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.

• The State, Aftab and five others vs Aftab, The State and another2025 LHC 1963 · Lahore High Court · 2025-03-11
  free fightsudden quarrelculpable homicide not amounting to murdermitigation of sentencedaman and arshmurder referencebenefit of doubt
  Summary & questions settled

  This judgment disposes of a criminal appeal and a murder reference arising from a private complaint concerning a sudden clash resulting in the death of one person and injuries to several others. The core legal question involved whether the incident constituted a pre-planned murder or a sudden free fight without premeditation, attracting mitigating exceptions. The Lahore High Court held that since both parties were armed, anticipated resistance, and engaged in a sudden altercation where injuries were sustained by both sides without the prosecution fully explaining the injuries on the accused, the case fell within Exception 4 of section 300 of the Pakistan Penal Code 1860, warranting conversion of the principal offender's conviction from section 302(b) to section 302(c). The court laid down the principle that in sudden free fights with mutual provocation and suppressed facts, individual liability is to be determined based on specific acts, and sentences can be modified keeping in view the principles of reformation and rehabilitation.

  Questions settled

  • Whether a sudden fight without premeditation where both parties sustain injuries attracts Exception 4 to section 300 of the Pakistan Penal Code 1860?
  • Can a conviction under section 302(b) be converted to section 302(c) in the absence of cruel or unusual manner of assault during a free fight?
  • Whether installments for the payment of Daman and Arsh can be granted to a convict under sections 337X and 337-Y of the Pakistan Penal Code 1860?
  • Does the failure of the prosecution to explain injuries sustained by the accused create a dent in the prosecution case requiring resolution in favor of the defence?
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• The State, Abdul Rasheed vs Abdul Rasheed, The State2025 LHC 1844 · Lahore High Court · 2025-03-10
  Qatl-i-AmdMurder ReferenceCriminal AppealEyewitness testimonyChance witnessBenefit of doubtBurden of proofDelay in FIRDelay in post-mortemRecovery evidence
  Summary & questions settled

  This judgment addresses a criminal appeal against conviction for Qatl-i-Amd under Section 302, Pakistan Penal Code, and a murder reference for confirmation of a death sentence. The core legal questions revolved around the reliability of eyewitness testimony, the veracity of the motive, the legality of recoveries, and the burden of proof. The Lahore High Court acquitted the appellant, setting aside his conviction and sentence, and answered the murder reference in the negative. The court held that the prosecution failed to prove its case beyond a reasonable doubt, finding the eyewitnesses to be 'chance witnesses' whose presence was not credibly explained, especially given the absence of a light source at night. Significant delays in reporting the incident and conducting the post-mortem examination, coupled with the non-production of natural witnesses and procedural defects in recoveries, further undermined the prosecution's narrative. The court reiterated that the burden of proof rests squarely on the prosecution and does not shift to the accused, even when a death occurs in their house.

  Questions settled

  • Can eyewitness testimony be relied upon if the witnesses are 'chance witnesses' who fail to credibly explain their presence at the scene of occurrence?
  • Does the absence of a proven light source at a night-time occurrence render eyewitness identification unreliable?
  • What is the impact of a significant and unexplained delay in lodging the First Information Report (FIR) and conducting the post-mortem examination on the prosecution's case?
  • Are recoveries made in violation of Section 103, Code of Criminal Procedure, admissible as incriminating evidence?
  • Does the burden of proof shift to the accused to explain an unnatural death occurring in their house, even if the prosecution's initial case is weak?
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• The State vs Asj, etc2025 LHC 3544 · Lahore High Court · 2025-04-09
  inter-provincial tradeessential commoditiesconstitutional lawpresidential assentsupardariseizure of goodsPunjab Prevention of Speculation in Essential Commodities Act 2021
  Summary & questions settled

  This petition challenged an order by the Additional Sessions Judge granting Supardari (custody) of sugar seized under the Punjab Prevention of Speculation in Essential Commodities Act, 2021. The core legal question was whether the Act of 2021 could validly restrict the inter-provincial transportation of essential commodities without Presidential assent, as required by Article 151 of the Constitution of Pakistan 1973. The Court held that the transaction, involving the movement of goods from Punjab to Sindh, constituted inter-provincial trade. It determined that the Act of 2021, lacking the mandatory Presidential assent required under Article 151(4) for provincial laws imposing restrictions on inter-provincial trade, could not legally regulate or restrict such movement. Consequently, the seizure of the goods by the authorities was found to be without lawful authority and unconstitutional. The Court dismissed the State's petition, affirming that the provincial statute could not override the constitutional guarantee of free inter-provincial trade. The judgment establishes that provincial legislation restricting inter-provincial commerce is invalid unless it strictly complies with the constitutional requirements of Presidential assent.

  Questions settled

  • Does the Punjab Prevention of Speculation in Essential Commodities Act, 2021 apply to the inter-provincial transportation of essential commodities?
  • Is Presidential assent required for a provincial law that imposes restrictions on inter-provincial trade under Article 151 of the Constitution of Pakistan 1973?
  • Can a provincial authority seize goods in transit between provinces under a statute that lacks the mandatory Presidential assent required by the Constitution?
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• The State through Deputy Prosecutor General Punjab, Multan vs Senior Civil2025 LHC 4418 · Lahore High Court · 2025-06-04Read full judgment →
• The State and others vs Muhammad Rafi alias Muhammad Rafique and others2025 LHC 1627 · Lahore High CourtRead full judgment →
• The State and others vs Muhammad Irfan alias Pomi and others2025 LHC 3801 · Lahore High Court
  qatl-i-amdocular testimonymitigating circumstancescourt languageSection 103 CrPCdeath sentence commutationfair trialappreciation of evidence
  Summary & questions settled

  This criminal appeal challenged the conviction and death sentence of the appellant for the murder of Abdul Nasir, alongside a petition against the acquittal of co-accused. The core legal questions concerned the reliability of ocular testimony from related witnesses, the impact of failed recovery and motive evidence on sentencing, and the procedural requirements for recording evidence in subordinate courts. The Court held that the ocular account, corroborated by medical evidence, was sufficient to establish guilt, despite the appellant's relationship with the witnesses. However, the Court found that the prosecution failed to prove the motive and that the recovery of the weapon violated Section 103 of the Code of Criminal Procedure 1898. Consequently, while maintaining the conviction under Section 302(b) of the Pakistan Penal Code 1860, the Court commuted the death sentence to life imprisonment. The Court also issued mandatory directions to subordinate courts to ensure simultaneous Urdu translation of evidence recorded in English to uphold the right to a fair trial under Article 10-A of the Constitution of Pakistan 1973 and to comply with Article 251.

  Questions settled

  • Does the relationship of eye-witnesses to the deceased automatically render their testimony unreliable?
  • Can a conviction be maintained if the prosecution fails to prove the motive and recovery of the weapon?
  • What are the procedural requirements for recording evidence in subordinate courts regarding the language of the record?
  • Does the acquittal of co-accused in a murder case necessarily invalidate the conviction of the principal offender?
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• The State and others vs Muhammad Arshad and others2025 LHC 3447 · Lahore High Court
  murdercommon objectplea of alibiocular evidencedeath sentenceburden of proofcriminal appeal
  Summary & questions settled

  This criminal appeal arose from a trial court judgment convicting multiple appellants for murder and attempted murder in a private complaint case. The primary legal questions concerned the sufficiency of evidence to sustain convictions under the doctrine of common object and the validity of a plea of alibi raised by one appellant. The Court held that the prosecution failed to establish the common object for five appellants, leading to the setting aside of their convictions for those specific charges and a reduction of their sentences to time served. Conversely, the Court upheld the convictions and death sentences of two appellants, finding the ocular testimony of injured witnesses credible and rejecting the plea of alibi due to a lack of substantiating evidence. The Court affirmed the principle that the burden of proof for a plea of alibi rests entirely on the accused, who must provide concrete, verifiable evidence rather than mere assertions. Furthermore, the judgment emphasized that while an accused is not required to enter the witness box, failing to do so when asserting a specific factual alibi weakens the defense.

