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.

• Muhammad Rizwan vs State and anotherPLJ 2021 Cr.C. 1109 · Lahore High Court · 2021-03-25
  suspension of sentencepost-conviction bailnarcotics controlshort sentencepunishment in advancecriminal appeal
  Summary & questions settled

  This criminal miscellaneous petition was filed by the petitioner seeking suspension of his sentence and release on bail pending the adjudication of his appeal. The petitioner had been convicted under Section 9(c) of the Control of Narcotics Substances Act, 1997, and sentenced to four years and six months of rigorous imprisonment for the recovery of 1110 grams of charas. The core legal question was whether the petitioner’s sentence should be suspended during the pendency of his appeal, given the short duration of the sentence and the lack of prospects for an early hearing. The Court held that where the sentence is short and there is no likelihood of the appeal being decided in the near future, refusing to suspend the sentence would effectively result in the petitioner serving the entire term before the appeal is heard on merits, which constitutes punishment in advance. Furthermore, the Court noted the petitioner had not misused the concession of bail granted during the trial. Consequently, the Court suspended the sentence and admitted the petitioner to bail.

  Questions settled

  • Can a sentence be suspended pending appeal if there is no prospect of an early hearing?
  • Does the fact that a convict did not misuse bail during trial support a request for suspension of sentence pending appeal?
  • Is it appropriate to suspend a sentence where the duration of imprisonment is short and the appellant might serve the entire term before the appeal is decided?
  Read full judgment →
• Muhammad Rizwan & 2 others vs Zarai Taraqiati Bank & another2021 LHC 5758 · Lahore High Court · 2021-10-07Read full judgment →
• Muhammad Riaz vs The State, etc2021 LHC 6946, PLJ 2022 Cr.C. 523, 2022 PCr. LJ 1005 · Lahore High Court · 2021-11-11
  private defenseself-defenseSection 342 statementappreciation of evidencemurderburden of proofexcessive force
  Summary & questions settled

  The appellant was convicted for the murder of Safdar Iqbal under Section 302(b) of the Pakistan Penal Code 1860. The core legal question was whether the prosecution established the case beyond reasonable doubt and whether the appellant’s plea of self-defense, articulated in his statement under Section 342 of the Code of Criminal Procedure 1898, justified his actions. The Court found the prosecution’s ocular evidence unreliable due to unexplained delays and inconsistencies, effectively rejecting it. However, upon accepting the appellant’s statement in its entirety, the Court held that while the appellant faced an altercation, he exceeded the right of private defense by firing multiple shots at close range against unarmed attackers. The Court affirmed the conviction, establishing the principle that when prosecution evidence is discarded, an accused’s statement under Section 342 of the Code of Criminal Procedure 1898 must be evaluated as a whole; if the admitted facts demonstrate that the accused exceeded the proportionate use of force necessary for self-defense, the plea of private defense fails, and the conviction is legally sustainable.

  Questions settled

  • Can an accused be convicted based on their own statement under Section 342 of the Code of Criminal Procedure 1898 if the prosecution's evidence is rejected?
  • Does the right of private defense extend to using lethal force against attackers who are not armed with firearms?
  • What is the legal effect of accepting an accused's statement under Section 342 of the Code of Criminal Procedure 1898 in its entirety when the prosecution fails to prove its case?
  Read full judgment →
• Muhammad Riaz vs The State and others2021 MLD 564 · Lahore High Court · 2018-04-26Read full judgment →
• Muhammad Riaz vs State etcPLJ 2021 Cr.C. 1701 · Lahore High Court · 2021-02-02
  pre-arrest bailunlawful assemblytwo versions of the incidentfurther inquirymurderous assaultcriminal procedure
  Summary & questions settled

  This matter concerns two consolidated petitions for pre-arrest bail arising from FIR No. 151/2020 registered at Police Station Noshera, District Khushab, involving allegations of offences under Sections 324, 148, and 149 of the Pakistan Penal Code 1860. The prosecution alleged that the petitioners formed an unlawful assembly and launched a murderous assault, resulting in injuries to five individuals. The core legal question was whether the petitioners were entitled to pre-arrest bail given the specific nature of the injuries attributed to them and the existence of conflicting versions of the incident. The Court held that the petitioners were entitled to bail. It reasoned that one petitioner's injury attribution required further inquiry due to the complainant's failure to appear before the medical board, while the injuries attributed to others were bailable. Furthermore, the Court emphasized that where two conflicting versions of an incident exist, the determination of the aggressor is a matter for the trial court after recording evidence, thereby justifying the grant of pre-arrest bail pending trial.

  Questions settled

  • Does the existence of two conflicting versions of an incident justify the grant of pre-arrest bail?
  • Is pre-arrest bail appropriate when the prosecution's medical evidence requires further inquiry due to the complainant's failure to appear before a medical board?
  • Should the determination of the aggressor in a criminal case be decided at the bail stage or during the trial?
  Read full judgment →
• Muhammad Riaz vs Additional Sessions Judge, Narowal etcPLJ 2021 Cr.C. (Lahore) 416 · Lahore High Court · 2015-02-03
  private complaintcriminal investigationpolice challanprosecution evidencemagisterial jurisdictioncomplainant rightsFIR
  Summary & questions settled

  This constitutional petition challenges the judgment of the Additional Sessions Judge, Narowal, which set aside a Magistrate's order dismissing a private complaint. The core legal question was whether a complainant, dissatisfied with the police investigation and the subsequent challan, is precluded from filing a private complaint after the charge has already been framed in the state-led criminal case. The Lahore High Court upheld the Additional Sessions Judge's decision, dismissing the petition in limine. The Court held that the Magistrate erred in dismissing the private complaint solely because the state case had progressed to the stage of prosecution evidence. The key principle laid down is that a complainant possesses an inherent legal right to file a private complaint against accused persons if they are dissatisfied with the police investigation, regardless of the stage of the state-led criminal proceedings. The Court affirmed that the complainant is not restricted to merely seeking the addition of offences within the existing state case but may pursue a private complaint to address their grievances regarding the investigation.

