commission (FCC) in the USA listed major elements of the public interest for the broadcast industry. The list contained 14 major elements that are usually necessary to secure public interest. These elements included Sports programmes, opportunity for local self-expression, the development and use of local talent, children's programmes, religious programmes, educational programmes, public affairs programmes, editorialisation by licensees, political broadcast, agricultural programmes, news programmes, weather and market programmes, services to minority group and entertainment programmes. Although the FCC was reluctant to enforce the 1960 statement, nevertheless, this approach and standard prevailed for the next two decades.

Until recent past, PTV had a very good tradition of broadcasting cricket as a free-view product for the enjoyment of the general public and there was no other TV channel except PTV until the end of the 20th century in Pakistan. A competition started after permission of private broadcasting in Pakistan, PEMRA regulate the broadcasting industry in Pakistan. Before that regulation, rights were protected by the Pakistan Telecommunication Authority ("PTA").

Anti-siphoning laws

Compared with Australia, the European Union, the United States and other countries, pay-TV in Pakistan is a recent development. In the past, there was just one public sector broadcasting company, the Pakistan Television Corp. Now, there are many private TV channels although no anti-siphoning laws for sport broadcasting. It is the best time to secure Pakistani cricket fans' interest. For this purpose, the anti-siphoning policy of different countries is considered below.

In 1994, the Australian Government introduced an anti-siphoning scheme, Australian legislation empowered the Minister to broadcast certain types of televised sports events free-to-air to the general public. It is also a condition of a licence that a subscription TV broadcaster cannot acquire the right to broadcast if the events are specified in the list in the Broadcasting Services Act 1992 S. 115(1). From September 2008, the Australian Communications and Media Authority ("ACMA") monitory authority operates the anti-siphoning laws instead of the Minster of Communication.

Some commentators interpret the intention of Australia's anti-siphoning legislation as being to give priority to free-to-air broadcasters over pay-TV or to restrict pay-TV. Actually, this is not the correct interpretation of the existing law. Priority is just the outcome of the anti-siphoning laws. The core intention is to provide free access to the general public.

As a result of the above section, ACMA provides a sporting event list to broadcast free to the general public. Under these laws, pay-TV can never acquire exclusive rights to a listed event while free-to-air broadcasters may acquire exclusive rights and further sell rights to pay-TV or cable operators.

The Australian anti-siphoning list comprises 34 sporting events across 12 sporting categories including cricket, tennis, golf, motor sports and football. Cricket matches are divided into three categories. First, each test and one-day cricket match which the Australian team play in Australia or the United Kingdom. Secondly, at least one match of each one-day cricket series played at home. Finally, all matches in the one-day cricket World Cup are also on the list. Australia is one of the few countries to provide legislation to ensure public access to sport broadcasting. The European Union also has rights in respect of free viewers. Major important events (the football World Cup and EU football championships) are available on free-TV. The broadcasting rights for such matches are not permitted to be the part of the football broadcasting market on pay-TV. In Europe, major sporting events may not be broadcast exclusively on pay-TV and must be available for the general public on free-TV. Member States may draw up a list for these events, determine the limit of coverage on free-TV and also broadcast the events of major interest for short news reports.

Germany and Switzerland have only sport events on the list but some EU countries have also included cultural events.

Anti-siphoning regulations currently do not exist in the United States. In the past, the Federal Communications Commission (FCC) has enacted them but they no longer exist. In fact, there are very few people who do not have access to pay-TV in America.

Pakistani electronic media

This section focuses on the history of Pakistani broadcasting which is divided into two stages that is the evolutionary period (1947-2000) and the latest developments (2000 to present). Pakistan entered into the TV broadcasting age by establishing the Pakistan Television Corporation Ltd at Lahore and Dhaka in November 1964 by the Government of Pakistan. Karachi and Islamabad TV centres were established in 1967, and Peshawar and Quetta in 1974. The private sector of Pakistani electronic media started operating under the control of the PTA on January 1, 1997 in accordance with the Telecom Reorganisation Act 1996.

Before 2002 when the PEMRA was created, the Pakistani electronic media laws were scattered amongst different legislative measures, administrative regulations and departments and rules. The major national laws that contain electronic media legislation were Copyright Ordinance 1962 and Pakistan Television Company Act 1964.

As far as international obligations are concerned, during this period, Pakistan became a member of the Berne Convention in 1948. Pakistan also joined the World Intellectual Property Organisation ("WIPO") in 1977 and the World Trade Organization ("WTO") in 1995.