  Questions settled

  • Does the failure of an accused to produce jail records or independent evidence to substantiate a plea of alibi render the plea ineffective?
  • Can a conviction based on the doctrine of common object be sustained when the prosecution fails to prove the shared intent of the accused?
  • Is an accused required to enter the witness box to prove a plea of alibi under the Code of Criminal Procedure 1898?
  • Does the granting of post-arrest bail by the Supreme Court based on a plea of alibi preclude the trial court from evaluating the merits of that plea during the trial?
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• The Province of Punjab through Secretary, Sports & Youth Affairs2025 LHC 794 · Lahore High Court · 2025-02-24
  condonation of delaylimitationland acquisitiongovernment litigationsufficient causetime-barred appealvested rights
  Summary & questions settled

  This matter concerns an application for condonation of a 318-day delay in filing an appeal under Section 54 of the Land Acquisition Act, 1894, against a judgment enhancing compensation for acquired land. The core legal question was whether internal administrative delays and alleged lack of knowledge by the government department constituted sufficient cause to condone the delay. The Court held that the application for condonation was meritless and dismissed the appeal as time-barred. The Court affirmed that government departments are not entitled to preferential treatment or leniency regarding limitation and must be treated like ordinary litigants. It emphasized that the law of limitation is not a mere technicality but creates vested rights for the opposing party. Furthermore, the Court established that sufficient cause requires a satisfactory explanation for each day of delay, and internal departmental correspondence or administrative sluggishness does not satisfy this requirement. The principle remains that the law aids the vigilant, not the indolent, and government functionaries cannot escape the consequences of their own carelessness.

  Questions settled

  • Can a government department claim preferential treatment or leniency regarding the law of limitation?
  • Does internal administrative correspondence or delay within a government department constitute sufficient cause for condoning a delay in filing an appeal?
  • Is the court required to condone a delay in filing an appeal if the appellant fails to explain each day of the delay?
  • Does the Limitation Act, 1908 apply to appeals filed under Section 54 of the Land Acquisition Act, 1894?
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• The Commissioner Inland Revenue. Rto, Faisalabad vs Mr. Zohaib Ali2025 LHC 5557 · Lahore High Court · 2025-09-08Read full judgment →
• The Chief Administrator of Auqaf, Punjab, Lahore and 02 others vs Muhammad Panah Nomani and 20 others2025 LHC 259 · Lahore High CourtRead full judgment →
• The Bank of Punjab vs M/s Hira Textile Mills Limited and 08 others2025 LHC 3488 · Lahore High Court · 2025-05-14Read full judgment →
• The Bank of Punjab vs M/s Agri International & 05 others2025 LHC 887 · Lahore High Court · 2025-03-18Read full judgment →
• TCS etc vs Muhammad Siddique Ghumman etc2025 LHC 3888 · Lahore High Court · 2025-06-03Read full judgment →
• Tariq Rehman Chohan vs The State and another2025 LHC 5337 · Lahore High Court · 2025-08-18
  post-arrest bailcriminal breach of trustdishonest chequemistaken bank transferprohibitory clauseimplied entrustment
  Summary & questions settled

  The petitioner sought post-arrest bail in a case involving Section 489-F of the Pakistan Penal Code 1860, following the dishonour of a cheque issued to a bank for funds mistakenly transferred to his account. The core legal questions were whether the receipt of mistakenly transferred funds constitutes 'entrustment' under Section 405 of the Pakistan Penal Code 1860, thereby attracting Section 406 of the Pakistan Penal Code 1860, and whether bail should be granted for offenses outside the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898 under these circumstances. The Court held that the receipt of such funds creates an implied entrustment, making the petitioner liable for criminal breach of trust alongside the dishonour of the cheque. Consequently, the Court ruled that a joint charge for both offenses is maintainable. Despite the offenses not falling within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898, the Court refused bail, citing the exceptional circumstances of the case, the petitioner's dishonest conduct, and the lack of repentance, establishing that bail is not a rule of universal application even in non-prohibitory cases.

  Questions settled

  • Does the receipt of funds mistakenly transferred into a bank account constitute 'entrustment' under Section 405 of the Pakistan Penal Code 1860?
  • Can a joint charge for offenses under Section 489-F and Section 406 of the Pakistan Penal Code 1860 be brought against an accused?
  • Is bail a matter of right in cases not falling within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
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• Tariq Mehmood vs Inspector General of Police and 4 others2025 PLJ Lahore 630 · Lahore High Court · 2025-03-13Read full judgment →
• Tariq Mehmood Aamir vs Government of the Punjab2025 LHC 3368 · Lahore High Court · 2025-05-15Read full judgment →
• Talib Hussain vs Muhammad Akram2025 LHC 4613 · Lahore High Court · 2025-06-20Read full judgment →
• Tahir Javed vs Muhammad Sharif2025 LHC 4635 · Lahore High Court · 2025-07-02Read full judgment →
• Tahir Jamal vs Government of the Punjab, etc2025 LHC 14 · Lahore High Court · 2025-01-07Read full judgment →
• T.L.C. Institute of Nursing & other Allied Sciences through its Chief Executive2025 LHC 4837 · Lahore High CourtRead full judgment →
• Sympl Energy Pvt Ltd vs Presiding Officer, etc2025 LHC 3362 · Lahore High Court · 2025-05-14Read full judgment →
• Syeda Muskan Zahra vs District Police Officer and others2025 LHC 5251 · Lahore High Court · 2025-08-07Read full judgment →
• Syed Sajid Raza vs Muhammad Ali Din2025 LHC 4668 · Lahore High Court · 2025-06-30Read full judgment →
• Syed Safeer Abbas Kazmi and 128 others vs Chief Executive Officer, District2025 LHC 5256 · Lahore High Court
  regularization of servicecontingent paid staffwork-charge employeesconstitutional petitionright to livelihoodequality before lawservice law
  Summary & questions settled

  This constitutional petition concerns the discontinuation of services of contingent paid staff (Sanitary Patrols) who had been employed on a work-charge basis since 2015-2016. The core legal question was whether these employees, having served for a significant duration, were entitled to regularization under the government's 2021 policy and the Industrial and Commercial Employment (Standing Orders) Ordinance, 1968. The Court held that the termination orders were illegal and set them aside. The ratio of the decision is that employees engaged on a work-charge basis against posts of a permanent nature, who have served for a considerable period, cannot be denied regularization through the use of artificial breaks in service. The Court emphasized that such long-term employment indicates the permanent nature of the work. Furthermore, the Court ruled that the respondents discriminated against the petitioners by failing to regularize them while regularizing similarly situated employees, violating Article 25 of the Constitution. The judgment affirms that the right to livelihood is protected, and authorities cannot arbitrarily terminate employees to avoid statutory obligations regarding regularization.

  Questions settled

  • Can contingent paid staff employed for a long duration against permanent posts claim regularization of their services?
  • Does the practice of renewing short-term contracts with artificial breaks preclude an employee from seeking regularization?
  • Is the state prohibited from discriminating against employees by regularizing some similarly situated staff while denying others?
  • Does the right to life under the Constitution include the right to livelihood, protecting employees from arbitrary termination?
  Read full judgment →
• Syed Nazir Hussain Shah vs Deputy Commissioner, etc2025 LHC 4449 · Lahore High Court · 2025-06-26Read full judgment →
• Syed Imtiaz Hussain (Deceased) Through his Legal Heirs etc vs Muhammad Hussain and 35 others2025 LHC 5519 · Lahore High CourtRead full judgment →
• Sultan alias Panun, Fida Hussain, Niaz Hussain, Inaam Mehdi vs The State, etc2025 LHC 825 · Lahore High CourtRead full judgment →
• Suleman Shahbaz Sharif vs Additional Sessions Judge, etc2025 LHC 5178 · Lahore High Court · 2025-07-31Read full judgment →
• Sui Northern Gas Pipelines Ltd vs Waseem Majid Malik & others2025 LHC 3529 · Lahore High Court · 2025-04-22Read full judgment →
• State Life Insurance Corporation vs The Cooperative Insurance Society of Pakistan Limited2025 LHC 2367 · Lahore High CourtRead full judgment →
• Sohail vs Station House Officer, etc2025 LHC 3151 · Lahore High Court · 2025-05-16Read full judgment →
• Shoukat Babar Virk vs The State & another2025 LHC 4784 · Lahore High Court · 2025-04-10
  post-arrest bailembezzlementcognizable offencerecidivismtrust propertyforgeryprohibitory clausecriminal conduct
  Summary & questions settled

  This petition concerns a post-arrest bail application in a case involving allegations of embezzlement of funds from the A.Q. Khan Trust and forgery. The petitioner challenged the FIR's validity, arguing that the absence of a complaint by the State Bank of Pakistan violated the Foreign Exchange Regulation Act, 1947. The court addressed whether this procedural defect invalidated the FIR and whether bail should be granted for offences not falling within the prohibitory clause of Section 497, Code of Criminal Procedure 1898. The court held that where an FIR includes a major, cognizable offence (Section 406, Pakistan Penal Code 1860) alongside subservient offences, the cognizable offence serves as the controlling provision, rendering specific authorization requirements for the subservient offences redundant. Regarding bail, the court affirmed that it is not a rule of universal application for non-prohibitory offences. It held that courts may exercise discretion to refuse bail based on the accused's conduct, including previous or subsequent criminal acts, as relevant under Article 21 of the Qanun-e-Shahadat, 1984, to assess the likelihood of recidivism and protect the public interest.