  Questions settled

  • Can a complainant file a private complaint if they are dissatisfied with the police investigation?
  • Does the framing of a charge in a state-led criminal case bar the filing of a private complaint by the complainant?
  • Is a Magistrate empowered to dismiss a private complaint solely because the state case has reached the stage of prosecution evidence?
  Read full judgment →
• Muhammad Riaz Malik vs Learned Additional Sessions Judge and 7 others2021 PLJ Lahore 386 · Lahore High Court · 2016-05-02Read full judgment →
• Muhammad Riaz etc vs Muhammad Sharif etcPLJ 2021 Cr.C. 1171 · Lahore High Court · 2021-03-11
  Illegal Dispossession Actjoint propertyco-sharerspartition of landcriminal appealacquittalpossession dispute
  Summary & questions settled

  This criminal appeal challenges the convictions and sentences imposed by the trial court under the Illegal Dispossession Act, 2005. The complainants alleged that the appellants forcibly dispossessed them of suit land, despite the complainants having obtained possession through a revenue court decree. The core legal question was whether the provisions of the Illegal Dispossession Act, 2005, could be invoked to penalize co-owners for dispossession when the suit property remains part of an unpartitioned joint Khata. The Court held that the conviction was unsustainable because the evidence established that the land in dispute was joint property between the parties and had not been legally partitioned. The Court emphasized that the Illegal Dispossession Act is not intended to resolve disputes between co-sharers where possession is contested within an unpartitioned joint holding. Consequently, the Court set aside the convictions and acquitted the appellants, ruling that the trial court's judgment resulted from a misreading and non-reading of evidence regarding the status of the land as joint property.

  Questions settled

  • Can the Illegal Dispossession Act 2005 be invoked to penalize co-owners for dispossession of land that remains part of an unpartitioned joint Khata?
  • Is a conviction under the Illegal Dispossession Act 2005 sustainable where the property in dispute has not been legally partitioned between the parties?
  Read full judgment →
• Muhammad Riaz and 2 others vs Province Of Punjab, through Home2021 PLC (C.S.) 705 · Lahore High Court · 2019-01-25
  regularization of servicecontract employeesconstitutional jurisdictionmaster and servantright to livelihooddiscriminatory treatmentpolice constables
  Summary & questions settled

  This judgment by the Lahore High Court addresses a set of consolidated writ petitions filed by ex-Army personnel who were appointed as Constables on a contract basis in the Punjab Police and sought regularization of their services pursuant to a government notification dated 01.03.2013. The core legal questions involved the maintainability of constitutional petitions by contractual employees, whether acceptance of contract terms bars an employee from seeking regularization, and whether the petitioners were entitled to regularization under the 2013 policy. The court held that contract employees can invoke constitutional jurisdiction for service matters, that unequal bargaining power in signing contracts does not bar employees from seeking regularization, and that denying the benefit of the regularization policy to the petitioners while regularizing their peers was discriminatory. The court allowed the petitions, reinstated the petitioners, and directed the authorities to consider their cases for regularization in accordance with the 2013 policy.

  Questions settled

  • Whether a contract employee can invoke the constitutional jurisdiction of the High Court in respect of grievances regarding the terms and conditions of service?
  • Does the signing of a contract containing a clause barring regularization estop an employee from seeking regular employment when there is an inequality of bargaining position?
  • Whether employees of a particular department can be deprived of the benefit of a general government regularization notification without explicit exclusion in the policy?
  • Does the right to life under Article 9 of the Constitution of Pakistan 1973 include the right to livelihood?
  Read full judgment →
• Muhammad Razzaq vs Surayya Bibi and 6 others2021 PLD Lahore 790, 2022 [M] CLR 457 · Lahore High Court · 2021-07-14Read full judgment →
• Muhammad Rashid vs State and anotherPLJ 2021 Cr.C. 1341 · Lahore High Court · 2021-05-24
  post-arrest bailaerial firingvicarious liabilityfurther inquirycommon object
  Summary & questions settled

  Through this petition, the petitioner Muhammad Rashid sought post-arrest bail in case FIR No. 289 dated 02.08.2020 registered under Sections 302, 324, 148, and 149 of the Pakistan Penal Code 1860 at Police Station Muhammad Pur, District Rajanpur. The core legal question was whether the petitioner was entitled to post-arrest bail where no specific overt act of causing injury or death was attributed to him except aerial firing, making his case one of further inquiry. The Lahore High Court allowed the bail petition, holding that the petitioner's culpability and the application of vicarious liability required further inquiry after recording evidence, especially as he was a previous non-convict and no longer required for investigation. The key principle laid down is that where no overt act is attributed to an accused other than aerial firing and the question of vicarious liability requires determination at trial, the case falls within the ambit of further inquiry under Section 497(2) of the Code of Criminal Procedure 1898, justifying the grant of post-arrest bail.

