Latest Judgments
Newly reported judgments from the Supreme Court of Pakistan, the High Courts and tribunals, added as they are processed — free, full text, updated daily. Judgments marked NEW were added in the most recent update. 79,348 judgments in total from the Lahore High Court.
- NEWChief Executive Officer, District Health Authority (DHA), Multan Versus Syed Safeer Abbas Kazmi2026 PLC 196 · Lahore High Court · 2025-09-11Read full judgment →
Summary & questions settled
This Intra-Court Appeal challenged a Single Bench judgment that allowed constitutional petitions by Sanitary Patrols, directing their regularization as permanent workmen. The appellants contended that regularization required sanctioned posts under Section 3(2) of the Punjab Regularization of Service Act, 2018, and that the constitutional petitions were not maintainable due to an alternate remedy under labour laws. The High Court dismissed the appeal, affirming the Single Bench's decision. It held that the respondents, having served continuously since 2015-2016 in duties of a permanent nature (epidemic prevention), qualified as "permanent workmen" under the Industrial and Commercial Employment (Standing Order) Ordinance, 1968, and a relevant policy. The Court found no merit in the argument regarding non-sanctioned posts, noting the department's knowledge and approval of their services, and applied the doctrine of legitimate expectation. It also reiterated that constitutional jurisdiction is invokable against arbitrary or discriminatory actions, upholding the regularization direction.
Questions settled- Can employees performing duties of a permanent nature for an extended period be declared 'permanent workmen' even if initially hired against non-sanctioned posts?
- Is the existence of a sanctioned post an absolute precondition for regularization of service under the Punjab Regularization of Service Act, 2018, when a policy and long-term service exist?
- Can constitutional jurisdiction be invoked in matters concerning regularization of service where an alternate remedy under labour laws might exist, if the action of the authority is arbitrary or discriminatory?
- Does long-term service on posts of a permanent nature, supported by an existing policy, create a legitimate expectation of regularization?
- Are employees who have continuously rendered services for several years in public health functions, such as epidemic prevention, considered to be performing duties of a permanent nature?
- NEWMuhammad Imran Versus Government of Punjab through Chief Secretary, Punjab, Lahore2026 PLC(CS) 982 · Lahore High Court · 2025-04-17Read full judgment →
Summary & questions settled
The petitioner filed a constitutional petition before the Lahore High Court challenging the refusal of the Administrative Department and the Punjab Public Service Commission to recommend his appointment against a resultant vacancy of Food Grains Supervisor from the waiting list. The core legal question was whether a candidate on a waiting list can be denied appointment due to the expiry of the waiting list caused by the administrative department's own delay and inaction in processing resultant vacancies arising from non-joining candidates. The Court held that the department's dilatory conduct and arbitrary exercise of power were unjustified, as the vacancy arose during the validity of the waiting list and the petitioner had made a timely application. The Court ruled that an administrative department cannot defeat a candidate's legitimate expectations through inaction and subsequently take shelter behind the lapse of time. The petition was allowed, directing the respondents to process the petitioner's appointment notwithstanding the expiry of the waiting list.
Questions settled- Whether an administrative department can refuse to recommend a candidate from a waiting list on the ground of expiry of the waiting list when the delay is attributable to the department's own inaction?
- Does administrative delay in processing resultant vacancies from a waiting list violate the legitimate expectations of an eligible candidate?
- Is a department under a legal obligation to deal expeditiously with a timely application made by a candidate from the waiting list against a resultant vacancy?
- NEWHafiz Ahmed Raza Versus Government of the Punjab2026 PLC(CS) 1005 · Lahore High Court · 2025-12-02Read full judgment →
Summary & questions settled
The petitioner, initially a contract employee, was reinstated as a regular employee with retrospective effect. Subsequently, the department recalled this reinstatement and declared the regularization null and void. The petitioner challenged this withdrawal via a constitutional petition, arguing that the department's current treatment of him as a contract employee rendered the petition maintainable and that the action violated his constitutional rights. The core legal question was whether a contract employee, once regularized and thus brought into the stream of regular civil service, can invoke the High Court's constitutional jurisdiction to challenge the withdrawal of such regularization, or if the matter falls exclusively within the domain of service tribunals. The Court held that once regularized, the petitioner attained the status of a civil servant by operation of law, regardless of the department's subsequent attempt to withdraw that status. Consequently, the petition was dismissed in limine. The key principle laid down is that the regularization of a contract employee constitutes a fresh appointment, transforming their status into that of a civil servant, thereby attracting the constitutional bar under Article 212 regarding service matters.
Questions settled- Does the regularization of a contract employee transform their legal status into that of a civil servant?
- Is a constitutional petition maintainable against an order withdrawing the regularization of a civil servant?
- Does the bar contained in Article 212 of the Constitution of the Islamic Republic of Pakistan, 1973 apply to a civil servant whose regularization has been subsequently recalled by the department?
- NEWGhulam Rasool Versus Ghulam Hussain2026 YLR 2234 · Lahore High Court · 2025-10-23Read full judgment →
Summary & questions settled
This civil revision petition challenges the concurrent findings of the lower courts, which dismissed the petitioner's suit for pre-emption regarding the sale of land. The core legal question concerned whether the petitioner had successfully established the performance of Talb-e-Muwathibat, specifically regarding the proof of the information source. The petitioner claimed to have learned of the sale through an informer, Ghulam Shabbir, who testified that he heard of the sale from his deceased maternal uncle. The High Court upheld the dismissal, ruling that the petitioner failed to prove the requisite Talb-e-Muwathibat. The Court held that hearsay evidence regarding the source of information is inadmissible. Furthermore, the Court emphasized that under the law of evidence, the informer must be a person with direct knowledge of the sale. Because the petitioner failed to produce the primary source or prove the death of the alleged informer through admissible evidence, the chain of information remained incomplete. Consequently, the Court affirmed that the petitioner failed to discharge the burden of proof required to enforce the right of pre-emption.
Questions settled- Is hearsay evidence regarding the source of information sufficient to establish the performance of Talb-e-Muwathibat in a pre-emption suit?
- Does the failure to produce an informer or prove their death through admissible evidence invalidate the claim of having performed Talb-e-Muwathibat?
- Must an informer in a pre-emption case possess direct knowledge of the sale transaction to satisfy the requirements of the Qanun-e-Shahadat Order 1984?
- NEWMuhammad Sardar Khan Versus Federal Land Commission of Pakistan2026 YLR 2212 · Lahore High Court · 2025-10-16Read full judgment →
Summary & questions settled
This constitutional petition challenged orders of Land Reforms Authorities that declared oral gift mutations void and resumed excess land under Martial Law Regulation 115 (MLR-115). The petitioners, declarants under MLR-115, had gifted land to their brothers and sister through oral mutations. The core legal questions revolved around whether these gifts were protected under MLR-115, particularly Explanation II to Paragraph 7(b) and a related notification, and whether the proceedings abated due to the *Qazalbash Waqf* judgment or Section 25 of the Land Reforms Act, 1977. The Lahore High Court held that the gifts were rightly declared void because the father of the donors and donees was alive, meaning no inheritance had opened, and thus the donees were not deprived of their due share, making the exemption inapplicable. The Court further held that the *Qazalbash Waqf* judgment did not affect cases where decisive steps, such as scrutiny of declarations and provisional resumption orders, had been taken before the cut-off date of 23.03.1990. The Court also clarified that while a notification preventing abatement under Section 25 of the Land Reforms Act, 1977, was ultra vires, the abatement would not help the petitioners as their mutations had already been reviewed and declared void before the Act's promulgation. The petitions were dismissed.
Questions settled- Can an oral gift of land to siblings be considered valid under Martial Law Regulation 115 if the father of the donors and donees is alive at the time of the gift?
- Does the declaration in *Qazalbash Waqf* case (PLD 1990 SC 99) affect land reform proceedings where decisive steps were taken before March 23, 1990?
- Does Section 25 of the Land Reforms Act 1977 cause abatement of all pending proceedings before the Federal Land Commission, even if a notification purported to prevent such abatement?
- Is a gift declared void by Land Reforms Authorities for the purpose of the Regulation also void inter-se the parties to the gift?
- What constitutes a "decisive step" in land reform proceedings that prevents abatement under the *Qazalbash Waqf* dictum?
- NEWMuhammad Irfan Versus State Fayyaz Ahmed Mehr2026 YLR 2196 · Lahore High Court · 2025-09-18Read full judgment →
Summary & questions settled
This petition was filed before the Lahore High Court seeking post-arrest bail in a case registered under Sections 420, 468, 471, 409, and 109 of the Pakistan Penal Code 1860 read with Section 5(2) 47 of the Prevention of Corruption Act 1947, wherein the petitioner, a bank branch manager, was accused of opening and operating a forged bank account with a co-accused. The primary legal questions addressed were whether an unexplained three-year delay in lodging the FIR justified an inference of false implication, whether the petitioner was entitled to bail under the doctrine of parity, and whether alleged abscondance precludes bail when a case qualifies for further inquiry. The High Court admitted the petitioner to post-arrest bail, holding that the unexplained delay, the absence of any financial loss, and the documentary nature of the evidence already secured warranted relief. The Court further ruled that under Articles 4 and 25 of the Constitution of Pakistan 1973, parity applies because the similarly placed co-accused had already obtained bail, and an accused entitled to bail as a matter of right under Section 497(2) of the Code of Criminal Procedure 1898 cannot be deprived of relief merely due to abscondance.
Questions settled- Does an unexplained, substantial delay in lodging an FIR create sufficient doubt regarding deliberation and consultation to support the grant of bail?
- Whether an accused person is entitled to the concession of bail under the doctrine of parity and the rule of consistency when a co-accused with an indistinguishable role has already been enlarged on bail?
- Can the concession of bail be denied on the ground of an accused's abscondance when the case otherwise falls within the scope of further inquiry under Section 497(2) of the Code of Criminal Procedure 1898?