  Questions settled

  • Does the presence of a cognizable offence in an FIR render the procedural authorization requirements for subservient offences under the Foreign Exchange Regulation Act, 1947 redundant?
  • Is the grant of bail a rule of universal application for offences that do not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Can an accused's previous or subsequent conduct be considered by a court when determining whether to exercise discretion in granting bail?
  Read full judgment →
• Shiraz Ahmad vs The State, etc2025 LHC 3190 · Lahore High Court · 2025-05-14
  criminal revisioncognizance of offenceprior sanctionspecial statuteelectronic crimesjurisdictionstatutory interpretation
  Summary & questions settled

  This criminal revision petition challenged an order of the Additional Sessions Judge, Lahore, which declined the petitioner's application for obtaining government sanction under Section 196 of the Code of Criminal Procedure, 1898, for taking cognizance of an offence under Section 295-A of the Pakistan Penal Code, 1860. The petitioner was facing trial for offences under the Pakistan Penal Code, 1860, and the Prevention of Electronic Crimes Act, 2016. The core legal question was whether the requirement of prior sanction under Section 196 of the Code of Criminal Procedure, 1898, applies to offences tried by a court established under the special provisions of the Prevention of Electronic Crimes Act, 2016. The Court held that the provisions of the Prevention of Electronic Crimes Act, 2016, and the Pakistan Penal Code, 1860, are interlinked, and that offences under the former are to be tried by a court specifically established under that Act. Consequently, the Court ruled that Section 196 of the Code of Criminal Procedure, 1898, does not apply to proceedings before a court constituted under a special statute when such application is inconsistent with the Special Act, thereby dismissing the revision petition.

  Questions settled

  • Does the requirement of prior sanction under Section 196 of the Code of Criminal Procedure, 1898, apply to offences tried by a court established under the Prevention of Electronic Crimes Act, 2016?
  • Are the offences under Section 11 of the Prevention of Electronic Crimes Act, 2016, and Sections 295-A, 295-B, 295-C, and 298-C of the Pakistan Penal Code, 1860, interlinked for the purpose of trial?
  • Does the Prevention of Electronic Crimes Act, 2016, override the procedural requirements of the Code of Criminal Procedure, 1898, regarding sanction for prosecution?
  Read full judgment →
• Sheroz Yousaf, The State vs The State, Sheroz Yousaf2025 LHC 3308 · Lahore High Court · 2025-05-20
  Qatl-e-amdmurderous assaultocular accountmedical evidencemitigating circumstancesdeath sentence commutationcriminal appealforensic corroboration
  Summary & questions settled

  This matter concerns a criminal appeal against the conviction and death sentence of the appellant for the murder of one individual and murderous assault on two others, alongside a murder reference for sentence confirmation. The core legal questions involved the reliability of the ocular account in light of alleged medical discrepancies and whether the circumstances warranted the capital punishment. The Lahore High Court upheld the conviction, finding the ocular account consistent and corroborated by forensic evidence, despite minor discrepancies regarding the number of injuries, which were explained by the victim falling after the initial gunshot. However, the Court modified the sentence, commuting the death penalty to life imprisonment. The ratio established that where the motive involves a sudden altercation or heat of passion without clear premeditation, it constitutes a mitigating factor for sentencing. The Court affirmed that while minor inconsistencies in witness testimony do not invalidate the prosecution's case, the absence of evidence regarding premeditation justifies leniency in capital sentencing, maintaining the conviction while reducing the penalty to life imprisonment.

  Questions settled

  • Does a discrepancy between the number of injuries stated in the FIR and the post-mortem report necessarily invalidate the prosecution's ocular account?
  • Can a sudden flare-up in the heat of passion constitute a mitigating factor for the reduction of a death sentence to life imprisonment?
  • Are minor inconsistencies in witness testimony sufficient to destroy the credibility of the prosecution's case?
  • Does the recovery of a weapon and forensic matching of cartridge cases provide sufficient corroboration to an ocular account?
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• Sheraz, etc vs The State, etc2025 LHC 2663 · Lahore High Court · 2025-04-21
  adulterationPunjab Food Authority Actbenefit of doubtcriminal appealseizure procedurephysical evidencefood safety
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence handed down by a Judicial Magistrate under the Punjab Food Authority Act, 2011, regarding allegations of operating a synthetic milk manufacturing unit. The core legal questions concerned whether the prosecution sufficiently proved the charges, specifically regarding the ownership of the premises, the production of physical evidence, and compliance with mandatory procedural requirements for seizures. The Lahore High Court held that the prosecution failed to establish the appellants' ownership of the premises, neglected to produce or exhibit the seized physical evidence in court, and failed to comply with the mandatory requirement under Section 13(2) of the Punjab Food Authority Act, 2011, to provide a seizure statement to the accused. Furthermore, the court noted the absence of chemical analysis reports to substantiate the nature of the seized materials. Consequently, the court set aside the convictions, extending the benefit of doubt to the appellants. The judgment reinforces the principle that failure to produce material evidence and adhere to mandatory procedural safeguards vitiates a conviction, necessitating acquittal.

  Questions settled

  • Does the failure to produce and exhibit seized physical evidence in court vitiate a conviction?
  • Is the failure of a Food Safety Officer to provide a seizure statement to the accused a violation of mandatory procedural law?
  • Can a conviction be sustained under the Punjab Food Authority Act, 2011, without chemical analysis proving the nature of the seized materials?
  Read full judgment →
• Sher Muhammad vs Karam Hussain2025 LHC 3050 · Lahore High Court · 2025-05-15Read full judgment →
• Sheikh Proteins Pvt. Ltd vs Punjab Food Authority, Lahore etc2025 LHC 2696 · Lahore High Court · 2025-04-30Read full judgment →
• Sheikh Naseem Akhtar vs Commissioner Inland Revenue (Legal) etc2025 LHC 2021 · Lahore High Court · 2025-03-03Read full judgment →
• Sheikh Anwar ul Haq vs Abdul Ghaffar etc2025 LHC 4441 · Lahore High Court · 2025-06-19Read full judgment →
• Sheikh Allah Bakhsh vs Additional District Judge, etc2025 LHC 4283 · Lahore High Court · 2025-05-07
  contempt of courtstatus quoviolation of court ordersui generis proceedingswillful disobedience
  Summary & questions settled

  This contempt petition was filed under Article 204 of the Constitution of Islamic Republic of Pakistan, 1973, alleging that the respondents violated a status quo order passed by the Lahore High Court regarding the property in dispute. The petitioner claimed the respondents breached the order by breaking a boundary wall and starting construction. The respondents denied the violation, asserting lawful possession and denying any new construction, a fact supported by the local SHO's report. The Lahore High Court observed that contempt proceedings are sui generis, requiring clear, deliberate, and willful disobedience, and that the disputed possession of the property was already pending adjudication before the civil court. Finding that the petitioner failed to establish willful disobedience of its order through reliable material, the court held that no case for contempt was made out. Consequently, the High Court dismissed the contempt petition as devoid of force.

  Questions settled

  • Can a party be punished for contempt of court without establishing clear, deliberate, and willful disobedience of an order?
  • Are contempt proceedings bound by the technical rules of the Code of Civil Procedure or the Code of Criminal Procedure?
  • Whether contempt proceedings can be initiated when the underlying question of possession is seriously disputed and sub judice before a civil court?
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• Sheikh Ali Jaffar vs The Registrar, Lahore High Court, Lahore2025 LHC 2391 · Lahore High Court
  misconductdisciplinary proceedingsreturning officerfunctus officiodouble jeopardyservice appealelection petition
  Summary & questions settled

  This service appeal challenges the dismissal of the appellant, a former Civil Judge and Returning Officer, from service following disciplinary proceedings. The core legal questions concern whether a Returning Officer possesses the legal authority to alter declared election results via a corrigendum after becoming functus officio, and whether such unauthorized action constitutes misconduct warranting dismissal. The Court held that a Returning Officer lacks the jurisdiction to modify election results once declared, as such disputes are exclusively reserved for Election Tribunals. The Court affirmed that the appellant’s unauthorized alteration of results and subsequent procedural irregularities constituted misconduct. Furthermore, the Court rejected the plea of double jeopardy, ruling that the disciplinary inquiry was an independent administrative process distinct from previous complaints. The judgment establishes that disciplinary proceedings are governed by the doctrine of preponderance of probabilities rather than the strict standards of criminal trials, and that a public officer’s deliberate departure from established legal procedure, especially in election matters, constitutes actionable misconduct justifying removal from service.

