NOOR ELAHI Versus FEDERATION OF PAKISTAN

This matter concerns a petition filed by a Head Clerk in the Pakistan Air Force (PAF) challenging an adverse Annual Confidential Report (ACR) recorded in 1991. The petitioner, having served for thirty-one years, contended that the adverse report was biased, as it was authored by a Reporting Officer under whom he served for only one year and who allegedly harbored a grievance against him. Furthermore, the petitioner argued that the communication of this adverse ACR was delayed by nearly four years, occurring only on August 15, 1994, which constituted a procedural violation of the specific instructions governing Confidential Reports for PAF Civilians. The core legal question before the Court was whether an adverse ACR communicated with significant, unexplained delay and allegedly motivated by personal bias should be expunged. Upon considering the petitioner's submissions regarding the procedural irregularities and the questionable circumstances of the report's issuance, the Supreme Court granted leave to appeal to examine the validity of the adverse ACR and the potential violation of the governing administrative instructions.