The second stage started with the establishment of the Pakistan Electronic Media Regulatory Authority under Pakistan Electronic Media Regulatory Authority Ordinance 2002 to facilitate and regulate the only private electronic media undertaking. On April 8, 2005, by a Presidential Ordinance, the Government of Pakistan decided to incorporate the management of intellectual property in keeping with the upcoming global trend. An enforcement committee is working under the supervision of the Intellectual Property Organisation of Pakistan with the cooperation of Pakistan Electronic Media Regulatory Authority. Pakistan Electronic Media Regulatory Authority controls the private sector. There are no checks and balances for the public sector. The public sector enjoys full facilities, like state aid, while the private sector has a different restriction on media authority.

As a developing country, Pakistan was given extra time to implement TRIPS. TRIPS came into force in Pakistan on January 1, 2000 in accordance with the general timetable of the WTO.

The obvious need for new laws to control the public and private TV channels post 1997 resulted in legislative action. So, new electronic media laws have been promulgated, that is Cable TV Regulations 2002, Broadcasting Regulations 2002, Copyright Ordinance 1962 (amendment 2000). Pakistan Electronic Media Regulatory Authority (Amendment) Act 2007 and Rule 2002 and Council of Complaint (Organisation and Function) Regulates 2002.

The Competition Commission of Pakistan ("CCP") was established on October 2, 2007 under the Competition Ordinance 2007. The CCP prohibits exploitive abuses of the dominant market. Competition laws clearly stop pay-TV creating a monopoly.

The Pakistan Television Corporation and cricket

The Pakistan Television Corporation is a public company limited by shares wholly owned by the stale and is established to provide TV broadcasting services by telecasting live programmes of all kinds: education, entertainment and several others. PTV Corp is a terrestrial channel with a share of more than 70 percent of TV viewers.

PTV Sports Division is a high-earning division of PTV. The main objectives of this division are to arrange healthy sports. PTV also broadcasts live national and international sports keeping in view the interest of Pakistani viewers. Fees are increasing day by day in Pakistani pay-TV: "The sports broadcast fees may skyrocket in the future". The pay-TV market in Pakistan is immature, with limited competition and high subscription fees.

An interesting factor is that PTV collects licence fees from viewers through electricity bills. Almost everyone has electricity connection in Pakistan. As a result, the general public have to pay the licence fee. Therefore, it is clear that public broadcasting is very common in Pakistan compared to private broadcasting.

The real problem started, when PTV as a public broadcaster and profitable organisation did not telecast Pakistani cricket matches. The controversy started in 2003 on the telecast rights between PTV and Geo Super, a private TV channel. The first international one day cricket match between New Zealand and Pakistan was blacked out worldwide due to conflict over telecast rights between public and private channels. Moreover, PTV did not telecast the T-20 World Cup 2007, Pakistan and Australia cricket series, and several others. In an upcoming home series between Pakistan and Sri Lanka at UAE, Geo Super has obtained exclusive telecast rights in Pakistan. The head of business unit for Geo Super said that there is no clause in the contract to share rights with PTV. Cricket broadcasting is converting from the public broadcasting industry to the private broadcasting industry.

Cricket has hard-core fans in Pakistan. All generations consider the game as a way of developing their personalities, to help them face the challenges of life and as a form of entertainment. The cricket is a source of unity for the nation. Traditionally, Pakistani cricket matches have always been available to all free viewers through PTV. Cricket is a golden opportunity for cricket fans to set aside their daily problems, even if just for a while.

Conclusion

In the future commercial channels may obtain the exclusive right to broadcast all cricket matches gradually. It is a major threat for cricket fans. Some consumer associations in Pakistan, who protect the interest of the public at large, support this view. Broadcasting should be independent in order to serve the interest of the public.

Another solution would be for the CCP to lake action against this practice. The CCP prohibits exploitive abuses of dominant undertakings. Competition laws can clearly prevent pay-TV from creating a monopoly. However, at this stage, there is no proposed law or regulation in Pakistan to address the issue of exclusive sports broadcasting.

The Pakistani broadcast, legislation is not harmonised to world standards. The Government should take the significant step of adopting an anti-siphoning sports law. By doing so, the Government of Pakistan can protect the enjoyment and interest of millions of people in free-view cricket.

[1]     This is a revised and updated version of the previous article published in Entertainment Law Review. See Muhammad Abrar, Anti-Siphoning Laws and Pakistan Cricket, 21 (2) Entertainment Law Review 62-67

[2]     The University of Glasgow. The author would like to thank Professor Rosa Greaves and Tom Guthrie for helpful comments on an earlier draft.