  Questions settled

  • Does a Returning Officer have the legal authority to alter election results after they have been officially declared?
  • Does the unauthorized alteration of election results by a Returning Officer constitute misconduct warranting dismissal from service?
  • Are disciplinary proceedings initiated after a previous administrative complaint barred by the principle of double jeopardy?
  • What is the standard of proof required in disciplinary proceedings against a civil servant?
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• Sheikh Akhtar Aziz vs Province of Punjab and others2025 MLD 55 · Lahore High Court · 2023-12-12Read full judgment →
• Shehnaz Akhtar Zahoor Cheema and another vs The Additional District2025 MLD 552 · Lahore High Court · 2024-12-17Read full judgment →
• Shakeel Ahmad vs The State2025 LHC 3222 · Lahore High Court · 2025-03-20
  criminal appealmurder referenceplea of guiltbenefit of doubtocular evidencedishonest improvementdelayed FIRadverse inference
  Summary & questions settled

  This criminal appeal and murder reference arose from a trial court judgment convicting the appellant, Shakeel Ahmad, for murder and causing hurt. The core legal questions concerned the sustainability of the conviction based on a qualified plea of guilt followed by a full trial, and the reliability of the prosecution's ocular and medical evidence. The Lahore High Court held that the conviction was unsustainable. The Court established that an unexplained delay in FIR registration is fatal to the prosecution's case. Furthermore, it affirmed that when a trial court proceeds with a full trial after an initial plea of guilt under Section 265-E of the Code of Criminal Procedure 1898, that confession cannot subsequently be used to the accused's detriment. The Court also held that dishonest improvements in witness testimony render them unreliable, and withholding cross-examination of a witness warrants an adverse inference under Article 129 of the Qanun-e-Shahadat Order 1984. Consequently, the Court granted the appellant the benefit of doubt, set aside the conviction, and answered the Murder Reference in the negative.

  Questions settled

  • Can a confession made under Section 265-E of the Code of Criminal Procedure 1898 be used against an accused if the trial court proceeds to conduct a full trial?
  • Does the withholding of cross-examination of a prosecution witness allow for an adverse inference under Article 129 of the Qanun-e-Shahadat Order 1984?
  • Is a conviction sustainable when the prosecution witnesses make dishonest improvements to align their testimony with medical evidence?
  • What is the legal effect of an unexplained delay in lodging an FIR on the prosecution's case?
  Read full judgment →
• Shakarganj Food Products Limited and another vs Federal Board of Revenue and others2025 PTD 659 · Lahore High Court · 2024-09-04Read full judgment →
• Sunny Hakim vs The State, etc2025 LHC 5113 · Lahore High Court · 2025-07-10
  post-arrest bailcriminal prosecution serviceprosecutorial independencepublic intereststatutory delayidentification paradeburden of proof
  Summary & questions settled

  This petition for post-arrest bail concerns an accused charged under Sections 394/411 of the Pakistan Penal Code 1860. The Court addressed significant procedural lapses by the prosecution, specifically the failure to prepare cases adequately and the inefficient handling of record production, contrary to Supreme Court directives. The judgment clarifies the independence of the Criminal Prosecution Service under the Punjab Criminal Prosecution Service (Constitution, Functions and Powers) Act, 2006, emphasizing that prosecutors are public servants who must act independently and in the public interest, free from government pressure. The Court held that the prosecution failed to discharge its burden of proof regarding the identification of the accused, as the injured party did not participate in the identification parade. Furthermore, the Court found that the petitioner had completed the statutory period of incarceration without the trial concluding, and the delay was attributable to the prosecution. Consequently, the Court granted post-arrest bail, holding that the accused made a case for further inquiry on merits and satisfied the statutory grounds for bail due to trial delay.

  Questions settled

  • Are prosecutors under the Punjab Criminal Prosecution Service (Constitution, Functions and Powers) Act, 2006 considered civil servants?
  • Does the burden of proof 'beyond reasonable doubt' apply at the pre-trial bail stage?
  • Can a prosecutor be directed by government authorities to achieve a pre-determined outcome in a criminal case?
  • What is the legal effect of the Punjab Criminal Prosecution Service (Constitution, Functions and Powers) Act, 2006 on the applicability of the Punjab Civil Servants Act, 1974 to prosecutors?
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• Shahzad Nazir vs Election Commission of Pakistan and 22 Others2025 LHC 3892 · Lahore High Court · 2025-02-18Read full judgment →
• Shahid Saleem vs Govt. of Punjab, etc2025 LHC 1174, 2025 PLJ Lahore 592 · Lahore High Court · 2025-03-13
  PEEDA Act 2006disciplinary proceedingsde novo inquiryremandenhancement of penaltyprinciple of proportionalitylegitimate expectationdouble jeopardyright of appealremoval from service
  Summary & questions settled

  This constitutional petition arose from disciplinary proceedings under the Punjab Employees Efficiency, Discipline & Accountability Act, 2006 (PEEDA). The petitioner was originally subjected to an inquiry for alleged misconduct and document tampering, where the inquiry officer recommended removal from service. However, the Competent Authority imposed a lesser penalty of demotion. The petitioner appealed, and the Appellate Authority set aside the order and remanded the matter for a de novo inquiry due to procedural shortcomings. Following the fresh inquiry on the identical allegations, the Competent Authority imposed the harsher punishment of removal from service along with a fine. The primary legal question before the High Court was whether the Competent Authority could inflict a more severe punishment post-remand on the same allegations absent any new material or aggravated misconduct. Allowing the petition, the Lahore High Court held that the imposition of an enhanced penalty violated procedural fairness, the principle of proportionality, and legitimate expectations. A public authority cannot subject an employee to worse detriment merely for exercising their legal right of appeal.

  Questions settled

  • Can a competent authority impose a harsher penalty post-remand upon a de novo inquiry when the remand was directed purely due to procedural shortcomings and no new misconduct was alleged?
  • Does the imposition of an enhanced punishment on the same set of allegations after an employee succeeds in obtaining a remand on appeal violate the principles of fairness and proportionality?
  • Can an individual be subjected to a more severe departmental penalty merely for exercising their statutory right of appeal against a lesser penalty?
  • Does the doctrine of estoppel prevent a competent authority from contradicting its earlier assessment of quantum of punishment in disciplinary proceedings on unchanged facts?
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• Shahid Mehmood & Co. (Pvt.) Ltd. vs Additional District Judge, Faisalabad2025 LHC 3661 · Lahore High CourtRead full judgment →
• Shahid Javed vs Government of Pakistan, etc2025 LHC 3866 · Lahore High Court · 2025-06-04Read full judgment →
• Shaheen Baig vs Zaheer Ahmed Loan2025 LHC 906 · Lahore High Court · 2025-02-20Read full judgment →
• Shahbaz Mustafa and another vs The State & another2025 LHC 4778 · Lahore High Court · 2025-04-14
  post-arrest bailrobberyidentification paradeCCTV footagemodern devicesrecovery of cashhistory sheeters
  Summary & questions settled

  The petitioners sought post-arrest bail in a case registered under Sections 392 and 411 of the Pakistan Penal Code 1860, following the refusal of bail by the Additional Sessions Judge. The core legal question was whether the lack of an identification parade entitled the petitioners to bail, given that they were not named in the FIR and CCTV footage captured the incident, alongside substantial recovery of looted cash and prior criminal records. The Lahore High Court held that holding an identification parade is not mandatory in every case where the identity of the accused is established through other relevant evidence such as CCTV footage under Articles 22 and 164 of the Qanun-e-Shahadat Order 1984. The court established that modern devices and CCTV recordings provide admissible evidence of identity, rendering an identification parade unnecessary when such material exists, and declined to exercise discretion in favor of history-sheeters.