- NEWM/s Pakmaco (Pvt.) Ltd. Versus Federation of pakistan through Secretary Ministry of Energy (Petroleum Division) Islamabad2026 YLR 2175 · Lahore High Court · 2025-07-02Read full judgment →
Summary & questions settled
The petitioner company challenged a condition for depositing an appeal fee under the Redressal of Grievance Regulations, 2021, related to a procurement process initiated by Sui-Northern Gas Pipelines Limited (SNGPL). During proceedings, it was discovered that the petitioner had tampered with a previous court order dated 13.10.2023, inserting a false injunction to suspend the procurement process. The Federal Investigation Agency (FIA) confirmed the tampering and the petitioner's subsequent non-cooperation and implausible explanation of blaming a former employee. The Lahore High Court dismissed the petition with a cost of Rs. 1,000,000/-, holding that the integrity and sanctity of judicial proceedings are fundamental to the justice system. The Court emphasized that tampering with judicial orders constitutes a direct assault on the rule of law and public interest, which cannot be excused by post-facto apologies. The Registrar was directed to register a criminal case against the delinquents.
Questions settled- What are the consequences for a party found to have tampered with a judicial order?
- Can an apology from a party's counsel mitigate the gravity of tampering with judicial records?
- What is the court's duty when faced with evidence of tampering with its own orders?
- Can a corporate entity evade responsibility for tampering with a judicial order by blaming a former employee?
- NEWMukhtiar Khan Versus State2026 YLR 2169 · Lahore High Court · 2026-06-06Read full judgment →
Summary & questions settled
This criminal appeal and connected Murder Reference arose from the judgment of the trial court convicting the appellant under Section 302(b) of the Pakistan Penal Code 1860 and sentencing him to death on two counts for murder. The High Court evaluated whether the prosecution proved its case beyond reasonable doubt against the appellant. The Court observed that independent injured eye-witnesses mentioned in the FIR were withheld, warranting an adverse presumption under Article 129(g) of the Qanun-e-Shahadat Order 1984. Additionally, firearm injuries sustained by the accused party were suppressed in the FIR, co-accused with similar roles were acquitted on the same evidence, and the uninjured status of closely related eye-witnesses contradicted the alleged deep-seated enmity motive. Furthermore, weapon recovery yielded a negative forensic report, and an accused's statement under Section 342 Cr.P.C. must be accepted or rejected in toto without relieving the prosecution of its primary burden of proof. Consequently, the High Court allowed the appeal, set aside the conviction and sentences, acquitted the appellant, and declined to confirm the death sentence.
Questions settled- Does the failure of the prosecution to produce material injured eye-witnesses warrant an adverse presumption under Article 129(g) of the Qanun-e-Shahadat Order 1984?
- Whether the suppression of firearm injuries sustained by the accused party during the same incident casts serious doubt on the prosecution case?
- Can an accused person be convicted solely on admissions in their statement recorded under Section 342 of the Code of Criminal Procedure 1898 if the prosecution fails to independently prove its case beyond reasonable doubt?
- Does a negative forensic ballistic report render the recovery of an alleged weapon of offence inconsequential against the accused?
- NEWMuhammad Imran Versus Mst. Maham Manzoor2026 YLR 2156 · Lahore High Court · 2025-11-20Read full judgment →
Summary & questions settled
This constitutional petition arises from a custody dispute over a 12-year-old minor. The Guardian Judge initially accepted the father's petition for custody under Section 25 of the Guardians and Wards Act, 1890, but the District Judge in appeal set aside that order and entrusted the minor to the maternal grandmother, as both parents had remarried and had children from their second marriages. The Lahore High Court examined the minor in chamber, noting her intelligent preference to live with her maternal grandmother as contemplated under Section 17(3) of the Guardians and Wards Act, 1890, and referencing Supreme Court jurisprudence on the right of the child to be heard and the welfare of the minor under international and domestic standards. The High Court upheld the appellate decision, holding that entrusting custody to the maternal grandmother in such sensitive circumstances serves the best interests of the child, and accordingly dismissed the petition while emphasizing the enforcement of a proper visitation schedule.
Questions settled- Whether the intelligent preference of a minor can be a pivotal factor in determining child custody under the Guardians and Wards Act, 1890?
- Can custody of a minor be entrusted to the maternal grandmother when both parents have contracted second marriages and have other children?
- Does the welfare of the minor principle encompass the right of the child to be heard in guardianship proceedings?
- NEWFarhat Iqbal (deceased) Versus Javed Iqbal2026 YLR 2148 · Lahore High Court · 2025-10-06Read full judgment →
Summary & questions settled
This civil revision challenged an appellate judgment that dismissed the petitioner's suit for declaration regarding the unauthorized transfer of her ancestral property. The core legal question was whether an attorney, acting under a General Power of Attorney (GPA), could lawfully transfer the principal's property to his own sons without express consent, and whether prior financial transactions between the parties constituted valid sale consideration. The Lahore High Court held that the transfer was unlawful. The Court found that the respondents failed to prove the alleged payments were sale consideration for the suit property. Furthermore, the Court established that an attorney requires the principal's prior permission, approval, and consent when transferring property to his own close relatives, regardless of general powers granted in the GPA. The appellate court’s finding of an implied understanding was deemed a gross misreading of evidence. Consequently, the Court allowed the revision, set aside the appellate judgment, and restored the trial court's decree in favor of the petitioner, affirming that such self-dealing by an attorney without express authorization is void.
Questions settled- Can an attorney acting under a General Power of Attorney transfer the principal's property to his own close relatives without express permission?
- Do financial transactions between a principal and an attorney, unrelated to the property, constitute valid sale consideration for the transfer of the principal's property?
- Does the failure to produce two independent witnesses for a receipt of payment violate the evidentiary requirements of the Qanun-e-Shahadat Order 1984?
- NEWMuhammad Nadeem Anjum Versus Senior Member/Member (Revenue), Board of Revenue Punjab Lahore2026 YLR 2130 · Lahore High Court · 2025-06-24Read full judgment →
Summary & questions settled
This Constitutional Petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973 challenged concurrent orders of the revenue hierarchy appointing respondent No. 7 (a female candidate) as permanent Lambardar and subsequently allotting her State land measuring 105 kanals 10 marlas as a Lambardari grant. The petitioner claimed hereditary preference, higher evaluation marks, and challenged respondent No. 7's eligibility based on her gender under Rule 19(2)(d) of the West Pakistan Land Revenue Rules, 1968. The Lahore High Court dismissed the petition, upholding the concurrent findings. The Court held that Rule 19(2)(d) is ultra vires Article 25(2) of the Constitution to the extent that it discriminates against women solely based on gender for appointment as Lambardar. Furthermore, no candidate holds a vested right to appointment; due deference must be given to the Collector's discretion unless proven perverse or illegal. As respondent No. 7's appointment was valid, she was lawfully entitled to the Lambardari service grant upon the lifting of the administrative ban.
Questions settled- Is Rule 19(2)(d) of the West Pakistan Land Revenue Rules, 1968 ultra vires Article 25(2) of the Constitution for discriminating against female candidates for appointment as Lambardar?
- Does a candidate possess a vested right to be appointed as a Lambardar based solely on hereditary claims or higher marks?
- Under what circumstances may the High Court in constitutional jurisdiction interfere with the discretion exercised by the District Collector in appointing a Lambardar?
- Can a newly appointed permanent Lambardar be allotted State land reserved as a Lambardari grant after the lifting of an administrative ban by the Board of Revenue?
- NEWHaji Musthaq Hussain Shah Versus Senior Civil Judge/Referee Judge, Khanewal2026 YLR 2118 · Lahore High Court · 2025-10-28Read full judgment →
Summary & questions settled
This constitutional petition challenged an order passed by the Senior Civil Judge/Referee Judge, Khanewal, which dismissed the petitioner's application under Order XVI, Rule 1, Code of Civil Procedure 1908 to summon additional official witnesses in a land acquisition reference. The core legal question was whether a party, after closing their oral evidence, can be permitted to summon witnesses not previously included in the list of witnesses without demonstrating good cause for the omission. The Lahore High Court dismissed the petition, holding that the trial court's order was legally sound. The Court affirmed that under Order XVI, Rule 1, Code of Civil Procedure 1908, parties must file a list of witnesses within seven days of framing issues. Permission to call additional witnesses requires showing good cause for the initial omission, which the petitioner failed to do. Furthermore, the Court clarified that the appropriate procedure for introducing official documents is to obtain certified copies or seek court intervention for production, rather than attempting to reopen oral evidence through late-stage witness summons.
Questions settled- Can a party be permitted to summon witnesses not included in the initial list of witnesses without showing good cause for the omission?
- Is a party entitled to reopen oral evidence to summon official witnesses after formally closing their oral evidence?
- What is the correct procedure for a party to produce documents in the custody of the opposite party under the Code of Civil Procedure 1908?
- NEWMuhammad Iqbal alias Bilal alias Jhatal Versus State2026 YLR 2091 · Lahore High Court · 2025-12-03Read full judgment →
Summary & questions settled
This criminal appeal challenges the conviction and sentence of the appellant, Muhammad Iqbal, for the murder of Muhammad Fazil and attempted robbery. The prosecution alleged that the appellant, along with co-accused, attempted to snatch a motorcycle and shot the deceased. The trial court convicted the appellant under Sections 302(b) and 393 of the Pakistan Penal Code 1860. Upon review, the High Court found the prosecution's case riddled with fatal flaws. Specifically, the Court noted significant inconsistencies regarding the timing of the FIR, the absence of a proven light source during a night-time occurrence, and the failure to establish the presence of eye-witnesses. Furthermore, the identification parade was deemed unreliable due to the appellant's prior exposure to witnesses and the joint nature of the identification. The medical evidence contradicted the ocular account regarding the distance of firing, and the forensic report failed to link the recovered weapon to the crime. Consequently, the Court held that the prosecution failed to prove its case beyond reasonable doubt, set aside the conviction, and acquitted the appellant, establishing that material discrepancies and lack of corroborative evidence entitle the accused to acquittal.