  Questions settled

  • Whether an accused to whom no overt act is attributed except aerial firing is entitled to post-arrest bail?
  • Does the question of vicarious liability in a murder case warrant further inquiry for the purpose of bail?
  • Is a previous non-convict entitled to bail when no longer required for police investigation?
  Read full judgment →
• Muhammad Rasheed, etc vs Government Of The Punjab through Secretary2021 PLJ Lahore 191 · Lahore High CourtRead full judgment →
• Muhammad Ramzan vs State etcPLJ 2021 Cr.C. (Lahore) 184 · Lahore High Court · 2019-12-03
  pre-arrest bailtheftfurther inquirydelay in FIRliberty of the subjectcriminal procedure
  Summary & questions settled

  This matter concerns a petition for pre-arrest bail filed by the petitioner, Muhammad Ramzan, who was accused of theft under Section 379 of the Pakistan Penal Code 1860. The core legal question was whether the petitioner was entitled to pre-arrest bail given the circumstances of the case, specifically the significant delay in lodging the FIR and the nature of the evidence. The Lahore High Court held that the petitioner was entitled to the relief sought. The Court observed that the three-month delay in filing the crime report remained unexplained, the occurrence was unseen, and the FIR lacked details regarding the transportation of the stolen property. Consequently, the Court determined that the case against the petitioner fell within the ambit of further inquiry under Section 497(2) of the Code of Criminal Procedure 1898. The key principle laid down is that in pre-arrest bail matters, the Court may evaluate the facts and circumstances, including potential mala fides and the merits of the case, to determine if the petitioner's liberty should be protected pending trial.

  Questions settled

  • Can a court evaluate the merits of a case when deciding on a petition for pre-arrest bail?
  • Does an unexplained three-month delay in lodging an FIR constitute grounds for further inquiry under Section 497(2) of the Code of Criminal Procedure 1898?
  • Is a petitioner entitled to pre-arrest bail when the prosecution fails to provide details regarding the transportation of allegedly stolen property in an unseen occurrence?
  Read full judgment →
• Muhammad Ramzan alias Waqas alias Papu vs State and another2021 PLJ Cr.C (Lahore) 828 · Lahore High Court · 2020-09-21
  narcotic substanceschemical examiner reportfull protocolscriminal appealacquittalrecovery contradictionadmissibility of evidence
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of the Appellant under Section 9(c) of the Control of Narcotic Substances Act, 1997, for the alleged possession of 1050 grams of charas. The core legal questions concerned the reliability of the prosecution's evidence, specifically regarding unexplained overwriting in the complaint and FIR, and the admissibility and validity of the Chemical Examiner's report. The Lahore High Court held that the prosecution's case was rendered dubious due to material contradictions between the complainant and the investigating officer regarding the alteration of the quantity of contraband in the official record. Furthermore, the Court held that the Chemical Examiner's report was legally deficient because it failed to comply with the mandatory requirements of Rule 6 of the Control of Narcotic Substances (Government Analysts) Rules, 2001, which necessitates the inclusion of full testing protocols. Additionally, the Court ruled that a photocopy of a Chemical Examiner's report is inadmissible without secondary evidence. Consequently, the conviction was set aside, and the Appellant was acquitted of the charge.

  Questions settled

  • Does the failure to include full testing protocols in a Chemical Examiner's report render it inconclusive and unreliable under Rule 6 of the Control of Narcotic Substances (Government Analysts) Rules, 2001?
  • Is a photocopy of a Chemical Examiner's report admissible in evidence without the production of the original or secondary evidence?
  • Do material contradictions in the prosecution's record regarding the quantity of recovered contraband create reasonable doubt sufficient for acquittal?
  Read full judgment →
• Muhammad Rafique, etc vs State etcPLJ 2021 Cr.C. 1081 · Lahore High Court · 2019-10-02
  murderblood feudjoint roleanti-terrorism actocular evidencemedical corroborationballistic reportsentence mitigationappeal against acquittal
  Summary & questions settled

  This criminal appeal arises from a judgment of the Anti-Terrorism Court convicting the appellants for murder and other offences following a fatal shooting incident resulting from a blood feud. The core legal questions involve the appreciation of ocular and medical evidence, the applicability of the Anti-Terrorism Act, 1997 to a crime arising from personal enmity, and the sustainability of convictions based on a joint role without specific attribution of fatal shots. The Lahore High Court held that while the ocular account of injured witnesses corroborated by medical evidence and ballistic reports proved the appellants' participation in the homicidal deaths beyond reasonable doubt, the offense fell outside the scope of anti-terrorism laws as it stemmed from private enmity rather than generating terror within the meaning of the statute. Consequently, the court set aside the convictions under the Anti-Terrorism Act, 1997, converted the death sentences to imprisonment for life under the Pakistan Penal Code, 1860 due to the joint attribution of roles, and additionally set aside the acquittal of a co-accused, convicting him similarly. The key principle laid down is that crimes rooted in personal blood feuds, despite occurring in public and causing multiple casualties, do not attract anti-terrorism legislation unless accompanied by the specific design or purpose specified in the statute.