  Questions settled

  • Whether holding an identification parade is a mandatory legal requirement in every criminal case for establishing the identity of an accused?
  • Is CCTV footage admissible under the Qanun-e-Shahadat Order 1984 to establish the identity of an accused without an identification parade?
  • Does the recovery of substantial looted cash and a history of previous criminal cases disentitle an accused to post-arrest bail?
  Read full judgment →
• Shahbaz Akmal Jandran vs Province of Punjab through Director General, Excise and Taxation, Lahore2025 LHC 2944 · Lahore High Court · 2025-04-15Read full judgment →
• Shah Jahan & another vs Province of Punjab & others2023 LHC 1127, 2025 CLC 650 · Lahore High Court · 2023-03-06Read full judgment →
• Shafqat Ali, Tariq Mehmood, Tariq Mehmood vs The State, etc2025 LHC 1269, PLJ 2025 Cr.C. 386 · Lahore High Court
  criminal appealmurderburden of proofQanoon-e-Shahadat Orderacquittaldouble presumption of innocencedomestic homicideeyewitness testimony
  Summary & questions settled

  This criminal appeal challenges the conviction and life imprisonment of the appellant, Shafqat Ali, under Section 302(b) of the Pakistan Penal Code 1860 for the murder of his wife, Mst. Humaira Bibi. The core legal questions concerned the sufficiency of eyewitness testimony, the validity of the appellant's alibi, and the burden of proof when a crime occurs within the accused's private residence. The Lahore High Court dismissed the appeal, affirming the conviction based on consistent eyewitness accounts and the appellant's failure to provide a credible explanation for the death occurring within his home. The court held that under Article 122 of the Qanoon-e-Shahadat Order, 1984, when a crime is committed inside the accused's house, the burden shifts to the accused to explain the circumstances leading to the death. Furthermore, the court dismissed the complainant's revision for sentence enhancement and the appeal against the acquittal of co-accused, emphasizing the double presumption of innocence attached to acquittal orders. The judgment reinforces the necessity of credible evidence and the specific evidentiary obligations of inmates in domestic homicide cases.

  Questions settled

  • Does the burden of proof shift to the accused to explain the circumstances of a death occurring within their private residence?
  • Can an appellate court interfere with an acquittal order where the trial court has provided valid and plausible reasons?
  • Is a delay in the registration of an FIR fatal to the prosecution's case if the delay is explained by the surrounding circumstances?
  Read full judgment →
• Shabana Parveen vs Malik Mohsin Hassan Rasheed etc2025 LHC 2894 · Lahore High Court · 2025-05-06Read full judgment →
• Sarja etc vs Syed Zahid Hussain Shah etc2025 LHC 3281 · Lahore High Court · 2025-05-02Read full judgment →
• Sardar Waseem Ilyas vs Federation of Pakistan and others2025 PTD 282 · Lahore High Court · 2023-12-07Read full judgment →
• Sardar Amber Maqood vs Federation of Pakistan, Privatisation2025 LHC 5392 · Lahore High Court · 2025-06-27Read full judgment →
• Samar Abbas, Muhammad Ramzan vs The State etc2025 LHC 2726 · Lahore High Court · 2025-04-22
  post-arrest bailfurther inquirypress clippingshearsay evidencecall data recordjudicial noticecriminal investigation
  Summary & questions settled

  This petition concerns post-arrest bail for two accused persons charged with murder under Sections 302/324/109/114/34 of the Pakistan Penal Code 1860. The core legal question was whether the prosecution established a prima facie case against the petitioners, particularly given the reliance on a supplementary statement and the admissibility of press clippings at the bail stage. The Court held that the petitioners were entitled to bail, finding the prosecution's case doubtful due to conflicting attendance records and the inconclusive nature of Call Data Records (CDR) lacking voice transcripts. Regarding the evidentiary value of press clippings, the Court clarified that while generally hearsay and inadmissible as substantive evidence without the author's testimony, they may be considered inquisitorially at the bail stage to determine if a case warrants further inquiry. Concluding that the prosecution's case rested on frail pillars and that the petitioners' continued incarceration served no useful purpose, the Court granted post-arrest bail, emphasizing that this assessment was tentative and would not prejudice the trial.

  Questions settled

  • Can press clippings be considered by a court at the bail stage to determine if a case warrants further inquiry?
  • Is a Call Data Record (CDR) sufficient to establish the identity of a user without a voice recording transcript?
  • Under what circumstances can a court take judicial notice of newspaper reports?
  • Does the Qanun-e-Shahadat Order 1984 allow courts to presume the genuineness of a newspaper?
  Read full judgment →
• Salamat Ali vs Sabohi Naz2025 LHC 3273 · Lahore High Court · 2025-05-05Read full judgment →
• Sakina Bibi vs The State & another2025 LHC 3670 · Lahore High Court · 2025-05-07
  narcoticschain of custodybenefit of doubtcriminal appealrecovery memopolice rulesacquittal
  Summary & questions settled

  This criminal appeal challenges the conviction of the appellant under the Control of Narcotic Substances Act, 1997, for the possession of opium and charas. The core legal question concerns whether the prosecution successfully established the chain of custody for the recovered narcotics, given the absence of documentary evidence regarding their handling. The Lahore High Court held that the prosecution failed to prove the guilt of the appellant beyond a reasonable doubt. The Court observed that the investigating officer and the police station Moharrer failed to produce evidence of entries in Register No. XIX or any road certificate regarding the transmission of sample parcels to the laboratory, as mandated by the Police Rules, 1934. The Court emphasized that when the law prescribes a specific procedure for handling case property, failure to adhere to it renders the prosecution's case doubtful. Consequently, the Court set aside the convictions and sentences, granting the appellant the benefit of the doubt and ordering her immediate acquittal.

  Questions settled

  • Does the failure to produce entries in Register No. XIX regarding the deposit of case property create a fatal gap in the chain of custody in narcotics cases?
  • Is the prosecution's case rendered doubtful if no road certificate is produced for the transmission of narcotic samples to the laboratory?
  • Does the failure to follow the prescribed procedure for handling case property under the Police Rules, 1934, entitle an accused to the benefit of doubt?
  Read full judgment →
• Sajjad Haider, etc vs Syed Ali Rizwan Kazmi, etc2025 LHC 2203 · Lahore High Court · 2025-04-03Read full judgment →
• Saira Bibi & 4 others vs Muhammad Hafeez & another2025 LHC 5536 · Lahore High Court · 2025-09-12Read full judgment →
• Saima Naureen vs Government of the Punjab, etc2025 LHC 477 · Lahore High Court · 2025-02-25
  service terminationprobation periodTEVTA employeefundamental rightswithholding of salaryactus curiae neminem gravabitconstitutional petition
  Summary & questions settled

  This constitutional petition under Article 199 of the Constitution of Pakistan, 1973, challenged a quasi-judicial order passed by the General Manager Operation-II, TEVTA, which upheld the termination of the petitioner from her post as an Instructor Professional Cooking. The core legal question concerned the lawfulness of terminating an employee who had successfully completed her probation period and whether state functionaries could ignore prior judicial directions and binding departmental appeals. The Lahore High Court held that the termination order and subsequent affirming orders were illegal, noting that the petitioner had successfully completed her probation under the TEVTA Employees Service Regulations, 2011, and that non-payment of salary infringed fundamental rights. The Court laid down the principle that under the maxim 'actus curiae neminem gravabit', no party should suffer due to a court's omission or procedural delay, and that withholding an employee's salary violates fundamental constitutional rights relating to life, dignity, and livelihood.

  Questions settled

  • Whether an employee's services can be terminated under probation clause after the successful completion of the probation period?
  • Does the non-payment of salary to an employee constitute a violation of fundamental rights guaranteed under the Constitution?
  • Can a departmental authority pass an order contrary to a final and un-challenged judicial direction passed in an earlier round of litigation?
  • Whether the maxim 'actus curiae neminem gravabit' protects a party from suffering due to an omission or oversight by the Court?
  Read full judgment →
• Saif Ali vs The State and others2025 LHC 2319 · Lahore High Court · 2025-04-10Read full judgment →
• Sahib Bibi & another vs Khushi Muhammad (deceased) through LRs2025 LHC 104, 2025 PLJ Lahore 406 · Lahore High Court · 2025-01-21Read full judgment →
• Saghir Hussain vs The State, etc2025 LHC 4892 · Lahore High Court · 2025-04-29Read full judgment →
• Safeer Hussain vs Capital City Police Officer and others2025 LHC 385 · Lahore High Court · 2025-02-25Read full judgment →
• Safdar Ali vs The State and another2025 P Cr. L J 835 · Lahore High Court · 2025-03-05
  post-arrest bailnarcotic substancesforensic evidencefurther inquirycriminal trialsample weight discrepancy
  Summary & questions settled

  This petition concerns a request for post-arrest bail by the petitioner, Safdar Ali, who was charged under Section 9(1)(c) of the Control of Narcotic Substances Act, 1997, following the registration of an FIR regarding the alleged recovery of 10 kilograms of narcotics. The core legal question was whether the petitioner was entitled to bail given the discrepancies in the forensic evidence and the duration of his incarceration. Upon reviewing the record, the Court observed a significant inconsistency between the weight of the recovered material (10 kg) and the sample analyzed by the Punjab Forensic Science Agency (246 grams), as well as discrepancies regarding the nature of the recovered substance. The Court held that these inconsistencies rendered the case one of further inquiry, thereby entitling the petitioner to bail. Furthermore, the Court noted the petitioner's lack of a criminal record and the lack of progress in the trial. Consequently, the petition was allowed, and the petitioner was admitted to post-arrest bail, establishing the principle that material discrepancies in forensic evidence and sample weight can constitute grounds for further inquiry, warranting the grant of bail pending trial.