[3]     PhD research student at the School of Law, University of Glasgow, United Kingdom.

[4]     Official website of Pakistan Electronic Media Regulation Authority, available at. <http://www.pemra.gov.pk/> accessed 11th November 2013.

[5]     Introduction, Intellectual Property Organisation of Pakistan available at <http://www.ipo.gov.pk/> accessed 11th November 2013.

[6]     Although the United States had an active role in the drafting process, it did not sign the Rome Convention. See S. Balganesh, "The Social Costs of Property Rights in Broadcast (and Cable) Signals" (Fall 2007) Berkeley Technology law Journal 1305.

[7]     It is jointly administered by the United Nations Educational, Scientific and Cultural Organisation (UNESCO), the International Labour Organisation (ILO) and WIPO.

[8]     In 1949, three international organisations-namely International Office of the Berne Union, the United Nations Educational, Scientific and Cultural Organisation and the International Labour Organisation--began a draft proposal on a related rights international treaty. After 10 years of meeting and revisions, the Rome Convention final draft was ready in 1961.

[9]     Rome Convention art.13.

[10]   See art.3 (e and f) for the meaning. Because limited to a wireless means of transmission, cable is not covered under it.

[11]   M. Ficsor, Guide to the Copyright and Related Rights Treaties Administrated by WIPO and Glossary of Copyright and Related Rights Term (Geneva: WIPO Publication, 2003), p.153.

[12]   Public broadcasting and government controlled broadcasting-are almost identical. Government control broadcasting exists in Belarus, Zimbabwe, Turkmenistan, China and Burma where the government monopolises the industry. Public Broadcasting exists in the United Kingdom, Japan, Germany, the Netherlands, the Nordic countries and Australia. It is also used in Africa, Asia and Eastern Europe. It most cases, it remains in some form of public ownership but operates under a statute. S. Buckly et al., Broadcasting, Voice and Accountability, (Michigal). The University of Michigan Press, 2008), p.38.

[13]   Some languages do not have a term fully corresponding to the English word "public" and the closest words are state/government/official broadcasting. See W. Rumphorst, "Public Broadcasting Legislation: Basic Requirements" (2002) Media Online 1.

[14]   The United States is a largely private broadcasting entity. S. Buckly et al., Broadcasting, Voice and Accountability, (2008), p.228.

[15]   The United Kingdom has two types of pay-TV network: the satellite network run by BskyB with more than 50 percent of subscribers, and the local cable networks largely owned by Telewest and NTL. BskyB was the first company to enter the pay-TV market. See D. Harbord, and S. Szymanski, "Football trials" [2004] E.C.L.R. 119.

[16]   S. Clover, "Confused signals-satellite broadcasting and Premiership football" [2007] E.L.R. 127.

[17]   W. Rumphorst, "Model Public Service Broadcasting Law" (1999) ITU/BDT and UNESCO 2.

[18]   Rumphorst, "Model Public Service Broadcasting Law" (1999) ITU/BDT and UNESCO 1.

[19]   Rumphorst, "Model Public Service Broadcasting Law" (1999) ITU/BDT and UNESCO 2.

[20]   Buckly et al., Broadcasting, Voice and Accountability, (2008), p.203.

[21]   Tax-payers finance programmes indirectly through state aid.

[22]   Consumers of products and services finance programmes as a purchaser.

[23]   Subscribers of TV channels finance programmes as a viewer.

[24]   Buckly et al., Broadcasting, Voice and Accountability, (2008), p.63.

[25]   H. Fleming, "Television without frontiers: The broadcasting of sporting events in Europe" [1997] E.L.R. 285.

[26]   Fleming, "Television without frontiers: The broadcasting of sporting events in Europe" [1997] E.L.R. 285.

[27]   F.W. Friendly, Due to Circumstances beyond Our Control (New York: Random House, 1967), p.291.

[28]   2005 C.L.D. 264 (Pakistani case law)

[29]   A.E. Varona, "Changing channels and bridging divides: The failure and redemption of American broadcast television regulation" (2004) Minnesota Journal of Law, Science & Technology 23.

[30]   V.F. Philips, "On media consolidation, the public interest and angels earning wings" (2004) American University Law Review 623.

[31]   Varona, " Changing channels and bridging divides: The failure and redemption of American broadcast television regulation" (2004) Minnesota Journal of Law, Science & Technology 24-25.

