Mst. ZAINAB BIBI and 8 others Versus ABDUL MALIK and 12 others

This matter concerns a petition for leave to appeal before the Supreme Court of Pakistan, arising from a Civil Revision Application filed by the petitioners in September 1990. The core legal question presented for determination is whether the High Court erred in dismissing the petitioners' Civil Revision Application on the ground that it was filed beyond the 90-day limitation period prescribed by the second proviso to subsection (1) of Section 115 of the Code of Civil Procedure 1908. The central issue is whether this limitation period, introduced by Act No. VI of 1992, which was promulgated on 30-5-1992, could be applied retrospectively to a revision application that had already been filed in September 1990, well before the enactment of the amending legislation. The Court granted leave to appeal to examine the validity of the High Court's application of this statutory amendment to pending proceedings, thereby addressing the principle of non-retroactivity of procedural amendments affecting vested rights of litigation, specifically regarding the temporal application of statutory limitation periods introduced after the initiation of legal proceedings.