  Questions settled

  • Does a significant discrepancy between the weight of recovered narcotics and the weight of the sample analyzed by a forensic laboratory constitute grounds for further inquiry in a bail application?
  • Is a petitioner entitled to post-arrest bail when there is a lack of material progress in the trial and no prior criminal record?
  • Can inconsistencies in the description and weight of recovered contraband justify the grant of bail under the Control of Narcotic Substances Act 1997?
  Read full judgment →
• Saeed Khan vs Omar Farooq, etc2025 LHC 4271 · Lahore High Court · 2025-06-18
  appeal against acquittalhurt caseJurah Jaifainjured witnessmedical evidenceconviction on minor offenceDaman
  Summary & questions settled

  This criminal appeal challenges the acquittal of the respondent by the trial court in a case involving knife injuries. The core legal question concerns the appreciation of ocular and medical evidence in hurt cases, particularly whether an internal organ impact constitutes the Islamic penal offence of Jurah Jaifa. The Lahore High Court held that the prosecution successfully proved the ocular account and medical evidence through the injured witness and medical experts, though the specific charge of Jurah Jaifa was not made out due to lack of proof regarding the wound extending into the body cavity, thus warranting conviction under a lesser hurt provision. The court established that the sole testimony of an injured witness, when corroborated by consistent medical evidence, is sufficient for conviction, and courts can convict for a minor offence under section 238 of the Code of Criminal Procedure 1898 even if not originally charged.

  Questions settled

  • Can an accused be convicted of a minor hurt offence under section 238 of the Code of Criminal Procedure 1898 even if not specifically charged with it?
  • Is the sole testimony of an injured witness sufficient to maintain a conviction in a criminal trial when corroborated by medical evidence?
  • What constitutes Jurah Jaifa under the Pakistan Penal Code 1860 regarding injuries extending to the body cavity of the trunk?
  • When can an appellate court reverse an acquittal judgment passed by a trial court in a criminal case?
  Read full judgment →
• Saeed Akhtar vs The State2025 LHC 4871 · Lahore High Court · 2025-06-26
  murdercriminal appealbenefit of the doubtchance witnessdelay in FIRmedical evidencesafe custody of weaponabscondanceacquittal
  Summary & questions settled

  The appellant was tried and convicted under section 302(b) of the Pakistan Penal Code 1860 for the murder of the deceased and sentenced to imprisonment for life as Tazir by the trial court. In the criminal appeal before the Lahore High Court, the core legal question revolved around whether the prosecution had proved its case beyond a reasonable doubt, specifically examining the credibility of eyewitnesses as chance witnesses, the unexplained delay in lodging the FIR, contradictions in medical and ocular evidence, a broken chain of safe custody regarding weapon recovery, and unproven motive and abscondance. The High Court held that the prosecution failed to establish a foolproof case, noting that the eyewitnesses were unreliable chance witnesses with unnatural conduct, the FIR suffered from a fatal inordinate delay, medical evidence conflicted with the ocular account regarding distance and injuries, and the chain of custody for the recovered weapon was compromised. Consequently, the Lahore High Court accepted the appeal, set aside the conviction and sentence, and acquitted the appellant on the benefit of the doubt. The key principle laid down is that minor discrepancies and cumulative defects such as delayed FIRs, chance witnesses with unnatural conduct, broken chain of custody for recoveries, and unproven motives cumulatively destroy the prosecution's case, entitling the accused to the benefit of the doubt.

  Questions settled

  • Whether an inordinate and unexplained delay in lodging the first information report creates doubt regarding the authenticity of the prosecution story?
  • Can the testimony of chance witnesses who display unnatural conduct be relied upon without convincing explanations for their presence at the crime scene?
  • Does a broken chain of safe custody regarding a recovered weapon render a positive forensic science laboratory report useless for the prosecution?
  • Is mere abscondence of an accused sufficient by itself to maintain a conviction and sentence in the absence of other reliable corroborative evidence?
  Read full judgment →
• Saeed Ahmad Saeedi vs The State, etc2025 LHC 2225 · Lahore High Court · 2025-03-25
  acquittalresiling witnessDNA evidencecorroboratory evidencerapecriminal revisionSection 265K Cr.P.C.
  Summary & questions settled

  This criminal revision challenged an order by the Additional Sessions Judge rejecting an application for acquittal under Section 265K of the Code of Criminal Procedure 1898 in a rape case. The core legal question was whether a trial can proceed and a conviction be sustained solely on DNA evidence when the complainant/victim, the sole witness to the alleged rape, has resiled from her testimony. The Court held that DNA evidence is corroboratory in nature and cannot serve as the sole basis for conviction. It reasoned that when a complainant resiles, the prosecution case is uprooted, and continuing the trial without substantive evidence constitutes an abuse of process. The Court emphasized that while DNA evidence is admissible, it must be used in conjunction with other substantive evidence to avoid constitutional concerns regarding self-incrimination and the potential for manipulation. Consequently, the Court set aside the impugned order and acquitted the petitioner, establishing the principle that in the absence of other substantive evidence, the resiling of a complainant necessitates acquittal under Section 265K of the Code of Criminal Procedure 1898.

  Questions settled

  • Can an accused be convicted solely on the basis of DNA evidence?
  • Does the resiling of a complainant in a rape case necessitate acquittal under Section 265K of the Code of Criminal Procedure 1898?
  • Is DNA evidence considered a substantive piece of evidence or merely corroboratory?
  • Does the constitutional guarantee against self-incrimination limit the use of DNA evidence in criminal trials?
  Read full judgment →
• Sadia Parveen vs Muhammad Umer2025 YLR 539 · Lahore High Court · 2024-10-03Read full judgment →
• Rukshanda Asad vs Commissioner Inland Revenue and others2025 LHC 2758, PTCL 2025 CL. 681 · Lahore High Court · 2025-04-29Read full judgment →
• Riaz Ahmad vs The State etc2025 LHC 2094, PLJ 2025 Cr.C. 448 · Lahore High Court · 2025-03-26
  post-arrest bailforged sale deedvaluable securityprohibitory clauselocus standifraud and forgeryanti-corruption
  Summary & questions settled

  This criminal petition arises out of FIR No. 28/2024 registered under Sections 420, 468, 471, 109, 419 of the Pakistan Penal Code 1860 and Section 5/2/47 of the Prevention of Corruption Act 1947, wherein the petitioner sought post-arrest bail for allegedly acquiring land through a forged sale deed in connivance with revenue officials. The core legal questions involved whether the offence fell within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898, and whether a complainant lacking direct legal heirship possesses the locus standi to set criminal law in motion for fraud and forgery. The court held that the forgery of a sale deed constitutes a valuable security attracting Section 467 of the Pakistan Penal Code 1860, which falls within the prohibitory clause, and that crimes of fraud and forgery are offences against the public at large, allowing any person to initiate proceedings. Consequently, the bail petition was dismissed.

  Questions settled

  • Whether a sale deed executed through forgery qualifies as a valuable security under Section 30 of the Pakistan Penal Code 1860?
  • Does the forgery of a sale deed attract offences falling within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Does a complainant who is not a direct legal heir possess the locus standi to lodge an FIR in cases involving fraud and forgery?
  • Is only a directly affected person competent to initiate criminal proceedings for a crime of fraud or forgery against public property?
  Read full judgment →
• Riaz Ahmad vs Registrar, Lahore High Court, Lahore & another2025 LHC 2164 · Lahore High Court · 2025-03-21Read full judgment →
• Rasheeda Saigol vs Zarai Taraqiati Bank Limited etc2025 LHC 2656 · Lahore High Court · 2025-04-24Read full judgment →
• Rao Omar Hashim Khan vs Ahmad Raza Maneka etc2025 LHC 4421 · Lahore High Court · 2025-06-18Read full judgment →
• Rana Zafarullah vs Abdul Ghafoor & others2025 LHC 438 · Lahore High Court · 2025-02-12
  ex-parte proceedingssetting aside ex-parte orderlimitationcondonation of delayretired government officialconstitutional petitioncivil servants immunity
  Summary & questions settled

  This constitutional petition under Article 199 of the Constitution of the Islamic Republic of Pakistan, 1973 challenged the revisional order of the Additional District Judge setting aside a Civil Judge's order that had recalled ex-parte proceedings after a delay of twelve years. The petitioner, a retired government official impleaded in his official capacity as Tehsildar, sought to set aside ex-parte proceedings initiated after service via newspaper publication. The revisional court dismissed his application on grounds of limitation and lack of due diligence. The High Court affirmed the revisional order, holding that ex-parte proceedings cannot be set aside after an inordinate delay without proper justification or proof of lack of service, as law favors the vigilant and not the indolent. The Court further observed that civil servants acting in good faith within official duties bear no personal liability under Section 22A of the Punjab Civil Servants Act, 1974, nor are retired officials required to defend past official acts absent allegations of mala fide, misconduct, or ultra vires actions. Finding no jurisdictional defect, the petition was dismissed in limine.