[32]   Varona, "Changing channels and bridging divides: The failure and redemption of American broadcast television regulation" (2004) Minnesota Journal of Law, Science & Technology 25-26.

[33]   See PEMRA website at <http://www.pemra.gov.pk/> accessed 11th November 2013.

[34]   See PTA website at <http://www.pta. gov.pk/index.php?cur_t=vnormal> accessed 11th November2013.

[35]   T. Humphrey, "The politics of sports: the why, when and how of sports law development and implementation" [2008] I.S.LR. 30.

[36]   Free-to-air means that the Australian Broadcasting Corporation (ABC), the Special Broadcasting Services (SBS) or commercial free-to-air broadcasters reach more than 50 per cent of the Australian population.

[37]   Broadcasting services Act 1992 S.115.

[38]   Schedule 2, Pt.6, cl.10

[39]   R. Redman and J. Dwyer, "Sports broadcasting in Australia-Government signals significant legislative changes" (2006) Sports Law Administration & Practice 15

[40]   Redman and Dwyer, "Sports broadcasting in Australia-Government signals significant legislative changes" (2006) Sports Law Administration & Practice 15.

[41]   Humphrey, "The politics of sports: the why, when and how of sports law development and implementation" [2008] I.S.LR. 30.

[42]   Broadcasting Services Act 1992 s.115.

[43]   J, B. Perrine, "Media Leagues: A Australia suggests new professional sports leagues for the twenty-first century" (2002) Marquette Sports Law Review 801.

[44]   Anti-siphoning list commencing 2006 is still applicable. See ACMA website at <http://www.acma.gov.au/theACMA/engage-blogs/engage-blogs/Broadcast/Statc-of-play-anti-.siphonin g-update> accessed 11th November 2013.

[45]   The Television without Frontiers Directive (89/552) was amended in 1997 (97/36) to include a new art.3A enabling Member States to view major sports events on free-TV. S. Clover, "Confused signals-satellite broadcasting and Premiership football" [2007] E.L.R. 128.

[46]   Council Directive 89/552 art.3 (i), [1989] OJ L298/23, amended by Council Directive 1997/36, [1997] OJ L202/60, and Council Directive 2007/65, [2007] OJ L332/27. Sec P. Hettich, "YouTube to be regulated? The FCC sits tight, while European broadcast regulators make the grab for the internet" (2008) Saint John's Law Review 1485.

[47]   Council Directive 2007/65 art.3 (j), [2007] OJ L332/27.

[48]   Council Directive 2007/65 art.3 (k), [2007].OJ L332/27.

[49]   Hettich, "YouTube to be regulated?" (2008) Saint John's Law Review 1485.

[50]   J.B. Perrine, "Media Leagues: Australia suggests new professional sports leagues for the twenty-first century" (2002) Marquette Sports Law Review 800.

[51]   In the United States, anti-siphoning rules were challenged in Home Box Office Inc v FCC, 567 F.2d 9, 34 (D.C. Cir. 1977) See Hettich, "YouTube to be regulated ?" (2008) Saint John's Law Review 1484.

[52]   J.B. Perrine, "Media Leagues: Australia suggests new professional sports leagues for the twenty-first century" (2002) Marquette Sports Law Review 796.

[53]   At first, Pakistani television started with black and white transmissions, colour transmissions began on February 18, 1979.

[54]   Over the years the system has grown countrywide. In 1964 television services in monochrome were commissioned; in 1967 two production studios were added at Rawalpindi and Karachi; in 1973 the national microwave network was commissioned which linked TV centres; in 1974 Quetta/Peshawar centres were commissioned; in 1976 colour transmission started, in 1987 the federal TV centre at Islamabad was commissioned; in 1992 a second TV channel for education was commissioned (this was the only TV station at Islamabad along with 16 rebroadcast stations); in 1996 local area transmissions from four stations started and extended to three more stations; in 1998 transmission of PTV world programmes started; in 1998 up to 2006, several production centres (Lahore, Quetta, Peshawar, Islamabad-l and Islamabad), 35 rebroadcast stations for PTV-I and 16 rebroadcast stations for PTV-2 were in operation. Introduction of Pakistan Television Corp Ltd available at < http://ptv.com.pk/lntroduction.asp > accessed 11th November 2013.

[55]   Dhaka was part of Pakistan; but after independence of Bangladesh, it is a part of Bangladesh.

[56]   Introduction of Pakistan Television Corp Ltd available at < http://ptv.com.pk/lntroduction.asp > accessed 11th November 20.13.