Questions settled- Does a joint identification parade, where multiple accused are identified in a single attempt, possess evidentiary value?
- Is the prosecution required to prove a source of light in a homicide case occurring during hours of darkness?
- Does the presence of blackening around an entry wound in medical evidence contradict an ocular account of firing from a distance?
- What is the legal consequence when a forensic report fails to match a recovered weapon with crime scene empties?
- NEWMuhammad Iqbal Versus State2026 YLR 2066 · Lahore High Court · 2026-04-02Read full judgment →
Summary & questions settled
This criminal appeal challenges the conviction and life imprisonment of the appellants under Section 302(b) of the Pakistan Penal Code 1860 for the murder of the deceased. The core legal question was whether the incident constituted intentional murder or culpable homicide not amounting to murder, given the sudden nature of the altercation and the suppression of injuries sustained by the accused party by the complainant. The Lahore High Court held that the prosecution failed to establish premeditation and that the incident occurred during a sudden fight at the spur of the moment. Consequently, the Court converted the appellants' conviction from Section 302(b) to Section 302(c) of the Pakistan Penal Code 1860, reducing their sentences from life imprisonment to fourteen years of rigorous imprisonment. The key principle laid down is that where an incident involves a sudden fight without premeditation, where the accused does not take undue advantage or act in a cruel manner, and where injuries sustained by the accused are suppressed by the complainant, the conviction should be mitigated to Section 302(c) rather than Section 302(b).
Questions settled- Whether a conviction under Section 302(b) of the Pakistan Penal Code 1860 can be converted to Section 302(c) when the incident arises from a sudden fight without premeditation?
- Does the suppression of injuries sustained by the accused party by the complainant affect the credibility of the prosecution's case regarding the nature of the occurrence?
- Can the benefit of mitigating circumstances, such as the absence of repeated blows, be extended to an accused to reduce a sentence from life imprisonment?
- NEWMansoor Ali Versus Mst. Anam Hussain2026 YLR 2051 · Lahore High Court · 2024-12-24Read full judgment →
Summary & questions settled
The present constitutional petitions arose from concurrent judgments of the lower courts in family litigation concerning the recovery of dower, dowry articles, and maintenance for a wife and minor child. The core legal questions involved whether depreciation on dowry articles during the pendency of a suit can be imposed on the female plaintiff when the defendant husband vaguely contests the claim, whether a father can be burdened beyond his financial means for child maintenance, and whether previously fixed maintenance can be reduced upon an adverse change in the father's financial circumstances. The Lahore High Court held that depreciation on dowry articles cannot be forced on the wife where the husband fails to admit the claim straightforwardly and return the belongings promptly. Furthermore, the Court held that a father cannot be burdened beyond his proven financial capacity, ensuring maintenance strikes a balance between the child's needs and the father's resources, and that maintenance may be reduced if the father's financial means genuinely diminish over time. The matter was remanded to the Appellate Court for fresh determination.
Questions settled- Whether depreciation in the value of dowry articles, during the period of pendency of a suit for their recovery, could be imposed on the female?
- Whether a father can be burdened beyond his financial means, in determining the quantum of maintenance of a child?
- Whether the maintenance of a child, once fixed, can be reduced with the adverse change in the financial means of the father?
- NEWCh. Muhammad Abdul Saleem (deceased) Versus Mst. Aziza Khatoon (deceased)2026 YLR 2017 · Lahore High Court · 2024-11-01Read full judgment →
Summary & questions settled
This Regular Second Appeal challenges the judgment and decree of the District Judge, Lahore, which decreed the respondents' suit for possession of a plot, reversing the trial court's dismissal. The core legal question was whether the respondents, as auction purchasers holding a valid Permanent Transfer Order (PTO) and Permanent Transfer Deed (PTD) issued in 1961, were entitled to possession against the appellants, who claimed title through a subsequent, allegedly fraudulent allotment order issued in 1976. The Court held that the property was no longer available in the settlement pool once the PTD was issued, rendering the subsequent allotment in favor of the appellants' predecessor void, collusive, and coram non judice. The Court emphasized that fraud vitiates the most solemn proceedings, and any title derived from such fraud cannot be validated. Furthermore, the Court affirmed that once a PTD is issued, the Settlement Department becomes functus officio and cannot re-allot the property. Consequently, the appellate court's decision in favor of the respondents was upheld, confirming their superior title based on the earlier, unchallenged auction proceedings.
Questions settled- Can the Settlement Department allot property that has already been transferred via a Permanent Transfer Deed?
- Does fraud vitiate the most solemn proceedings in property allotment cases?
- When does the Settlement Department become functus officio regarding the disposal of property?
- Is a subsequent allotment order valid if the property was not available in the settlement pool?
- NEWSaadat Hussain Versus State2026 YLR 1968 · Lahore High Court · 2025-03-13Read full judgment →
Summary & questions settled
This criminal appeal challenged the conviction and death sentence of the appellant for the murder of his wife. The core legal question was whether the prosecution successfully established the appellant's guilt beyond reasonable doubt through the provided ocular and circumstantial evidence. The Lahore High Court set aside the conviction and acquitted the appellant, holding that the prosecution’s case was fundamentally flawed. The Court found the ocular witnesses unreliable, noting their conduct was contrary to natural human behavior, as they failed to intervene when the appellant allegedly took the victim into a room. Crucially, the witnesses' claim that the room was locked was contradicted by the Investigating Officer, who confirmed the room lacked a door. The Court emphasized that medical evidence is only confirmatory and cannot identify a culprit. Additionally, the prosecution failed to produce natural witnesses, delayed FIR registration, and violated mandatory procedural requirements regarding recoveries under Section 103 of the Code of Criminal Procedure, 1898. Consequently, the Court laid down the principle that a single circumstance creating reasonable doubt entitles an accused to acquittal as a matter of right.
Questions settled- Does the failure of prosecution witnesses to intervene during a crime render their testimony unreliable?
- Can medical evidence alone be used to identify an accused in a criminal case?
- What is the legal effect of failing to associate independent witnesses during a search and recovery under Section 103 of the Code of Criminal Procedure, 1898?
- Is an accused entitled to acquittal if a single circumstance creates reasonable doubt in the prosecution's case?
- NEWSher Azam Khan Versus State2025 YLR 930 · Lahore High Court · 2024-11-28Read full judgment →
Summary & questions settled
This criminal appeal challenges the conviction and life sentences imposed upon the appellants for Qatl-i-Amd under Sections 302 and 324 of the Pakistan Penal Code 1860. The core legal question concerns the reliability of ocular evidence when contradicted by medical reports and independent official records. The Lahore High Court held that the prosecution failed to prove its case beyond reasonable doubt. The Court observed that the eye-witnesses were chance witnesses whose presence was negated by Rescue 1122 emergency records, which failed to mention them. Furthermore, discrepancies between the alleged firing incidents and the medical examination of the deceased, alongside the failure to comply with Section 103 of the Code of Criminal Procedure 1898 regarding weapon recovery, rendered the prosecution's narrative unreliable. The Court established that where a single circumstance creates reasonable doubt in a prudent mind, the accused is entitled to the benefit of the doubt as a matter of right. Consequently, the convictions were set aside, and the appellants were acquitted, emphasizing that the burden of proof remains strictly on the prosecution.
Questions settled- Does a conflict between ocular and medical evidence regarding the seat of injuries warrant the rejection of eye-witness testimony?
- Can official records, such as Rescue 1122 emergency forms, be used to rebut the presence of alleged eye-witnesses at the scene of the crime?
- Is a conviction sustainable when the recovery of the weapon of offense violates the mandatory provisions of Section 103 of the Code of Criminal Procedure 1898?
- What is the legal effect of failing to produce independent witnesses during recovery proceedings?
- NEWMuhammad Imran Versus State2025 YLR 888 · Lahore High Court · 2024-12-11Read full judgment →
Summary & questions settled
This criminal appeal challenged the conviction of the appellant under Section 9(c) of the Control of Narcotic Substances Act, 1997, for the possession of 19 kilograms of heroin. The core legal questions concerned the sufficiency of evidence regarding the recovery proceedings, the safe custody of the contraband, and the application of the presumption of guilt under Section 29 of the Control of Narcotic Substances Act, 1997. The Lahore High Court held that the prosecution failed to establish the case beyond reasonable doubt due to material contradictions in witness testimonies, the failure to prove the nexus between the appellant and the vehicle, and the lack of evidence regarding the safe custody and transmission of the narcotics. Furthermore, the Court found that the prosecution failed to properly exhibit the recovered articles. The Court laid down the principle that the presumption of guilt under Section 29 does not relieve the prosecution of its initial burden to prove the recovery and the accused's possession beyond a shadow of doubt. Consequently, the conviction was set aside, and the appellant was acquitted.
Questions settled- Does the presumption of guilt under Section 29 of the Control of Narcotic Substances Act, 1997 absolve the prosecution from proving its case beyond reasonable doubt?
- What is the legal consequence of a witness making dishonest improvements in their statement to strengthen the prosecution's case?
- Is the failure to prove the ownership of a vehicle from which narcotics were recovered a sufficient ground for acquittal?
- Can evidence of recovered articles be relied upon if they were not produced and exhibited in court in accordance with the Rules and Orders of the Lahore High Court?