  Questions settled

  • Can ex-parte proceedings be set aside after an inordinate delay of 12 years without establishing lack of proper service or misrepresentation?
  • Is a retired government official required to defend in court official actions taken in good faith during service absent allegations of mala fide or ultra vires conduct?
  • Can constitutional jurisdiction under Article 199 of the Constitution be invoked as a substitute for ordinary legal remedies where a party failed to act within the prescribed statutory limitation period?
  Read full judgment →
• Rahil Butt And 21 Others vs The Federation Of Pakistan Through Secretary2025 LHC 3087 · Lahore High Court
  quo warrantocivil service appointmentregularization of serviceFederal Public Service Commissionpast and closed transactionlocus poenitentiaecabinet sub-committeeconstitutional petition
  Summary & questions settled

  This constitutional petition, filed under Article 199 of the Constitution of the Islamic Republic of Pakistan, 1973, sought a writ of quo warranto against the appointment and regularization of respondents in the Federal Government Educational Institution. The core legal question was whether the regularization of these employees in BS-16 and above posts by a cabinet sub-committee, without adhering to the mandatory recruitment process of the Federal Public Service Commission, was lawful. The Court held that the regularization was void ab initio as the cabinet sub-committee lacked the authority to bypass statutory recruitment requirements. It rejected preliminary objections regarding laches, territorial jurisdiction, and the "past and closed transaction" doctrine, emphasizing that illegal appointments cannot be shielded by the passage of time. The key principle laid down is that quo warranto proceedings are inquisitorial in nature, and public offices must be filled in strict accordance with the law; consequently, illegal appointments cannot be regularized by executive committees lacking statutory power. The Court directed the appointing authority to refer the respondents' cases to the Federal Public Service Commission for a determination of fitness under Section 11-B of the Civil Servants Act, 1973.

  Questions settled

  • Can a cabinet sub-committee regularize the appointment of civil servants in BS-16 and above without the involvement of the Federal Public Service Commission?
  • Does the doctrine of 'past and closed transaction' protect an appointment that was void ab initio?
  • Is the principle of laches applicable to a writ of quo warranto challenging the legality of a public office holder?
  • Can a court issue a writ of quo warranto against a public office holder whose appointment was made without following the prescribed statutory procedure?
  Read full judgment →
• Qurban Ali vs The State, etc2025 LHC 1400 · Lahore High Court · 2025-03-25
  post-arrest bailfake advocateimpersonationPunjab Bar Councilstatutory interpretationcriminal procedurefurther inquiry
  Summary & questions settled

  This matter concerns a post-arrest bail application filed by a petitioner accused of impersonating an advocate and committing fraud. The core legal question is whether a private complainant can directly initiate criminal proceedings against an alleged "fake advocate" without first engaging the Punjab Bar Council. The Court held that the Punjab Legal Practitioners & Bar Council Rules, 2023, mandate a specific inquiry process by the Executive Committee of the Punjab Bar Council before prosecution can be initiated under the Legal Practitioners & Bar Councils Act, 1973. The Court emphasized the principle that where the law prescribes a specific procedure for an act, it must be followed strictly. Since the complainant failed to involve the Punjab Bar Council or provide documentary evidence of the alleged impersonation, and the police failed to substantiate the allegations, the Court found the petitioner’s case fit for further inquiry. Consequently, the bail application was allowed, and the petitioner was admitted to post-arrest bail, reinforcing that private individuals must exhaust the prescribed Bar Council inquiry mechanism before pursuing criminal litigation against alleged fake advocates.

  Questions settled

  • Can a private individual directly initiate criminal proceedings against a person for impersonating an advocate without first exhausting the inquiry process under the Punjab Legal Practitioners & Bar Council Rules, 2023?
  • What is the procedure for initiating prosecution against a person alleged to be a 'fake advocate' under the Legal Practitioners & Bar Councils Act, 1973?
  • Which court has jurisdiction to try an offence committed under the Legal Practitioners & Bar Councils Act, 1973, and the Punjab Legal Practitioners & Bar Council Rules, 2023?
  • How should a conflict of jurisdiction between two courts regarding the trial of an offence be resolved under the Code of Criminal Procedure 1898?
  Read full judgment →
• Quality Schools Foundation vs Federation of Pakistan etc2025 LHC 392 · Lahore High Court · 2025-04-30Read full judgment →
• Qari Shahid vs The State and another2025 LHC 4763 · Lahore High Court · 2025-04-28
  post-arrest bailsexual abusesimilar factschild abuseprohibitory clausedelay in F.I.R.
  Summary & questions settled

  The petitioner, an Imam of a mosque accused in case F.I.R. No. 1403/2024 under Section 377-B of the Pakistan Penal Code 1860, sought post-arrest bail after it was refused by the Additional Sessions Judge. The core legal questions involved whether the delay in lodging the F.I.R., lack of medical examination, and similar past allegations warranted the grant of post-arrest bail for offences involving sexual abuse of children. The Lahore High Court held that delay in reporting matters involving family honor is natural, lack of medical examination does not vitiate the charge where acts like sexual abuse do not require consummation, and evidence of similar facts showing a state of mind is admissible under Article 27 of the Qanun-e-Shahadat 1984. The court ruled that the petitioner, facing habitual allegations of a heinous nature, was not entitled to bail due to the prima facie case falling under the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898, thereby dismissing the petition.

  Questions settled

  • Whether delay in lodging an F.I.R. in cases involving sexual abuse and family honor can be resolved in favor of the accused?
  • Is a medico-legal examination mandatory for establishing an offence under Section 377-B of the Pakistan Penal Code 1860?
  • Whether involvement in similar crimes is admissible as evidence of a particular state of mind under Article 27 of the Qanun-e-Shahadat 1984?
  • Does the offence of sexual abuse under Section 377-A and 377-B of the Pakistan Penal Code 1860 require the consummation of sexual intercourse?
  Read full judgment →
• Qamar-ul-Islam vs Province of Punjab, etc2025 LHC 3173 · Lahore High Court · 2025-05-07Read full judgment →
• Qalab Abbas, Amjad Pervaiz, Fateh Muhammad, The State vs The State &2025 LHC 3110 · Lahore High CourtRead full judgment →
• Qadeer Ali, etc vs Province of Punjab, etc2025 LHC 5221 · Lahore High Court · 2025-07-23Read full judgment →
• Province of the Punjab through its Chief Secretary etc vs Chand Iqbal etc2025 LHC 3999 · Lahore High Court · 2025-06-16
  intra court appealpafper leakageprobationary periodtermination of servicelocus poenitentiaesuo motu jurisdictionpublic service commission
  Summary & questions settled

  This intra-court appeal addresses the legality of the termination of services of Deputy Accountants (BS-16) and the simultaneous withdrawal of recommendations and cancellation of recruitment tests by the Punjab Public Service Commission following a widespread question paper leakage scandal investigated by the Anti-Corruption Establishment. The core legal questions involve whether the PPSC has the authority to withdraw its recommendations under its regulations and the principle of locus poenitentiae, whether a probationer's services can be terminated without notice, and whether the High Court can exercise suo motu jurisdiction in writ petitions. The Lahore High Court held that the PPSC retains jurisdiction to withdraw recommendations tainted by fraud or irregularity, that a probationer can be terminated simpliciter without notice or show cause during probation, and that the High Court cannot grant unpleaded relief through suo motu action. The court set aside the single bench judgment and dismissed the respondents' writ petitions, establishing that maintaining merit, transparency, and public trust outweighs individual claims where an entire examination process is compromised by systematic cheating.