[57]   The Pakistan Telecommunication Ordinance 1994 established the primary regulatory framework for the telecommunication industry including the establishment of an authority. Thereafter, the Telecommunication (Re-Organisation) Act No. XVII was promulgated in 1996 which aimed to reorganise the telecom sector of Pakistan. Under the Telecom Reorganisation Act 1996, the Pakistan Telecommunication Authority (PTA) was established in January 1997 to regulate the establishment, operation and maintenance of telecommunication systems, and the provision of telecom services.

[58]   WIPO is a specialised agency of the United Nations. It is dedicated to developing a balanced and accessible international intellectual property (IP) system, which rewards creativity, stimulates innovation and contributes to economic development while safeguarding public interest. WIPO was established by the WIPO Convention in 1967 with a mandate from its Member States to promote the protection of IP throughout the world through co-operation among states and in collaboration with other international organisations. Its headquarters are in Geneva, Switzerland. What is WIPO? Available at <http://www.wipo.int/about-wipo/en/what_is_wipo.html> accessed 11th November 2013.

[59]   Convention establishing the World Intellectual Property Organisation: WIPO Convention (1967), amended in 1979 available at

          http://www.wipo.int/treaties/en/documents/pdf/wipo-convention.pdf> accessed 11th November 2013.

[60]   See WTO website available at < http://www.wto.org/english/tratop_e/trips_e/tripfq_e.htrn> accessed 11th November 2013.

[61]   Enforcement co-ordination is being institutionalised and expanded by establishing Enforcement Committees in Islamabad, Karachi and Lahore. Its membership comprises the following stakeholders: "Introduction to IPO Pakistan" (2007) Intellectual Property Organisation of Pakistan available at

          <http://www.ipo.gov.pk/Contents/AboutlPO.aspx> accessed 11th November 2013.

[62]   The TRIPS agreement is a part of the WTO package. Therefore it applies to all WTO members. The general timetable for implementing the TRIPS agreement, which entered into force on January 1, 1995, was one year for industrialised countries, five years for developing country and 11 years for less-developed countries. Pakistan, being a developing country, was required to harmonise its laws in accordance with TRIPS before January 1, 2000. M. Siddique, Intellectual Property Rights Day, TRIPS Agreement and its Implementation for Pakistan, (2005) Business Recorder 11.

[63]   See WTO website available at <

          http://www.wto.org/english/tratop_e/trips_e/tripfq e.htm>

          accessed 11th November 2013; what is the World Trade Organization? Available at <http://www.wto.org/english/thewto_e/whatis_e/tif_e/factl_e.htm> accessed 11th November 2013.

[64]   See website of MCA at <http://www.mca.gov.pk/> accessed 11th November 2013.

[65]   Section 3, Competition Ordinance, 2007.

[66]   Section 3, Competition Ordinance, 2007.

[67]   Article 1(111), Memorandum of Association, Pakistan Television Corp Ltd.

[68]   "To save Rs. 30 million, PTV did not show Pak-Austrolia series-Report", May 12, 2009, available at <http://www.tvexplore.com/to-save-rs-30-million-ptv-did-not-show-pak-australia-series-report/> accessed 11th November 2013.

[69]   Introduction of Pakistan Television Corp Ltd available at < http://ptv.com.pk/lntroduction.asp > accessed 11th November 2013.

[70]   B.H. Malkawi, "Broadcasting the 2006 World Cup: The right of Arab fans versus art exclusive" (2007) Fordham Intellectual Property, Media and Entertainment Law Journal 594.

[71]   There are different packages from almost £15 to £43 per month.

[72]   See ESPN website available at <http://www.espncricinfo.com/pakistan/content/story/125296.html> accessed 11th     November 2013.

[73]   "Welcome to the guestbook" available at <http://ptv.com.pk/guest/z/default.asp?Page Position=9> accessed 11th November 2013.

[74]   "To save Rs. 30 million, PTV did not show Pak-Australia series-Report", May 12, 2009, available at <http://www.tvexplore.com/to-save-rs-30-million-ptv-did-not-show-pak-australia-series-report/> accessed 11th November 2013.

[75]   See ESPN website available at <http; www.espncricinfo.com/pakistan/content/story/669399.html> accessed 11th November 2013.

[76]   The Network for Consumer Protection is a not-for-profit, public interest and independent non-government organisation in Pakistan. See website at <http://www.thenetwork.org.pk/ > accessed 11th November 2013.

[77]   The Competition Ordinance 2007 S.3.

[78]   The Competition Ordinance 2007 S.3.