- NEWMst. Shahidah Bibi Versus State2025 YLR 867 · Lahore High Court · 2024-11-13Read full judgment →
Summary & questions settled
This criminal appeal challenges the judgment of the trial court convicting and sentencing the appellant under Section 9(1)(3)(c) of the Control of Narcotic Substances Act, 1997 for the alleged possession of 1500 grams of charas. The core legal questions involve whether the prosecution established an unbroken chain of safe custody and safe transmission of the recovered narcotics and sample parcels, and whether material evidence not put to the accused under Section 342 of the Code of Criminal Procedure, 1898 can be used for conviction. The Lahore High Court held that discrepancies in the testimonies regarding recovery, safe custody, and transmission of the sample to the forensic agency created deep doubts, and that incriminating material not put to the accused under Section 342 Cr.P.C. cannot be used against her. Consequently, the appeal was accepted, the conviction was set aside, and the appellant was acquitted on the benefit of the doubt, reinforcing the principle that an unbroken chain of custody is mandatory in narcotics cases.
Questions settled- Whether the failure of the prosecution to prove an unbroken chain of safe custody and safe transmission of narcotic samples vitiates the conviction?
- Can a piece of evidence not put to the accused person at the time of recording a statement under Section 342 of the Code of Criminal Procedure, 1898 be used against him by the prosecution?
- Does a single reasonable doubt or dent in the prosecution's case entitle the accused to an acquittal?
- NEWTariq Mehmood Versus Additional Sessions Judge/Ex-Officio Justice of Peace2025 YLR 86 · Lahore High Court · 2023-12-15Read full judgment →
- NEWS. Akmal (deceased) Versus Model Town Cooperative Housing Society2025 YLR 841 · Lahore High Court · 2022-05-06Read full judgment →
- NEWHabib-ur-Rehman Versus State2025 YLR 835 · Lahore High Court · 2024-11-01Read full judgment →
Summary & questions settled
This matter involves a post-arrest bail petition filed under Section 497 of the Code of Criminal Procedure 1898 arising from FIR No. 52/2024 registered under Section 9(2)-9 of the Control of Narcotic Substances Act, 1997, relating to the alleged recovery of methamphetamine soaked in clothing parcels booked for delivery abroad. The core legal question concerns the effect of an inconclusive forensic report that establishes the presence of a psychotropic substance qualitatively but fails to determine its exact quantitative weight due to analytical limitations. The Lahore High Court held that the absence of a quantitative analysis leaves the precise quantity undetermined, bringing the case within the scope of further inquiry under Section 497(2) of the Code of Criminal Procedure 1898. The court laid down the principle that where a forensic report fails to ascertain the exact quantity of a recovered narcotic or psychotropic substance, creating evidentiary ambiguity regarding the applicable penal tier, the accused becomes entitled to the concession of post-arrest bail pending trial.
Questions settled- Does the absence of a quantitative analysis in a forensic report regarding a recovered narcotic substance bring the case within the scope of further inquiry under Section 497(2) of the Code of Criminal Procedure 1898?
- Whether an accused is entitled to post-arrest bail when the exact quantity of the psychotropic substance remains undetermined by the forensic laboratory?
- What is the distinction between qualitative and quantitative tests for narcotic substances under the Control of Narcotic Substances Act, 1997?
- NEWMuhammad Ashfaq Versus Civil Judge, Samundari2025 YLR 830 · Lahore High Court · 2024-11-13Read full judgment →
- NEWRizwan Sami khan Versus State2025 YLR 811 · Lahore High Court · 2024-12-03Read full judgment →
Summary & questions settled
This criminal appeal challenges the conviction of the appellant for offenses under Sections 376, 292, 500, and 509 of the Pakistan Penal Code 1860. The core legal question was whether the prosecution successfully proved the charges of rape and related offenses beyond a reasonable doubt. The Lahore High Court found that the prosecution’s case suffered from significant evidentiary gaps, including the failure to recover the alleged weapon, the withholding of natural witnesses, and the failure to produce the primary evidence, specifically the memory card and photographs, in court. Furthermore, the prosecution failed to establish the safe custody of evidence and produced inconsistent testimony regarding the victim's family. Crucially, the absence of a medico-legal examination of the victim and the failure to conduct a potency test on the accused, as required under Section 53-A of the Code of Criminal Procedure 1898, created fatal doubts. Consequently, the Court held that the prosecution failed to meet the burden of proof, set aside the conviction, and acquitted the appellant, granting him the benefit of the doubt.
Questions settled- Does the failure to produce a potency test report for an accused in a rape case create a reasonable doubt regarding the prosecution's case?
- Is the failure to produce the primary evidence, such as a memory card and photographs, in court fatal to the prosecution's case?
- Does the failure to establish the safe custody of case property in the police 'Malkhana' undermine the prosecution's evidence?
- NEWNayyar Abbas Versus State2025 YLR 75 · Lahore High Court · 2024-02-13Read full judgment →
Summary & questions settled
This criminal appeal challenges the conviction of the appellant under Section 9(c) of the Control of Narcotic Substances Act, 1997, for the alleged possession of 2250 grams of charas. The core legal question concerns the evidentiary value and authenticity of the recovery memo, which serves as a foundational document in narcotics cases. Upon review, the Court found that the recovery memo failed to mention the FIR number, date, or police station, and prosecution witnesses admitted it was prepared after the FIR's registration. The Court held that the recovery memo must be prepared at the spot with marginal witnesses to ensure transparency and exclude the possibility of false implication. Because the prosecution failed to establish the authenticity of the recovery proceedings, the Court ruled that the conviction could not be sustained. Reaffirming the principle that any reasonable doubt in the prosecution's case entitles the accused to acquittal as a matter of right, the Court set aside the conviction and acquitted the appellant.
Questions settled- Does the failure to mention the FIR number and date on a recovery memo render the recovery suspicious?
- Is the preparation of a recovery memo after the registration of an FIR fatal to the prosecution's case?
- Does the requirement of Section 103 of the Code of Criminal Procedure 1898 apply to all searches under the Control of Narcotic Substances Act 1997?
- Is an accused entitled to acquittal if the prosecution's recovery proceedings are found to be fabricated or procedurally flawed?
- NEWMuhammad Ali Versus Iftikhar Hussain2025 YLR 663 · Lahore High Court · 2024-11-04Read full judgment →
- NEWNoor Khan Versus State2025 YLR 62 · Lahore High Court · 2024-06-27Read full judgment →
Summary & questions settled
This criminal revision petition challenges an order passed by the Additional Sessions Judge dismissing a complaint filed under section 3 of the Illegal Dispossession Act, 2005. The core legal question concerns the proper scope and procedure of conducting inquiries and ordering investigations by courts upon receiving a direct complaint under the Illegal Dispossession Act, 2005, particularly regarding non-cognizable offences. The Lahore High Court held that the trial court failed to conduct a proper inquiry or order an investigation, and ignored crucial background material such as connected police records and warrants of possession. The court set aside the impugned order, remanded the complaint back to the lower court, and laid down the principle that courts must ascertain the truth or falsehood of allegations through proper inquiries or police investigations under section 5 of the Illegal Dispossession Act, 2005, detailing the distinct thresholds and operational stages for inquiries versus investigations in property grabbing matters.
Questions settled- Whether a court is bound to conduct an exhaustive inquiry or order an investigation when the commission of an offence under the Illegal Dispossession Act, 2005 is apparent from the record?
- How do preliminary inquiries and police investigations differ in scope and application within proceedings under the Illegal Dispossession Act, 2005?
- Can a court order an investigation by the police in a non-cognizable case under the Illegal Dispossession Act, 2005?
- What is the evidentiary value of a local inquiry report submitted by a Magistrate or a revenue officer under section 5 of the Illegal Dispossession Act, 2005?
- NEWMuhammad Zareen Versus Additional Sessions Judge, Jhelum2025 YLR 616 · Lahore High Court · 2024-10-11Read full judgment →
Summary & questions settled
This matter comes before the Lahore High Court through a criminal miscellaneous application filed under Section 561-A of the Code of Criminal Procedure 1898, challenging the concurrent orders of the lower courts whereby an application for the exhumation of the dead body of the petitioner's wife, Mst. Maryam Zareen, filed by her real brother, was accepted. The core legal question revolves around whether exhumation and post-mortem examination are permissible to determine the cause of an unnatural death despite the petitioner's objections regarding the sanctity of the grave. The court held that a legal heir has a fundamental right to have their genuine suspicions regarding the unnatural death of a relative investigated, and exhumation serves as an essential tool to unearth the truth and advance the cause of justice. The Lahore High Court laid down the principle that the sanctity of a grave cannot override the paramount necessity of uncovering the real cause of death in cases involving serious suspicion, and exhumation does not inherently determine individual culpability prior to a positive medical report.
Questions settled- Whether a legal heir has the right to seek exhumation of a deceased relative to ascertain the cause of an unnatural death?
- Does the exhumation of a dead body violate the sanctity of the grave when necessary to advance the cause of justice?
- Can concurrent orders for exhumation and post-mortem examination be interfered with under Section 561-A of the Code of Criminal Procedure 1898 without a showing of jurisdictional defect or patent illegality?
- NEWSyed Shehanshah Raza Hussain Rizvi Versus Tariq Nawaz Khan2025 YLR 575 · Lahore High Court · 2024-10-16Read full judgment →
- NEWNoora Versus Province of Punjab2025 YLR 566 · Lahore High Court · 2024-10-30Read full judgment →
- NEWEjaz Ahmed Versus State2025 YLR 451 · Lahore High Court · 2023-11-28Read full judgment →
Summary & questions settled
This judgment addresses Criminal Appeal No. 788-J of 2019, Criminal Appeal No. 588 of 2019, and Murder Reference No. 22 of 2019, arising out of a double-murder conviction under Section 302(b), Pakistan Penal Code 1860, wherein the appellant was awarded the death sentence. The core legal issues revolved around the credibility of chance and related witnesses, the non-production of material physical evidence, uncorroborated recovery, delayed post-mortem examinations, and the standard of appellate review regarding acquittal appeals. The Lahore High Court held that the prosecution failed to prove its case beyond reasonable doubt. The eyewitnesses were chance witnesses who failed to plausibly explain their presence, the vehicle they allegedly used was never recovered or produced, the alleged prime target was left completely unhurt against human nature, and the safe custody and transmission of the recovered firearm was unproven. Consequently, the High Court allowed the appellant's appeal, acquitted him, declined confirmation of the death sentence, and dismissed the complainant's appeal against the co-accused's acquittal.