  Questions settled

  • Does a murder committed in a public place as a result of a longstanding personal blood feud attract the provisions of the Anti-Terrorism Act, 1997?
  • Whether the assignment of a joint role to multiple accused persons for causing firearm injuries without attributing a specific fatal shot to an individual warrants the mitigation of a death sentence to imprisonment for life?
  • Can the positive report of a Ballistic Expert regarding recovered weapons provide sufficient corroboration to the testimony of injured eye-witnesses?
  • Under what circumstances can an appellate court reverse an acquittal and convict a co-accused whose role was identical to that of convicted co-accused?
  Read full judgment →
• Muhammad Rafique vs The State and another2021 P Cr. L J 553 · Lahore High Court · 2015-01-28
  circumstantial evidencebenefit of doubtlast seen evidencewajtakkarmurderacquittal of co-accusedindependent corroboration
  Summary & questions settled

  This criminal appeal challenges the judgment of the Sessions Judge Khushab, whereby the appellant was convicted under section 302(b) of the Pakistan Penal Code 1860 and sentenced to life imprisonment for the murder of the deceased. The core legal question revolves around whether the circumstantial evidence presented by the prosecution—including last seen, wajtakkar, motive, medical evidence, and the recovery of a cycle—was sufficient to prove the guilt of the appellant beyond a reasonable doubt, particularly when co-accused facing the same trial and evidence had already been acquitted. The Lahore High Court held that the circumstantial evidence failed to form an unbroken chain pointing solely to the guilt of the appellant, that material improvements and contradictions rendered the witness testimonies unreliable, and that no independent corroboration existed to sustain a conviction when the common set of evidence had been disbelieved regarding the acquitted co-accused. The court laid down the principle that in cases resting entirely on circumstantial evidence, the circumstances must form a continuous chain connecting the accused to the crime without missing links, and that when evidence is rejected against co-accused, independent corroboration on material particulars is mandatory to sustain a conviction against the remaining accused.

  Questions settled

  • Whether circumstantial evidence can sustain a conviction when the links in the chain of evidence are missing?
  • Can evidence disbelieved against acquitted co-accused be used to convict another accused without independent corroboration on material particulars?
  • Is an accused entitled to the benefit of doubt as a matter of right when the prosecution fails to prove its case beyond reasonable doubt?
  Read full judgment →
• Muhammad Rafique vs State and anotherPLJ 2021 Cr.C. 960 · Lahore High Court · 2020-12-07
  murderrobberyidentification paradechance witnessbenefit of doubtforensic evidencecriminal appealdishonest improvement
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of the appellant for murder and robbery under the Pakistan Penal Code 1860. The core legal questions concerned the reliability of chance witnesses, the evidentiary value of an identification parade where no specific role was attributed to the accused, and the impact of dishonest improvements in witness testimony. The Lahore High Court held that the prosecution failed to prove its case beyond a reasonable doubt. The Court found the ocular account inconsistent with medical evidence and noted that the eye-witnesses were chance witnesses without justification for their presence. Furthermore, the identification parade was deemed legally insignificant because the witnesses failed to attribute a specific role to the appellant during the proceedings, and subsequent improvements in court were rejected as dishonest. Additionally, the forensic evidence was disregarded due to the failure to prove the safe transmission of the weapon. Consequently, the Court set aside the conviction, acquitted the appellant, and extended him the benefit of the doubt, establishing that identification proceedings lacking specific role attribution and testimony tainted by dishonest improvements are insufficient to sustain a conviction.

  Questions settled

  • Does an identification parade lose its legal significance if the witnesses fail to attribute a specific role to the accused during the proceedings?
  • Can a conviction be sustained when the ocular account is contradicted by the medical evidence regarding the nature of the injury?
  • What is the legal consequence of dishonest improvements made by witnesses in their court statements to strengthen the prosecution's case?
  • Is the forensic report reliable if the prosecution fails to produce the official responsible for the safe transmission of the crime weapon?
  Read full judgment →
• Muhammad Rafique etc vs State etcPLJ 2021 Cr.C. 1430 · Lahore High Court · 2019-10-02
  criminal appealmurderattempted murderanti-terrorism actprevious enmityocular evidencemedical evidenceballistic reportacquittalconvictionlife imprisonmentdeath sentence commutationjoint role
  Summary & questions settled

  This judgment addresses criminal appeals against conviction, a capital sentence reference, and an appeal against acquittal arising from a murderous assault. The appellants, Muhammad Rafique and Muhammad Asif, were convicted and sentenced to death for multiple murders and attempted murder under the Pakistan Penal Code and the Anti-Terrorism Act, 1997. The core legal questions involved the applicability of the Anti-Terrorism Act in cases of previous enmity, the consistency of ocular and medical evidence, and the propriety of acquitting a co-accused with an identical role. The Lahore High Court partially allowed the appeal, setting aside convictions and sentences under Section 7 of the Anti-Terrorism Act, 1997, on the grounds that previous enmity as a motive does not automatically attract its provisions. The death sentences under Section 302(b), PPC were converted to life imprisonment due to the joint role of multiple accused. The court also set aside the acquittal of co-accused Muhammad Ashraf, convicting him for murder and attempted murder, finding no material to differentiate his role from the convicted accused.

  Questions settled

  • Can a case motivated by previous enmity attract the provisions of the Anti-Terrorism Act 1997?
  • Is a minor discrepancy in the time of death in medical evidence sufficient to discredit confidence-inspiring ocular account?
  • Can an acquittal based on an Investigating Officer's finding of innocence be set aside if the evidence on record proves guilt?
  • Whether a joint role of multiple accused in a murder case can be a mitigating factor for awarding a lesser sentence?
  • Is the testimony of injured eye-witnesses, corroborated by medical evidence and ballistic reports, considered trustworthy and confidence-inspiring?
  Read full judgment →
• Muhammad Rafique Awan vs The Land Acquisition Collector, National2021 MLD 766 · Lahore High Court · 2020-12-31Read full judgment →
• Muhammad Rafique alias Mamun vs State etcPLJ 2021 Cr.C. 1447 · Lahore High Court · 2019-01-09
  pre-arrest baildelay in FIRstatement of co-accusedfurther inquirycriminal cases involvement
  Summary & questions settled

  This criminal miscellaneous petition seeks pre-arrest bail in respect of FIR No. 337/2018 registered under Section 380, PPC at Police Station Alpa, District Multan. The core legal question revolves around whether the petitioner is entitled to pre-arrest bail where the FIR was lodged with a delay of three years, the occurrence was unseen, and the primary incriminating material against the petitioner is the statement of a co-accused. The court held that the statement of the co-accused is inadmissible, the unexplained delay casts doubt on the prosecution's version, and mere involvement in other criminal cases does not disentitle an accused to bail in the absence of a conviction, thereby making the case one of further inquiry. The petition was consequently allowed and the pre-arrest bail confirmed.

