Zardari's counsel Farooq H Naek said that his client could not be charged by the Accountability Court in today's hearing and the proceedings were deferred till January 18.
Assistant lawyer Amjad Iqbal Advocate said that arguments will be presented in the next hearing with the reference to 58-year-old Zardari's indictment.
Leaving the court, Zardari, dressed in a black overcoat and a black cap, smiled and waved to his Pakistan People's Party supporters and the media personnel.
"There is not ground in this case for a charge to be framed," Naek said.
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The references against Zardari were deferred earlier as he enjoyed immunity during his tenure as the President of Pakistan. The court had earlier released several of the co-accused in the references against Zardari.
"Pakistan People's Party has always respected the courts and so has former president Zardari which can be seen by the fact that he appeared before the court today," said former Interior Minister Rehman Malik.
"We (PPP) have always faced victimisation," he had earlier said, adding that the party will stand and face any charges against them.
"Jails and handcuffs are not a big issue for the PPP," Malik had added.
Zardari had earlier missed three hearings, citing security threats. The court had earlier decided to indict Zardari on December 9 in four graft references out of five pending against him.