Questions settled- What duty lies upon chance witnesses to establish their credibility when claiming to have observed an incident away from their residence?
- Does the failure of assailants to target or injure an unarmed prime adversary present at close range cast doubt on the presence of eyewitnesses under Article 129 of the Qanun-e-Shahadat Order, 1984?
- Can a conviction for murder be sustained primarily on abscondence and medical evidence when the substantive ocular account is disbelieved?
- What evidentiary effect does the prosecution's failure to establish safe custody and safe transmission of an alleged crime weapon have on a forensic report?
- Under what circumstances can an appellate court overturn a trial court's order of acquittal?
- NEWUsama Ali Versus State2025 YLR 427 · Lahore High Court · 2024-12-24Read full judgment →
Summary & questions settled
This criminal appeal challenges the conviction and life imprisonment of the appellant for triple murder under Sections 302, 109, 148, and 149 of the Pakistan Penal Code 1860. The core legal question concerns whether the prosecution established the appellant's guilt beyond a reasonable doubt through circumstantial evidence, specifically last-seen testimony, DNA profiling, and weapon recovery. The Lahore High Court held that the prosecution’s case was fundamentally flawed, characterized by investigative 'tunnel vision' and fabricated evidence. The court found the last-seen witnesses unreliable, the forensic evidence—including DNA and shoe identification—procedurally compromised and inconsistent with the crime scene, and the recovery of the weapon planted. Emphasizing that a single reasonable doubt entitles an accused to acquittal, the court ruled that the prosecution failed to prove the charge. Consequently, the conviction was set aside, and the appellant was acquitted. The judgment underscores that investigative bias, confirmation bias, and hindsight bias undermine the integrity of criminal proceedings, necessitating strict judicial scrutiny of circumstantial evidence to prevent the conviction of the innocent.
Questions settled- Does the failure of the prosecution to prove the actual place of occurrence render the entire case doubtful?
- Can a conviction be sustained solely on circumstantial evidence when the chain of evidence is broken by procedural irregularities?
- Is identification of recovered items, such as shoes, valid without expert analysis or independent corroboration?
- Does the doctrine of 'tunnel vision' in police investigations justify the rejection of prosecution evidence?
- NEWWaseem Versus State2025 YLR 378 · Lahore High Court · 2024-10-28Read full judgment →
Summary & questions settled
This criminal petition was filed under Section 497 of the Code of Criminal Procedure 1898 by the accused seeking post-arrest bail in a case registered under Sections 376(iii)/511 of the Pakistan Penal Code 1860 for attempting to commit sodomy with a minor. The core legal question was whether the petitioner was entitled to post-arrest bail when named in the FIR for attempting sodomy on a minor, and how such acts fall within the legal framework of sexual abuse under Sections 377A and 377B of the Pakistan Penal Code 1860. The Lahore High Court held that upon tentative assessment, the allegations and statements of the victim directly linked the accused to an offense under Section 377B, falling within the prohibitory clause of Section 497(1) of the Code of Criminal Procedure 1898, thereby disentitling him to bail. The key principle laid down is that acts previously framed merely as attempts to commit sodomy or rape against minors under eighteen years fall within the comprehensive definition of sexual abuse under Section 377A and are punishable under Section 377B of the Pakistan Penal Code 1860, attracting the prohibitory clause.
Questions settled- Whether an accused charged with attempting to commit sodomy on a minor is entitled to post-arrest bail?
- Do acts previously treated merely as attempts to commit sodomy or rape against minors fall within the definition of sexual abuse under Section 377A of the Pakistan Penal Code 1860?
- Does an offense punishable under Section 377B of the Pakistan Penal Code 1860 fall within the prohibitory clause of Section 497(1) of the Code of Criminal Procedure 1898?
- NEWQamar Masih Versus State2025 YLR 333 · Lahore High Court · 2024-10-09Read full judgment →
Summary & questions settled
This criminal appeal challenges the judgment of the trial court convicting and sentencing the appellant under Section 9(c) of the Control of Narcotic Substances Act, 1997. The core legal question before the court was whether the prosecution successfully established the unbroken chain of safe custody and safe transmission of the recovered narcotic substance from the place of recovery to the Chemical Examiner and subsequently to the trial court. The Lahore High Court held that the prosecution failed to prove the safe custody and transmission of the case property, as there was no evidence on record regarding its handling and transit before reaching the Chemical Examiner, nor was it proven who brought the case property back for production during trial. Consequently, the Chemical Examiner's report lost its reliability, and the conviction could not be sustained. The key principle laid down is that the prosecution must prove an unbroken, unsuspicious, and indubitable chain of custody for narcotics cases, and a failure to establish safe custody and transmission of the sample and case property vitiates the trial and mandates the acquittal of the accused.
Questions settled- Whether the failure of the prosecution to establish an unbroken chain of safe custody and safe transmission of narcotics renders the Chemical Examiner's report inconclusive?
- Does a break in the chain of custody of recovered narcotics entitle the accused to an acquittal without examining the other merits of the case?
- Is the prosecution required to prove through positive evidence who transported the sample of the recovered substance to the laboratory and brought it back to the court?
- NEWAbdul Rehman Versus Nazir Ahmad2025 YLR 322 · Lahore High Court · 2024-09-30Read full judgment →
- NEWMst. Kaneez Fatima Versus Ghulam Husain2025 YLR 302 · Lahore High Court · 2023-12-07Read full judgment →
- NEWDr. Iqrar Ahmad Khan Versus Director General, Anti-Corruption Establishment2025 YLR 281 · Lahore High Court · 2024-07-09Read full judgment →
- NEWImran Ahmad Khan Niazi Versus Election Commission of Pakistan2025 YLR 271 · Lahore High Court · 2023-01-05Read full judgment →
- NEWAbdul Shakoor Versus Rana Abid Mahmood2025 YLR 229 · Lahore High Court · 2023-04-13Read full judgment →
- NEWMuhammad Umar Versus State2025 YLR 197 · Lahore High Court · 2024-05-14Read full judgment →
Summary & questions settled
This appeal challenged the conviction of the appellants for murder and related offenses, which was based entirely on circumstantial evidence, including DNA profiles, fingerprint analysis, and alleged recoveries. The Lahore High Court examined the procedural compliance of the investigation, specifically regarding the collection and handling of forensic evidence under the Police Rules, 1934, and the Punjab Forensic Science Agency Act, 2007. The Court held that the prosecution failed to establish an unbroken chain of evidence, noting significant irregularities in the chain of custody, the direct collection of samples by forensic experts without investigator supervision, and the failure to properly seal and identify recovered articles. The Court emphasized that forensic reports are merely corroborative and cannot sustain a conviction in the absence of substantive proof. Furthermore, the Court ruled that identification of recovered property requires strict procedural adherence similar to suspect identification parades. Finding that the prosecution failed to prove the case beyond reasonable doubt due to these procedural lapses and unreliable evidence, the Court allowed the appeal and acquitted the appellants.
Questions settled- Can a conviction be sustained solely on forensic evidence if the chain of custody protocols under the Police Rules 1934 are breached?
- Does the Punjab Forensic Science Agency have the authority to independently collect evidence from a crime scene without being summoned by the investigating officer?
- Is the identification of recovered articles valid if the property was not sealed and kept in a sealed condition until produced before a Magistrate?
- Can medical evidence alone be used to identify the real assailant in a criminal trial?
- NEWMahmooda Bibi Versus Muhammad Khurshid Alem2025 YLR 164 · Lahore High Court · 2022-10-13Read full judgment →
- NEWBilal Sikandar Versus State2025 YLR 152 · Lahore High Court · 2024-08-21Read full judgment →
Summary & questions settled
The petitioner, Bilal Sikandar, sought post-arrest bail under section 497 of the Code of Criminal Procedure, 1898 in case FIR No.99 of 2024 registered under sections 302 and 311 of the Pakistan Penal Code, 1860 for the alleged honour killing of his sister. The core legal questions involved whether a compromise between the legal heirs warrants bail in an honour killing case and whether an alleged discrepancy between ocular and medical evidence constitutes a case of further inquiry. The Lahore High Court dismissed the petition, holding that an offence committed in the name of honour falls within the ambit of fasad-fil-arz and cannot be summarily compounded to grant bail, as the accused may still face mandatory imprisonment under Section 311 of the Pakistan Penal Code, 1860. Furthermore, minor conflicts between medical and ocular accounts do not warrant bail at the pre-trial stage upon a tentative assessment of evidence. The court laid down the principle that honour killing does not furnish a valid ground for bail and that statutory amendments preclude lenient treatment via compromises in such heinous crimes.
Questions settled- Does a compromise between the legal heirs of a victim provide a valid ground for the grant of post-arrest bail in an honour killing case?
- Can a discrepancy between ocular testimony and medical evidence be considered a sufficient ground for further inquiry under Section 497(2) of the Code of Criminal Procedure, 1898 at the bail stage?
- Does an offence committed in the name or on the pretext of honour fall within the definition of fasad-fil-arz under the Pakistan Penal Code, 1860?
- NEWKhurram Shahzad Versus Zeeshan Nawaz2025 YLR 13 · Lahore High Court · 2023-06-16Read full judgment →
- NEWKhalil Ahmad Versus State2025 YLR 116 · Lahore High Court · 2023-09-14Read full judgment →
Summary & questions settled
The Lahore High Court heard a criminal appeal alongside a murder reference regarding the conviction and sentences awarded to the appellants by the trial court under Sections 302(b), 148, and 149 of the Pakistan Penal Code 1860. The core legal questions pertained to the credibility of ocular testimony from interested and chance witnesses, the effect of unexplained delays in postmortem examinations, conflicts between medical and eye-witness evidence, and uncorroborated recovery evidence. The High Court found that the postmortem examination was delayed by eleven hours, indicating that time was spent in deliberations to fabricate the case and plant chance witnesses. Furthermore, the eye-witnesses were close relatives who provided no plausible justification for their presence and remained unharmed despite close-range firing. Medical evidence contradicted the distance and nature of injuries claimed, and forensic reports showed recovered firearms did not match the crime empties. Reaffirming that a single reasonable doubt entitles an accused to acquittal as a matter of right, the High Court allowed the appeal, set aside the convictions, and declined to confirm the death sentence.