  Questions settled

  • Whether an unexplained delay of three years in lodging the FIR reflects on the veracity of the prosecution version in a bail application?
  • Is the statement of a co-accused implicating the petitioner admissible in evidence for the purpose of denying bail?
  • Does mere involvement in other criminal cases disentitle an accused to the concession of bail in the absence of a previous conviction?
  Read full judgment →
• Muhammad Rafiq vs Hussain and another2021 LHC 6963, 2022 MLD 939 · Lahore High Court · 2021-11-02Read full judgment →
• Muhammad Qayyum vs Habib Bank Limited2021 PLJ Lahore 144 · Lahore High Court · 2019-04-30Read full judgment →
• Muhammad Qasim vs The State2021 MLD 1263 · Lahore High Court · 2021-02-16
  criminal appealmurder referencebenefit of doubtchance witnessespost-mortem delayforensic evidenceacquittal
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence of the appellant, Muhammad Qasim, for the murder of his sister-in-law, Shamsa Kanwal, under Section 302(b) of the Pakistan Penal Code 1860. The core legal questions concerned the reliability of the prosecution's evidence, specifically the testimony of chance witnesses and the integrity of the forensic recovery. The Lahore High Court found that the prosecution failed to establish the presence of the eye-witnesses at the scene of the crime, noting they were chance witnesses who could not justify their presence. Furthermore, the Court observed a significant delay in the post-mortem examination, suggesting the fabrication of evidence and the procurement of witnesses. Additionally, the Court discarded the forensic report due to the suspicious timing of the recovery and dispatch of the crime weapon and empty casing. Consequently, the Court held that these factors created reasonable doubt regarding the appellant's guilt. The conviction was set aside, the appellant was acquitted, and the murder reference was answered in the negative, affirming the principle that a single circumstance creating reasonable doubt entitles an accused to acquittal as a matter of right.

  Questions settled

  • Does a delay in conducting a post-mortem examination create a reasonable doubt regarding the prosecution's case?
  • Is an accused entitled to the benefit of doubt as a matter of right if a single circumstance creates reasonable doubt?
  • Can a forensic report be discarded if the crime weapon and empty casing were received by the forensic agency simultaneously after a significant delay?
  Read full judgment →
• Muhammad Qasim vs State2021 PLJ Cr.C (Lahore) 838 · Lahore High Court · 2021-02-16
  murderdeath sentencechance witnessbenefit of the doubtdelayed post-mortemcriminal appealacquittal
  Summary & questions settled

  The appellant, Muhammad Qasim, challenged his conviction and sentence of death under Section 302(b) of the Pakistan Penal Code 1860 along with a murder reference stemming from FIR No. 137 dated 19.06.2014. The Lahore High Court examined whether the prosecution proved its case beyond a reasonable doubt through eye-witness testimony, medical evidence, and weapon recovery. The Court held that the eye-witnesses were uncorroborated chance witnesses who failed to establish their presence at the scene, the post-mortem examination was subject to unexplained delay suggestive of concoction, and the weapon recovery and forensic report were unreliable. Consequently, the appeal was accepted, the conviction and death sentence were set aside, the appellant was acquitted on the basis of benefit of the doubt, and the murder reference was answered in the negative. The key principle laid down is that a single circumstance creating a reasonable doubt in a prudent mind regarding the guilt of the accused entitles them to an acquittal as a matter of right.

  Questions settled

  • Are chance witnesses whose presence at the crime scene is unestablished considered reliable for a murder conviction?
  • Does a delay in conducting the post-mortem examination raise a strong possibility of police fabrication and planting of witnesses?
  • Can an accused be acquitted on the basis of a single circumstance creating reasonable doubt in a prudent mind?
  Read full judgment →
• Muhammad Pervaiz vs The State2021 LHC 116 · Lahore High Court · 2021-02-01
  criminal appealdying declarationbenefit of doubtchance witnessQatl-i-Amdocular evidenceburden of proofappreciation of evidence
  Summary & questions settled

  This criminal appeal challenged the conviction and life imprisonment of the appellant for the murder of the deceased under Section 302(b) of the Pakistan Penal Code 1860. The core legal questions concerned the reliability of the alleged dying declaration, the credibility of ocular witnesses, and the evidentiary value of the recovery of the weapon. The Lahore High Court held that the prosecution failed to prove its case beyond a reasonable doubt. The court found the purported dying declaration to be a fabricated document, noting the deceased's physical inability to make a lucid statement and the lack of medical attestation. Furthermore, the court identified the eye-witnesses as "chance witnesses" who failed to explain their presence at the scene and whose testimony was contradicted by natural human conduct, as the assailant allegedly spared them despite being prime targets. The court reiterated the principle that the burden of proof lies solely on the prosecution and that any single circumstance creating reasonable doubt entitles the accused to acquittal as a matter of right. Consequently, the conviction was set aside, and the appellant was acquitted.

