In a strongly-worded response to a show-cause notice issued to him by Pakistan Tehreek-e-Insaf (PTI), Hamid Khan on Wednesday warned that he would do everything possible within the limits of the law and the constitution to "protect and defend" his party membership.

In a nine-page response to the show-cause notice issued to him on December 1, he made crystal clear that he would not quit the party 'under any circumstances.'

The PTI has recently suspended Khan's basic party membership and slapped him with a show-cause notice for 'defaming and maligning' the party through his statements on media and sought an explanation from Khan within a week.

Khan, who is one of the PTI's founding members, had in his credit of writing PTI's first constitution, and he earned the ire of the party leadership after he accused them of playing into the hands of the establishment.

In his nine-page response to the show-cause, dated December 3, he 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 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 wrote.

He said that he would stand by his fellow party workers through thick and thin, come what may, and would be their voice. "I will not abandon them to be victimized by outrageously evil elements that have entered the party," he added.

Khan also told how he was informed of the notice, saying he had learnt through 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."

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 mala fide 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 team 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 pressurized by those quarters to take action against me".

"My impression might be wrong that but it is important to know 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.