Questions settled- Does an unexplained delay in a postmortem examination create doubt regarding the presence of eye-witnesses at the scene?
- Whether ocular testimony contradicted by medical evidence and forensic reports can form the basis of conviction in a murder trial?
- Can related chance witnesses who offer no plausible justification for their presence be relied upon without independent corroboration?
- Is a single reasonable doubt sufficient to entitle an accused person to acquittal as a matter of right?
- NEWMunir Hussain Shah Versus State2025 YLR 1001 · Lahore High Court · 2024-12-02Read full judgment →
Summary & questions settled
This criminal appeal challenges the judgment of the trial court convicting the appellant under Sections 302(b) and 458 of the Pakistan Penal Code 1860, and sentencing him to death and imprisonment for five years respectively, along with a connected murder reference. The core legal questions involved the reliability of the eyewitness testimonies, the corroborative value of medical evidence and the time of death, the effect of unproved motive, and the quantum of sentence. The Lahore High Court held that the prosecution successfully established the guilt of the appellant beyond a shadow of doubt through prompt FIR lodging, trustworthy ocular accounts, and medical corroboration, notwithstanding an unproved motive and inconsequential weapon recovery. Consequently, the High Court upheld the conviction under Section 302(b) of the Pakistan Penal Code 1860, but converted the death sentence into imprisonment for life, while maintaining the conviction and sentence under Section 458 of the Pakistan Penal Code 1860 and the compensation order under Section 544-A of the Code of Criminal Procedure 1898. The key principles laid down include that an unproved motive can serve as a mitigating circumstance warranting the reduction of a death sentence to life imprisonment, and that the presence of natural eyewitnesses in a night-time house occurrence is given full credence when corroborated by prompt reporting.
Questions settled- Can a conviction for murder under Section 302(b) of the Pakistan Penal Code 1860 be sustained when the prosecution fails to prove the alleged motive?
- Whether the unproved motive can be treated as a mitigating factor for converting a death sentence into imprisonment for life?
- Does the absence of blood-stained earth from the crime scene vitiate the trial or weaken the prosecution case when other incriminating evidence is available?
- Is the testimony of a related eyewitness residing elsewhere sufficient to establish guilt when they offer a plausible explanation for their presence at the crime scene?
- NEWKot Addu Power Company Limited Versus Commissioner Inland Revenue, Regional Tax Officer, Multan2025 PTD 77 · Lahore High Court · 2022-05-25Read full judgment →
- NEWCommissioner Inland Revenue Versus Masood-Ul-Hassan2025 PTD 58 · Lahore High Court · 2024-05-20Read full judgment →
- NEWCommissioner Inland Revenue, Lahore Versus Arco Plastics (Pvt.) Limited Lahore Barrister Pirzada Aurang Zaib , Shahbaz Butt2025 PTD 552 · Lahore High Court · 2018-06-21Read full judgment →
- NEWDefence Housing Authority Versus The Federal Board of Revenue2025 PTD 530 · Lahore High Court · 2024-09-24Read full judgment →
- NEWCommissioner Inland Revenue, Faisalabad Versus Be Be Jan Fibres (Pvt.) Ltd., Faisalabad Amjad Hussain Malik and Ijaz Mehmood Chaudhry , Shahbaz Butt2025 PTD 51 · Lahore High Court · 2022-03-16Read full judgment →
- NEWAmir Khan Versus Additional Collector of Customs (Adjudication)2025 PTD 490 · Lahore High Court · 2025-01-29Read full judgment →
- NEWD.G. Khan Cement Company Limited Versus Federal Board of Revenue2025 PTD 424 · Lahore High Court · 2023-01-24Read full judgment →
- NEWThe Commissioner of Inland Revenue, Legal Division, Rto, Lahore Versus Wire Products (Pvt.) Limited, Lahore Imran Rasool , Shahbaz Butt, Ahsan Mahmood, Khurram Shahbaz Butt, Muhammad Usman Zia and Muhammad Ibraheem Hassan2025 PTD 386 · Lahore High Court · 2022-06-02Read full judgment →
- NEWCommissioner Inland Revenue Versus Standard Ice and Cold Storage, Lahore Ali Asad Gondal , M. Ijaz Ali Bhatti2025 PTD 35 · Lahore High Court · 2022-03-07Read full judgment →
- NEWMrs. Shehla Tariq Saigol Versus Federation of Pakistan through Secretary Finance2025 PTD 313 · Lahore High Court · 2024-06-26Read full judgment →
Summary & questions settled
This intra-court appeal, along with connected matters, addressed the constitutionality of Section 8(2)(b) of the Finance Act, 2022, which imposes Capital Value Tax (CVT) on foreign assets of resident individuals exceeding Rupees one hundred million. The core legal questions revolved around the interpretation of Entry 50 of the Federal Legislative List (Fourth Schedule to the Constitution), specifically whether the phrase "not including taxes on immovable property" entirely restricts Parliament's power to tax immovable property, and the interplay with Article 141 of the Constitution concerning Parliament's extra-territorial legislative competence. A preliminary issue also concerned the appellate court's powers under Order XLI, Rule 33, Code of Civil Procedure, 1908, regarding granting relief without cross-objections. The court held that Parliament has the legislative competence to impose CVT on foreign immovable assets of resident individuals, as provincial legislatures lack extra-territorial jurisdiction for such taxation. The appeals were dismissed, upholding the constitutionality of Section 8(2)(b) of the Finance Act, 2022.
Questions settled- Can the Parliament of Pakistan levy Capital Value Tax on foreign immovable assets owned by resident individuals?
- Does Entry 50 of the Federal Legislative List, which states "Taxes on the capital value of the assets, not including taxes on immovable property," preclude the Parliament from taxing foreign immovable property?
- Can an appellate court exercise powers under Order XLI, Rule 33, Code of Civil Procedure, 1908, to grant relief to parties who have not filed an appeal or cross-objection?
- Do provincial legislatures possess extra-territorial legislative competence to tax immovable property situated outside their territorial limits?
- Should courts lean in favor of upholding the constitutionality of a legislative enactment unless it is ex-facie violative of a Constitutional Provision?
- NEWMuhammad Zubair Versus Federation of Pakistan2025 PTD 274 · Lahore High Court · 2024-10-25Read full judgment →
- NEWPak Gulf Construction (Pvt.) Limited Versus Government of Punjab2025 PTD 255 · Lahore High Court · 2024-06-13Read full judgment →
- NEWD.G. Khan Cement Company Limited Versus The Federal Board of Revenue2025 PTD 199 · Lahore High Court · 2022-04-27Read full judgment →
- NEWThe Commissioner Inland Revenue, Zone-I, Gujranwala Versus Gujranwala Electric Power Company (GEPCO), Gujranwala Mian Yousaf Umar , Shahbaz Butt and Ahsan Mahmud2025 PTD 166 · Lahore High Court · 2022-03-16Read full judgment →
- NEWMehr Dastgir Leather and Footwear Industries (Pvt.) Limited Versus Federation of Pakistan through Secretary Ministry of Finance2025 PTD 16 · Lahore High Court · 2024-09-11Read full judgment →
- NEWFatima Sugar Mills Limited Versus Appellate Tribunal, Inland Revenue, Lahore2025 PTD 148 · Lahore High Court · 2024-10-08Read full judgment →
- NEWCommissioner Inland Revenue, District Zone, Regional Tax Office, Rawalpindi Versus Sh. Ikram Ellahi2025 PTD 137 · Lahore High Court · 2024-09-04Read full judgment →
- NEWCommissioner Inland Revenue, Legal Zone-Lto, Lahore Versus Rasool Nawaz Sugar Mills, Ltd. Syed Zain-ul-Abidein Bokhari , Waseem Ahmad Malik2025 PTD 121 · Lahore High Court · 2023-09-26Read full judgment →
- NEWCommissioner Inland Revenue, Sialkot Versus Chaudhry Steel Mills S.I.E., Daska2025 PTD 101 · Lahore High CourtRead full judgment →
- NEWFaiza Basir Syed Versus Customs Appellate Tribunal2025 PTD 1 · Lahore High Court · 2024-09-11Read full judgment →
- NEWMuhammad Ahsan Versus State2026 PLD 663 · Lahore High Court · 2024-12-18Read full judgment →
Summary & questions settled
This writ petition was filed by the petitioner/accused seeking the quashing of an FIR registered under Section 295A of the Pakistan Penal Code 1860, based on allegations that he issued a fatwa declaring members of the Shia sect as non-Muslims. The petitioner argued that Section 295A PPC is non-cognizable and subject to the complaint procedure under Section 196 Cr.P.C., rendering the FIR a nullity. The High Court analyzed the statutory scheme governing the recording of information, the distinction between entering substance in the daily diary versus the FIR register, and the interplay between Police Rules 1934 and the Cr.P.C. The Court held that registration of an FIR bearing a non-cognizable penal provision does not by itself justify quashing at the preliminary stage, as errors in penal sections can be rectified by police or prosecutors, preliminary investigation can be sanctioned under Section 196B Cr.P.C., or cognizable offences under the Anti-Terrorism Act 1997 may be added. Consequently, the High Court declined to quash the FIR and disposed of the petition with comprehensive procedural directions.
Questions settled- Whether the mere mention of a non-cognizable offence in an FIR provides sufficient grounds for its quashing at the preliminary stage?
- What constitutes the 'book' prescribed by the Provincial Government for entering the substance of information under Section 154 and Section 155 of the Code of Criminal Procedure 1898?