  Questions settled

  • Can a conviction be maintained solely on the basis of a dying declaration that lacks medical attestation and contradicts the physical condition of the deceased?
  • Does the failure of the prosecution to produce witnesses present at the scene of the crime warrant an adverse presumption under Article 129 of the Qanun-e-Shahadat Order 1984?
  • Is an accused entitled to acquittal if the prosecution fails to prove its case beyond a reasonable doubt, even if the accused takes a specific defence plea?
  • Can the testimony of eye-witnesses be discarded if they are found to be 'chance witnesses' who failed to provide a plausible reason for their presence at the crime scene?
  Read full judgment →
• Muhammad Nazir vs Naara Khan and 3 others2021 CLC 1372 · Lahore High Court · 2021-03-10Read full judgment →
• Muhammad Nawazish Ijaz vs Imtiaz Khalid, etc2021 [M] C L R 1122 · Lahore High Court · 2017-02-23Read full judgment →
• Muhammad Nawaz vs The State2021 LHC 6642, 2022 P Cr. L J 1542 · Lahore High Court · 2021-11-08
  murderdeath sentencebenefit of doubtdelay in FIRmedical evidencefirearm recoverymotive
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence of the appellant under Section 302(b) of the Pakistan Penal Code 1860 for qatl-i-amd of the deceased, alongside a murder reference for confirmation. The core legal questions involved the credibility of eyewitnesses, the implications of significant unexplained delays in lodging the FIR and conducting the post-mortem examination, contradictions between medical and ocular evidence regarding firearm range and injuries, and the reliability of weapon recovery and forensic reports where arrest dates are unproven. The Lahore High Court held that the prosecution failed to establish its case beyond a reasonable doubt due to multiple fatal flaws, including fake eyewitnesses, lack of medical treatment and absence of bandages, unverified motive, and doubtful forensic evidence. The court laid down that a single reasonable circumstance creating doubt in a prudent mind entitles the accused to the benefit of doubt as a matter of right, leading to the acquittal of the appellant and the negative answer to the murder reference.

  Questions settled

  • Whether an unexplained delay in lodging the FIR and conducting the post-mortem examination casts serious doubt on the presence of eyewitnesses?
  • Does a contradiction between medical evidence regarding the absence of blackening or burning and the ocular account of firing from close range undermine the prosecution's case?
  • Can a positive forensic science laboratory report and weapon recovery form the sole basis for conviction in the absence of reliable direct evidence and unproven arrest dates?
  • Is an accused entitled to the benefit of doubt as a matter of right when multiple circumstances create reasonable doubt in a prudent mind regarding the prosecution story?
  Read full judgment →
• Muhammad Nawaz vs The State & another2021 MLD 1126, PLJ 2021 Cr.C. (Lahore) 784, 2021 LHC 767 · Lahore High Court · 2021-03-19
  post-arrest bailqatl-bis-sababdiyatmedical negligenceprohibitory clausedouble jeopardyundertrial prisoner
  Summary & questions settled

  The petitioner, a doctor, sought post-arrest bail in a case registered under Section 322 of the Pakistan Penal Code 1860 for committing qatl-bis-sabab through alleged negligence during surgery. The core legal question was whether an accused charged under Section 322 PPC is entitled to post-arrest bail considering that the punishment provided is 'Diyat' only, which does not attract the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898, nor allows for the adjustment of pre-sentence custody under Section 382-B CrPC. The court held that since Section 322 PPC does not entail a sentence of imprisonment as a primary punishment—confinement only occurring upon default in paying Diyat—incarceration of the accused as an undertrial prisoner would amount to pre-trial punishment and double jeopardy. The court laid down the principle that in offenses not entailing imprisonment, the accused is entitled to bail as of right, and prolonged pretrial detention serves no useful purpose since such period cannot be compensated under Section 382-B CrPC upon conviction. The petition was consequently allowed.

  Questions settled

  • Does the punishment of Diyat provided under Section 322 of the Pakistan Penal Code 1860 attract the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Is an accused charged with an offense under Section 322 of the Pakistan Penal Code 1860 entitled to bail as of right?
  • Does Section 382-B of the Code of Criminal Procedure 1898 apply to a conviction under Section 322 of the Pakistan Penal Code 1860 where the only punishment is Diyat?
  • Can an accused facing a charge under Section 322 of the Pakistan Penal Code 1860 be kept in prolonged incarceration as an undertrial prisoner?
  Read full judgment →
• Muhammad Nawaz vs State etcPLJ 2021 Cr.C. 981 · Lahore High Court · 2021-04-19
  post-arrest baildishonoured chequeprohibitory clausefurther inquirybusiness transactioncriminal breach
  Summary & questions settled

  This matter arises from a petition filed under Section 497 of the Code of Criminal Procedure 1898 seeking post-arrest bail in respect of FIR No. 993/2019 registered under Section 489-F of the Pakistan Penal Code 1860 at Police Station Gaggo, District Vehari, concerning the dishonouring of a cheque issued in connection with a business transaction for the purchase of rice. The core legal question is whether the petitioner is entitled to post-arrest bail when the offence does not fall within the prohibitory clause of Section 497, Cr.P.C. and involves disputed business transactions requiring further inquiry. The Lahore High Court allowed the petition, holding that since the offence carries a maximum punishment of three years and does not fall within the prohibitory clause, the grant of bail is the rule and should be favoured in the absence of exceptional circumstances. The court established that mere issuance of a cheque does not constitute an offence under Section 489-F PPC unless dishonesty or discharge of a loan or financial obligation is proved, and emphasized that the penal provision cannot be used as a recovery mechanism.