  Questions settled

  • Does the Punjab Public Service Commission possess the authority to withdraw recommendations for appointment after detecting errors, omissions, or leakage in examination papers?
  • Can the services of a civil servant be terminated without notice during their initial or extended period of probation?
  • Whether the High Court can assume suo motu jurisdiction to grant relief not specifically prayed for in a constitutional petition?
  • Does the principle of locus poenitentiae prevent an authority from rescinding an order or recommendation that was initially tainted by illegality or fraud?
  Read full judgment →
• Province of the Punjab etc vs Mirza Waseem Baig2025 LHC 5021 · Lahore High Court · 2025-06-24
  civil servantprobationerPunjab Service Tribunalconstitutional petitionIntra-Court Appealmaintainabilityterms and conditions of servicedischarge of inefficient
  Summary & questions settled

  This Intra-Court Appeal arose from a judgment of the learned Judge-in-Chambers which accepted a constitutional petition and set aside orders rescinding the respondent's appointment as a Traffic Assistant. The core legal questions involved whether a probationer is a civil servant under the Punjab Service Tribunals Act, 1974, whether an order of discharge under Rule 12.21 of the Police Rules 1934 is appealable before the Punjab Service Tribunal, and whether a constitutional petition is maintainable when a statutory service appeal is available. The Lahore High Court held that a probationer qualifies as a civil servant, that the bar against departmental appeals under Rule 12.21 does not exclude the statutory right of appeal before the Punjab Service Tribunal under Section 4 of the Act, and that termination based on alleged fraudulent entry or misconduct relates to terms and conditions of service rather than fitness. Consequently, the High Court laid down the principle that subordinate departmental rules cannot override the exclusive judicial jurisdiction of service tribunals established under Article 212 of the Constitution, rendering the constitutional petition and the resulting Intra-Court Appeal barred.

  Questions settled

  • Whether a probationer falls within the definition of a civil servant under the Punjab Service Tribunals Act, 1974?
  • Does Rule 12.21 of the Police Rules 1934 bar the statutory right of appeal before the Punjab Service Tribunal under Section 4 of the Punjab Service Tribunals Act, 1974?
  • Is an order of discharge based on allegations of fraudulent entry into service considered a matter of fitness or a matter of terms and conditions of service?
  • Whether a constitutional petition under Article 199 of the Constitution of Pakistan, 1973 is maintainable against a departmental termination order when an alternate statutory remedy before the Service Tribunal is available?
  Read full judgment →
• Province of the Punjab and two others vs Akbari Begum (deceased)2025 LHC 1390 · Lahore High Court · 2025-02-20Read full judgment →
• Phaphi alias Fatima and another vs The State and another2025 LHC 788 · Lahore High Court · 2025-03-10
  pre-arrest bailcriminal breach of trustmala fidefamily disputefemale accusedSection 406 PPC
  Summary & questions settled

  This petition sought pre-arrest bail for two female petitioners accused of offences under Sections 406 and 420 of the Pakistan Penal Code 1860, following the refusal of bail by the trial court. The core legal question was whether the transfer of gold rings and money for marriage expenses constituted criminal breach of trust or a civil/family dispute, and whether the petitioners were entitled to relief. The court held that the transfer of property in the context of marriage arrangements did not satisfy the essential ingredients of entrustment required for Section 406 PPC, characterizing the transaction as a gift. Consequently, the court confirmed the pre-arrest bail. The key principles laid down are that mala fide intent can be inferred from the inherent weakness of the prosecution's case and surrounding circumstances, even in the absence of direct evidence. Additionally, the court affirmed that for female, non-convict petitioners where no recovery is pending, judicial discretion should be exercised to protect their modesty and prevent irreparable harm from unnecessary arrest.

  Questions settled

  • What are the essential ingredients required to constitute the offence of criminal breach of trust under Section 406 of the Pakistan Penal Code 1860?
  • Can mala fide intent be inferred from the weakness of the prosecution's case in a bail application?
  • Does the transfer of property for marriage expenses constitute an entrustment for the purposes of criminal breach of trust?
  Read full judgment →
• Parks & Horticulture Authority vs Punjab Labour Appellate Tribunal, etc2025 LHC 463 · Lahore High Court · 2025-02-20
  permanent workmandaily wagersregularization of serviceindustrial and commercial establishmentParks and Horticulture Authority
  Summary & questions settled

  This constitutional petition addresses whether daily-wage workers who have served for approximately ten years at the Parks and Horticulture Authority (PHA) qualify as 'workmen' under labor legislation and are entitled to regularization and permanent status. The core legal questions involve determining the applicability of the Punjab Industrial Relations Act, 2010, and the Industrial and Commercial Employment (Standing Orders) Ordinance, 1968, to employees of a statutory authority like the PHA, and distinguishing between a declaration as a permanent workman and the administrative process of regularization. The Lahore High Court held that the PHA functions as a commercial establishment regarding its horticultural maintenance, rendering continuous daily-wage manual workers eligible to be declared permanent workmen by operation of law after fulfilling the statutory duration. However, the court held that labor courts lack the jurisdiction to order regularization, which is an administrative process governed by civil service laws and specific government policies. The court maintained the Labour Court's declaration of permanent workman status while setting aside the Labour Appellate Tribunal's direction for regularization.

  Questions settled

  • Whether daily wage employees of the Parks and Horticulture Authority fall under the definition of workman under the Punjab Industrial Relations Act, 2010 and the Industrial and Commercial Employment (Standing Orders) Ordinance, 1968?
  • What is the legal distinction between the regularization of service and the declaration of an employee as a permanent workman?
  • Does a Labour Court have the authority to direct the administrative regularization of daily-wage employees in public authorities?
  • Does the existence of statutory service rules exempt a statutory organization from the application of labor laws for employees performing manual work?
  Read full judgment →
• Palwasha Nageen vs The State2025 LHC 563 · Lahore High Court · 2025-02-24
  criminal appealmurderbenefit of doubtjuvenile offendereye-witness testimony contradictioncircumstantial evidenceweapon recoveryacquittal
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of the appellant, a juvenile, under Section 302(b) of the Pakistan Penal Code 1860 for the murder of her husband. The core legal question revolves around whether the prosecution successfully proved the guilt of the appellant beyond a reasonable doubt, particularly in light of contradictions in eyewitness testimony, the absence of corroborative forensic evidence such as matching crime empties, and an implausible motive. The Lahore High Court held that the prosecution failed to establish its case, as the presence of the eyewitnesses was doubtful, the recovery of the weapon was unreliable, and the unnatural death of a spouse inside a house alone is insufficient to secure a conviction without independent supporting evidence. The court laid down the principle that a single circumstance creating a reasonable doubt in a prudent mind entitles the accused to the benefit of doubt as a matter of right, resulting in the setting aside of the conviction and the acquittal of the appellant.

  Questions settled

  • Whether the unnatural death of a husband inside a house where he lived with his wife is by itself sufficient to establish the wife's guilt in the absence of other connecting evidence?
  • Does a contradiction regarding the number of fire shots and recovered crime empties create a reasonable doubt as to the presence of eyewitnesses?
  • Is an accused entitled to the benefit of doubt as a matter of right when a single circumstance creates reasonable doubt in a prudent mind?
  • Can a conviction be sustained on the basis of a motive that has been expressly discarded by the trial court?
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  criminal appealbenefit of doubtocular accountindependent corroborationacquittal of co-accusedmurderSection 161 CrPCappreciation of evidence
  Summary & questions settled

  This criminal appeal challenges the convictions and sentences imposed by the trial court for murder and murderous assault. The core legal question is whether the prosecution successfully proved its case beyond reasonable doubt, particularly when the same eye-witnesses' testimony was previously rejected by the trial court to acquit co-accused in the same incident. The Lahore High Court held that the prosecution failed to establish its case, citing significant doubts regarding the ocular account, the delayed recording of statements under Section 161, Code of Criminal Procedure 1898, and the lack of independent corroboration. The Court applied the principle that if eye-witnesses are disbelieved regarding some accused, their testimony cannot be relied upon against others without independent corroboration. Consequently, the Court set aside the convictions, acquitted the appellants, and dismissed the complainant's revision petition for sentence enhancement. The judgment reaffirms that the prosecution must stand on its own legs, and any single circumstance creating doubt regarding the prosecution's story is sufficient to entitle the accused to the benefit of the doubt.

  Questions settled

  • Can eye-witnesses who are disbelieved regarding some accused persons be relied upon to convict other co-accused without independent corroboration?
  • Does the acquittal of co-accused based on the same ocular evidence necessitate the acquittal of remaining accused in the absence of independent corroboration?
  • What is the legal effect of a delay in recording statements under Section 161 of the Code of Criminal Procedure 1898 without a plausible explanation?
  • Can the prosecution rely on the weaknesses of the defence to prove its case?
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