- Whether an investigation conducted into an offence mentioned under Section 196 of the Code of Criminal Procedure 1898 can proceed via preliminary investigation under Section 196B of the Code without prior government sanction?
- Can a police report in a non-cognizable case investigated without the authorization of a Magistrate be treated as a valid report or complaint under Section 190(1) of the Code of Criminal Procedure 1898?
- NEWKhalid Mehmood Versus Sabir Ali2026 PLD 654 · Lahore High Court · 2025-07-17Read full judgment →
Summary & questions settled
This civil revision under Section 115 of the Code of Civil Procedure, 1908 challenges the appellate court judgment dismissing the petitioner's appeal against the trial court's dismissal of a suit for specific performance. The core legal question involves whether an appeal can be dismissed as time-barred when the trial court failed to frame a formal decree-sheet following the dismissal of the suit on merits. The Lahore High Court held that the preparation of a decree-sheet is a mandatory requirement and a condition precedent for the exercise of the right of appeal, and limitation commences from the date of the decree. Since no decree-sheet was prepared, the appellate court erred in computing limitation from the date of the order and dismissing the appeal as barred by time. The Court set aside the impugned appellate judgment, directing the appellate court to ensure the preparation of the decree-sheet and decide the limitation issue afresh.
Questions settled- Whether an appeal can be declared barred by limitation when the trial court has failed to draw up a formal decree-sheet?
- Does the dismissal of a suit for failure to deposit balance sale consideration under the Specific Relief Act amount to a decree or an order?
- Is the preparation of a decree-sheet mandatory before time for filing an appeal begins to run?
- What is the legal effect of an appellate court deciding an appeal without a decree-sheet being annexed to the memorandum of appeal?
- NEWMuhammad Asif Versus State2026 PLD 649 · Lahore High Court · 2025-09-23Read full judgment →
Summary & questions settled
This criminal revision petition challenged the judgments passed by an Additional Sessions Judge and a Family Court in a family complaint concerning the offence of polygamy under Section 6 of the Muslim Family Laws Ordinance 1961. The core legal question was whether a Sessions Judge was competent to hear an appeal against a conviction rendered by a Family Court acting as a Judicial Magistrate under the Family Courts Act 1964, or if such an appeal lies exclusively before the District Judge. The Lahore High Court held that pursuant to Section 5 and Section 20 of the Family Courts Act 1964, Family Courts exercise exclusive jurisdiction over offences under the Muslim Family Laws Ordinance 1961, and under Section 14 of the same Act, appeals from their decisions lie to the District Court, not the Court of Sessions. The Court ruled that any decision rendered by a forum lacking jurisdiction is void under Article 175(2) of the Constitution of Pakistan 1973. Consequently, the High Court set aside the appellate judgment of the Additional Sessions Judge and remanded the matter to the District Judge for fresh disposal.
Questions settled- Whether an appeal against a judgment of conviction passed by a Family Court for an offence under the Muslim Family Laws Ordinance 1961 lies before the Court of Sessions or the District Judge?
- Does a Court or Sessions possess jurisdiction to adjudicate appeals arising from trials conducted by Family Courts under the Family Courts Act 1964?
- What is the legal effect of a decision rendered by a court that lacks jurisdiction under Article 175(2) of the Constitution of Pakistan 1973?
- NEWFauzia Qayyum through Special Attorney Abdul Qayyum Versus Additional District Judge Gujranwala2026 PLD 640 · Lahore High Court · 2025-11-03Read full judgment →
Summary & questions settled
This constitutional petition challenges an appellate judgment that directed the return of a plaint for presentation before a Rent Tribunal, asserting that the Civil Court lacked jurisdiction. The core legal question was whether a Civil Court retains jurisdiction to adjudicate a suit for recovery of rent and damages after the tenant has vacated the premises, or if the Rent Tribunal holds exclusive jurisdiction. The Court held that the jurisdiction of the Rent Tribunal under the Punjab Rented Premises Act, 2009 is premised on the existence of a subsisting landlord-tenant relationship and the tenant's continued occupation of the premises. Once the tenant vacates and possession is restored to the landlord, the Rent Tribunal's jurisdiction ceases. Consequently, the Civil Court possesses plenary jurisdiction under Section 9 of the Code of Civil Procedure, 1908 to try such civil disputes, as no express or implied statutory bar exists. The Court set aside the impugned judgment, ruling that the suit for recovery of arrears is maintainable before the Civil Court.
Questions settled- Does a Rent Tribunal have jurisdiction to adjudicate a dispute after the tenant has vacated the premises and the landlord has regained possession?
- Is a suit for recovery of rent and damages arising from a tenancy agreement maintainable before a Civil Court after the termination of the tenancy?
- Does the definition of 'tenant' under the Punjab Rented Premises Act, 2009 extend to persons who are no longer in occupation of the rented premises?
- Does a Civil Court have the authority to try a suit for recovery of rent arrears in the absence of an express or implied statutory bar?
- NEWMuhammad Ali Ansari Versus Federation of Pakistan through Secretary Ministry of Interior, Islamabad2026 PLD 635 · Lahore High Court · 2025-09-23Read full judgment →
Summary & questions settled
This petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973, challenged the blocking of the petitioner’s Computerized National Identity Card (CNIC) by NADRA, which was executed pursuant to a civil court order during execution proceedings. The core legal question was whether a CNIC constitutes "movable property" subject to attachment or confiscation by a civil court as a coercive measure. The Court held that a CNIC is not movable property; it is the property of the Federal Government, serving solely as proof of identity. It cannot be sold, transferred, inherited, or possessed by anyone other than the holder, and it confers no proprietary rights. Consequently, the Court ruled that civil courts lack the jurisdiction to order the blocking of a CNIC as a coercive measure. The Court affirmed that NADRA may only cancel, impound, or confiscate a CNIC under the specific circumstances and procedures prescribed in Section 18 of the National Database and Registration Authority Ordinance, 2000. The blocking of the petitioner's CNIC was declared illegal and without lawful authority.
Questions settled- Is a Computerized National Identity Card considered movable property of its holder?
- Can a civil court order the blocking of a Computerized National Identity Card as a coercive measure in execution proceedings?
- Under what circumstances can the National Database and Registration Authority cancel or impound a Computerized National Identity Card?
- NEWMuhammad Naseem Versus Asghar Ali Tabassum2026 PLD 630 · Lahore High Court · 2025-06-19Read full judgment →
Summary & questions settled
This civil revision petition arises from a dispute over the estate of the deceased Bashir Ahmed, whose property was transferred to the respondent through four oral gift mutations. The petitioners, who are the deceased's children from a different marriage, challenged the validity of these gifts, alleging fraud and invoking the principle of zarar (harm) under Islamic law, arguing the gifts were intended to deprive them of their inheritance. The Trial Court and Appellate Court concurrently dismissed the suit, finding the gifts valid. The core legal question was whether the gifts constituted an invalid transaction under the principle of zarar due to the exclusion of legal heirs. The High Court dismissed the petition, holding that while a gift intended solely to maliciously deprive legal heirs may be void, a transfer based on natural love, affection, and filial duty—particularly where the donee provided care and support while the petitioners severed ties—is a valid exercise of an owner's autonomy. The Court emphasized that the applicability of the zarar principle is fact-dependent and does not invalidate bona fide gifts made in recognition of personal service.
Questions settled- Does a gift of property by a father to one child to the exclusion of others automatically constitute invalid zarar (harm) under Islamic law?
- Can a court set aside an oral gift on the basis of zarar when the donor was motivated by the donee's care and support rather than malice?
- Is a gift transaction valid if the donor transfers property to a child who provided companionship while other heirs severed ties?
- NEWMst. Nasreen Akhtar Versus Additional District Judge, Chichawatni2026 PLD 627 · Lahore High Court · 2026-02-11Read full judgment →
Summary & questions settled
This constitutional petition under Article 199 of the Constitution of the Islamic Republic of Pakistan, 1973 challenged the appellate court's judgment which had set aside the Family Court's decree for the recovery of dowry articles. The core legal question was whether the refusal of a non-claimant (the petitioner's father) to take a special oath offered by the opposing party could by itself form the legal basis for the dismissal of a suit. The Lahore High Court held that refusal to take a special oath does not warrant drawing a conclusive adverse inference against the refusing party, nor can it override the independent appraisal of evidence already available on record. The ratio laid down is that an appellate court cannot reverse well-reasoned findings of a trial court based solely on the refusal of a party's witness or relative to take a special oath without independently reappraising the evidence on record, and such refusal by a non-claimant cannot extinguish the substantive rights of the actual claimant.
Questions settled- Whether refusal to take a special oath by a non-claimant can by itself form the basis for the dismissal of a suit?
- Does the Oaths Act, 1873 mandate drawing a compulsory adverse inference against a person refusing to take a special oath?
- Can an appellate court reverse a trial court's findings solely on the ground that a party's witness declined a special oath without independently reappraising the evidence?
- NEWNoor Fatima Versus Station House Officer2026 PLD 617 · Lahore High Court · 2025-02-25Read full judgment →
Summary & questions settled
This constitutional petition concerned a Christian woman who, after her marriage to a Christian man, converted to Islam and subsequently married a Muslim man. Her first husband contested the second marriage, arguing that their original union subsisted as no judicial decree of divorce had been obtained, and alleged harassment by police at his instance. The core legal question before the Lahore High Court was whether a married Christian woman's conversion to Islam automatically dissolves her prior marriage, enabling her to lawfully remarry a Muslim man without a formal divorce decree. The Court, considering Islamic and Christian legal perspectives, noted that while conversion does not automatically dissolve a Christian marriage, Islamic law requires dissolution if the non-Muslim husband does not convert within the Iddat period. However, due to disputed facts regarding the intimation of conversion and the commencement of Iddat, the Court declined to determine the validity of the second marriage or potential criminal liability in constitutional proceedings. The petition was disposed of based on the police's assurance to act in accordance with the law, with the Court emphasizing the need for legislative clarity on marriage dissolution upon conversion.