  Questions settled

  • Whether bail should be granted when an offence does not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Does the mere issuance of a cheque constitute an offence under Section 489-F of the Pakistan Penal Code 1860 without proof of dishonesty or repayment of a loan?
  • Can Section 489-F of the Pakistan Penal Code 1860 be utilized as a mechanism for the recovery of money?
  Read full judgment →
• Muhammad Nawaz vs Rani & others2021 KLR Civil Cases 177 · Lahore High Court · 2016-06-21Read full judgment →
• Muhammad Nawaz vs Director General Rescue 1122 and another2021 [M] CLR 1406, 2021 KLR Civil Cases 429, 2022 PLC (C.S.) 873 · Lahore High Court · 2021-05-31
  public employmentage eligibilitycut-off dateservice ruleswrit petitionrecruitment criteriaRescue 1122
  Summary & questions settled

  This writ petition challenged the exclusion of the petitioner from the final interview list for the post of Driver (BPS-4) in Rescue 1122, Government of the Punjab, on the grounds that he was overage by five days. The petitioner argued that since he submitted his application prior to the closing date, his age should be calculated as of the date of submission, at which point he was within the prescribed limit. The core legal question was whether the cut-off date for determining age eligibility is the date of application submission or the closing date stipulated in the advertisement. The Court held that the petitioner was ineligible, as he exceeded the upper age limit on the closing date. Relying on Rule 18(2)(ii) of the Punjab Civil Servants (Appointment and Conditions of Service) Rules, 1974, the Court affirmed that age must be reckoned as of the last date fixed for the submission of applications. The judgment establishes that for public employment, age eligibility is strictly determined by the cut-off date fixed by service rules or the advertisement, not the individual date of application.

  Questions settled

  • Is the age eligibility of a candidate for public employment determined by the date of application submission or the closing date fixed in the advertisement?
  • Does Rule 18(2)(ii) of the Punjab Civil Servants (Appointment and Conditions of Service) Rules, 1974 require age to be reckoned as of the closing date for applications?
  • Can a candidate claim eligibility based on their age at the time of submitting an application if they are overage by the closing date fixed for applications?
  Read full judgment →
• Muhammad Nawaz and others vs State etcPLJ 2021 Cr.C. (Lahore) 118 · Lahore High Court · 2020-11-02
  criminal appealmurder referencebenefit of doubteyewitness credibilityimprovements in testimonydelayed statementacquittal
  Summary & questions settled

  This criminal appeal arises from a judgment of the trial court convicting the appellants under various sections of the Pakistan Penal Code for murder and attempt to commit murder, alongside a murder reference for confirmation of death sentences. The core legal questions involved the credibility of eyewitness testimony containing material improvements, unexplained delay in recording statements of injured witnesses, the reliability of retracted motives, and the application of the principle of benefit of doubt. The Lahore High Court held that dishonest improvements and omissions by eyewitnesses, coupled with unexplained delays in recording statements and lack of independent corroboration following the acquittal of co-accused, shatter the prosecution's case. The court established that minor or major circumstances creating a reasonable doubt in a prudent mind entitle the accused to acquittal as a matter of right, leading to the acceptance of the appeal, setting aside of convictions, and answering the murder reference in the negative.

  Questions settled

  • Whether dishonest improvements and omissions in the statements of eyewitnesses shatter their credibility?
  • Does an unexplained delay in recording the statement of an injured witness render their testimony unreliable?
  • Can the same evidence disbelieved for acquitting co-accused be relied upon to convict remaining accused without independent corroboration?
  • Is an accused entitled to the benefit of doubt as a matter of right when reasonable doubt exists regarding their participation?
  Read full judgment →
• Muhammad Naveed vs StatePLJ 2022 Cr.C. 1114 · Lahore High Court · 2021-10-07
  murderqatl-i-amdbenefit of doubtcontradiction between medical and ocular evidenceinterested witnessesweapon recoverymotivedeath sentenceacquittal
  Summary & questions settled

  This criminal appeal and murder reference arise from a judgment of the trial court convicting the appellant, Muhammad Naveed, under Section 302(b) of the Pakistan Penal Code 1860 for the qatl-i-amd of Mst. Noreen Bibi and sentencing him to death, alongside a compensation order under Section 544-A of the Code of Criminal Procedure 1898. The core legal questions involve the credibility of ocular testimony, the corroborative value of weapon recoveries, the establishment of motive, and the safety of relying on prosecution evidence in the presence of glaring contradictions with medical evidence. The Lahore High Court held that the prosecution failed to prove its case beyond a reasonable doubt, noting material contradictions between the eyewitness accounts and the medical evidence, doubtful recoveries, and an unproved motive. The court laid down the principle that the prosecution must stand on its own legs, and multiple glaring discrepancies between ocular and medical evidence, coupled with interested and inconsistent witnesses, warrant extending the benefit of the doubt to the accused, leading to his acquittal.