Questions settled- Does the conversion of a married Christian woman to Islam automatically terminate her marriage?
- Can a Christian woman who converts to Islam lawfully contract a second marriage with a Muslim man in the absence of a formal decree of divorce?
- What is the procedure for dissolution of marriage when a non-Muslim wife converts to Islam and her husband remains a non-Muslim?
- What is the role of the Iddat period in the dissolution of marriage upon a non-Muslim wife's conversion to Islam?
- Does the Divorce Act 1869 determine the effect of the conversion of one spouse professing the Christian faith?
- NEWKaneez Begum Versus Additional District Judge2026 PLD 610 · Lahore High Court · 2025-12-18Read full judgment →
Summary & questions settled
This Constitution Petition challenges the orders of the trial court and the appellate court, which recalled an ad-interim injunction granted in a suit for declaration and consequential relief. The petitioner, who had sought an injunction to protect property, repeatedly failed to argue the application, leading the trial court to withdraw the ad-interim relief to regulate its own proceedings. The appellate court subsequently dismissed the appeal against this withdrawal, holding that the order was not a 'case decided' as the main application for interim relief remained pending. The High Court upheld these orders, holding that a court possesses the inherent discretionary power to regulate its own procedure and may withdraw ad-interim relief if a party abuses the process by delaying the adjudication of the pending application. The court affirmed that such procedural orders, which do not finally determine the rights of parties or dispose of the main application, are not appealable. The petition was disposed of with a direction for the petitioner to argue the pending application on its merits.
Questions settled- Can a trial court recall an ad-interim injunction due to the dilatory conduct of a party?
- Is an order recalling an ad-interim injunction, while the main application for interim relief remains pending, considered a 'case decided'?
- Does a court have the inherent power to regulate its own procedure by withdrawing interim relief when a party fails to argue the matter?
- Is an order that does not finally determine the rights of the parties or dispose of a pending application appealable?
- NEWMian Zaheer Abbas Rabbani Versus State2025 PLD 98 · Lahore High Court · 2024-11-13Read full judgment →
- NEWNiagara Mills (Pvt.) Limited Versus Punjab Cooperative Board for Liquidation (PCBL)2025 PLD 79 · Lahore High Court · 2024-09-20Read full judgment →
- NEWHuman Rights Commission of Pakistan Versus Federation of Pakistan through Secretary, Ministry of Economic Affairs, Islamabad2025 PLD 7 · Lahore High Court · 2024-09-06Read full judgment →
- NEWImdad Ullah Versus State2025 PLD 512 · Lahore High Court · 2023-10-25Read full judgment →
Summary & questions settled
This criminal appeal challenges the judgment dated 25.08.2022 passed by the Additional Sessions Judge, Chishtian, convicting the appellant under Section 377-B of the Pakistan Penal Code 1860 and sentencing him to fourteen years of rigorous imprisonment with a fine. The core legal questions involved whether a judgment rendered by a judge designated as a Special Court under the Anti-Rape (Investigation and Trial) Act 2021 is valid without explicitly writing the designation under their signature, whether the testimony of a child witness is inadmissible without a preliminary voir dire test, and whether a conviction can be based on the uncorroborated testimony of a child sexual abuse victim. The Lahore High Court held that technical misdescription or omission of a formal designation does not vitiate jurisdiction if the court was duly notified, that a voir dire test is not strictly mandatory as long as the court is satisfied with the child's intelligence and ability to give rational answers, and that a child victim's testimony can sustain a conviction without strict corroboration if found reliable. The appeal was dismissed.
Questions settled- Does the omission of a judge to explicitly write their designation as a Special Court under their signature vitiate a judgment rendered under the Anti-Rape (Investigation and Trial) Act 2021?
- Is a preliminary voir dire test mandatory to assess the competency of a child witness, and is their testimony inadmissible without it?
- Can an accused be convicted solely on the uncorroborated testimony of a child who is a victim of sexual abuse?
- Are out-of-court complaints made by a child victim of sexual abuse admissible as an exception to the rule against hearsay?
- NEWAllah Ditta Versus Noor Ahmad2025 PLD 508 · Lahore High Court · 2024-12-09Read full judgment →
- NEWMumtaz Ghani Textile (Pvt.) Ltd. Versus Federation of Pakistan through Secretary, Ministry of Finance2025 PLD 502 · Lahore High Court · 2025-01-21Read full judgment →
- NEWSheikh Nadeem Anwar Versus Illaqa Magistrate2025 PLD 496 · Lahore High Court · 2024-11-11Read full judgment →
- NEWTariq Mehmood Versus Fateh Muhammad2025 PLD 491 · Lahore High Court · 2024-12-11Read full judgment →
- NEWTanveer Ahmed Versus Imtiaz Anwar2025 PLD 486 · Lahore High Court · 2024-11-06Read full judgment →
- NEWUnited Bank Ltd. Versus Muhammad Amjad Hayat Khan2025 PLD 425 · Lahore High Court · 2024-04-18Read full judgment →
- NEWRai Muhammad Aslam Versus Additional Sessions Judge2025 PLD 405 · Lahore High Court · 2024-10-28Read full judgment →
Summary & questions settled
This criminal petition challenges an order passed by the Additional Sessions Judge, Hafizabad, granting permanent exemption from personal appearance to the accused, who was residing and earning his livelihood abroad in a criminal trial under the Pakistan Penal Code, 1860. The core legal question was whether earning a livelihood abroad constitutes being 'incapable of remaining before the Court' under Section 540A of the Code of Criminal Procedure, 1898, thereby justifying the dispensation of personal attendance and representation through a pleader. The Lahore High Court held that the phrase 'incapable of remaining before the Court' is an enabling, benevolent provision that must be interpreted liberally and can include circumstances such as earning a livelihood abroad, provided the accused is initially before the court. Furthermore, the Court highlighted that modern technological alternatives like video conferencing can be utilized for virtual attendance to ensure expeditious justice. Consequently, the petition was dismissed, upholding the impugned order of permanent exemption through counsel.
Questions settled- Does the phrase 'incapable of remaining before the Court' under Section 540A of the Code of Criminal Procedure, 1898 include earning a livelihood abroad?
- Can an accused seek permanent exemption from personal attendance during a criminal trial through a pleader?
- Is the use of modern technology such as video link permissible for the virtual attendance of an accused in a criminal trial?
- Does Section 540A of the Code of Criminal Procedure, 1898 require the personal presence of the accused at the time of filing an exemption application?
- NEWMst. Razia Begum Versus Public at Large2025 PLD 40 · Lahore High Court · 2024-10-01Read full judgment →
- NEWJalal Construction Company Versus The Secretary, C & W Department, Lahore2025 PLD 379 · Lahore High Court · 2024-02-09Read full judgment →
- NEWNusrat Aftab Versus Rabeah Hussain2025 PLD 366 · Lahore High Court · 2022-05-06Read full judgment →
- NEWSyed Sibt Hassan Versus Saba Batool2025 PLD 359 · Lahore High Court · 2024-02-19Read full judgment →
- NEWFaraz Iqbal Jamil Versus The Federation of Pakistan2025 PLD 352 · Lahore High Court · 2024-04-25Read full judgment →
- NEWMag Apartments Private Limited Versus Lahore Development Authority2025 PLD 347 · Lahore High Court · 2024-11-18Read full judgment →
- NEWMuhammad Adil Nawaz Bhatti Versus Chairman Union Council No. 116-Eme2025 PLD 340 · Lahore High Court · 2024-01-30Read full judgment →
- NEWSakhawat Hussain Versus Additional District Judge2025 PLD 332 · Lahore High Court · 2024-11-27Read full judgment →
- NEWKashif Law Book House Versus Federation of Pakistan2025 PLD 311 · Lahore High Court · 2024-01-26Read full judgment →
- NEWBilawal Gull Builders Versus Government of Punjab2025 PLD 293 · Lahore High Court · 2024-03-05Read full judgment →
- NEWSabir Ali Versus Munawar2025 PLD 286 · Lahore High Court · 2024-04-24Read full judgment →
- NEWFaysal Bank Limited Versus Dynasel Limited2025 PLD 263 · Lahore High Court · 2024-05-13Read full judgment →
- NEWMst. Misbah Iftikhar Versus Mst. Aleesa2025 PLD 249 · Lahore High Court · 2024-09-26Read full judgment →
- NEWState Versus Muhammad Altaf Ch. Asghar Ali Gill, Deputy Prosecutor General2025 PLD 235 · Lahore High Court · 2023-11-14Read full judgment →
Summary & questions settled
The State filed an appeal under Section 48 of the Control of Narcotic Substances Act 1997 challenging a judgment of the Additional Sessions Judge/MCTC convicting the respondent under Section 9(c) of the Act and sentencing him to fifteen months of rigorous imprisonment upon an amended plea of guilt. The core legal questions addressed were whether an accused can plead guilty at an intermediary stage of a trial after initially denying the charge, and whether a lenient sentence is justified upon such a plea. The Lahore High Court held that there is no specific statutory prohibition preventing an accused from admitting guilt at any stage of a trial to waive their right to a protracted trial, provided the court ensures the admission is voluntary and not for capital or life imprisonment offenses. The court further held that an accused who willingly confesses should be treated more leniently regarding the quantum of sentence to reduce prosecution costs. The appeal was dismissed in limine.
Questions settled- Can an accused person plead guilty at an intermediary stage of a trial after initially denying the charge under the Code of Criminal Procedure 1898?
- Whether the recording of a plea of guilt mid-way through a criminal trial vitiates the conviction or can be legally sustained?
- Is an accused who voluntarily confesses guilt entitled to a more lenient sentence in terms of quantum?
- What is the distinction between ratio decidendi and obiter dicta regarding observations on procedural stages of a trial?