  Questions settled

  • Whether glaring contradictions between the ocular version and medical evidence are sufficient to discard the testimony of eyewitnesses?
  • Can a conviction on a capital charge be sustained solely on the basis of a disputed and weakly corroborated weapon recovery?
  • Does the failure of the prosecution to prove the alleged motive create a reasonable doubt in the prosecution's case?
  • What is the standard of proof required by the prosecution in criminal cases to secure a conviction?
  Read full judgment →
• Muhammad Nasir vs Chairman Bank Of Punjab2021 LHC 7027 · Lahore High Court · 2021-06-21Read full judgment →
• Muhammad Naeem vs State etcPLJ 2021 Cr.C. (Lahore) 780 · Lahore High Court · 2021-02-15
  narcoticssentence reductioncriminal appealpossession of charasquantum of sentencejudicial discretion
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence recorded by the Additional Sessions Judge/Special Judge CNS, Rawalpindi, against the appellant, Muhammad Naeem, for an offence under Section 9(c) of the Control of Narcotic Substances Act, 1997. The appellant was found in possession of 2000 grams of charas. During the appellate proceedings, the appellant's counsel stated that the appellant did not contest the conviction but sought a reduction in the sentence, offering an undertaking to remain a law-abiding citizen. The prosecution did not raise serious objections to this request. The Court upheld the conviction, finding that the trial court had correctly evaluated the evidence. However, considering the appellant's confession of guilt and his undertaking to reform, the Court held that a reduction in the sentence would serve the ends of justice. Consequently, the Court maintained the conviction but reduced the sentence of rigorous imprisonment from four years and six months to three years, while maintaining the fine and the benefit of Section 382-B of the Code of Criminal Procedure 1898.

  Questions settled

  • Can an appellate court reduce a sentence where the appellant does not contest the conviction but seeks leniency?
  • Is a confession of guilt and an undertaking to be a law-abiding citizen a valid ground for the reduction of a sentence in narcotics cases?
  Read full judgment →
• Muhammad Naeem vs Additional District Judge and others2021 YLR 108 · Lahore High Court · 2019-10-09Read full judgment →
• Muhammad Nadeem vs State etcPLJ 2021 Cr.C. (Lahore) 367 · Lahore High Court · 2019-02-12
  post-arrest baildishonoured chequebusiness disputeprohibitory clausefurther inquiry
  Summary & questions settled

  This matter comes before the Lahore High Court through a petition under Section 497 of the Code of Criminal Procedure 1898, whereby the petitioner, Muhammad Nadeem, seeks post-arrest bail in case F.I.R. No. 210 dated 11.09.2018 registered under Section 489-F of the Pakistan Penal Code 1860 at Police Station City Farooqabad District Sheikhupura, concerning the dishonour of a cheque amounting to Rs. 40,00,000/-. The core legal question is whether the petitioner is entitled to post-arrest bail in a business dispute involving an offence not falling within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898. The court held that since the offence is punishable with imprisonment for a term up to three years and does not fall within the prohibitory clause, and the case involves further inquiry based on documentary evidence already seized by the police, the petitioner has made out a case for bail. The court laid down the principle that in offences falling outside the prohibitory clause, the grant of bail is a rule and refusal is an exception, and where the matter emanates from a business dispute with conflicting stances, bail should be granted liberally.

  Questions settled

  • Whether post-arrest bail should be granted when an offence under Section 489-F of the Pakistan Penal Code 1860 does not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Does a dispute arising from business relations and issuance of a cheque as a guarantee warrant further inquiry under Section 497(2) of the Code of Criminal Procedure 1898?
  • Is bail to be refused when the entire case is based on documentary evidence already in possession of the police and the accused is no longer required for investigation?
  Read full judgment →
• Muhammad Mushtaq and another vs State and anotherPLJ 2021 Cr.C. (Lahore) 634 · Lahore High Court · 2020-11-19
  murderocular accountdeath sentence commutationextenuating circumstancescriminal appealmedical evidencemotiveforensic report
  Summary & questions settled

  This criminal appeal arose from a trial court judgment convicting the appellants for murder and murderous assault under Sections 302(b), 324, and 337-F(v) of the Pakistan Penal Code 1860. The core legal questions concerned the reliability of the ocular account, the impact of unproven motive and failed forensic evidence on the conviction, and the appropriateness of the death sentence. The Lahore High Court held that while the ocular account, corroborated by medical evidence, was sufficient to maintain the conviction for murder, the death sentence was not warranted. The court reasoned that because the prosecution failed to substantiate the alleged motive and the recovery of the weapon was rendered inconsequential by a negative forensic report, these constituted extenuating circumstances. Consequently, the court maintained the conviction but commuted the death sentence to imprisonment for life. The principle laid down is that while an ocular account can sustain a conviction, the absence of proof regarding motive and weapon recovery can serve as valid grounds to commute a death sentence to life imprisonment, even when the conviction itself remains sound.

  Questions settled

  • Can a death sentence be commuted to life imprisonment if the prosecution fails to prove the motive and weapon recovery?
  • Does the close relationship between eyewitnesses and the deceased automatically invalidate their testimony?
  • Is the failure of the prosecution to prove motive a sufficient ground to reduce a capital sentence?
  Read full judgment →
• Muhammad Musarrat Bajwa and others vs Muhammad Arif and others2021 PLJ Lahore 566 · Lahore High Court · 2018-05-23Read full judgment →
• Muhammad Munir Piracha vs Deputy Commissioner Inland Revenue, Audit-II, Rawalpindi2021 LHC 7041 · Lahore High CourtRead full judgment →
• Muhammad Mubashir vs State and anotherPLJ 2021 Cr.C. 973 · Lahore High Court · 2020-06-10
  post-arrest bailforgerycheatingprohibitory clausedocumentary evidenceregistered sale deedcriminal liability
  Summary & questions settled

  This petition was filed under Section 497 of the Code of Criminal Procedure 1898, seeking post-arrest bail for the petitioner, Muhammad Mubashir, in a case involving allegations of fraud and forgery under Sections 420, 468, and 34 of the Pakistan Penal Code 1860. The core legal question was whether the petitioner was entitled to bail given the nature of the allegations and the evidentiary record. The Court held that the petitioner was entitled to bail, noting that the disputed property transfer was executed via a registered sale deed, which had not been challenged in any forum, thereby negating the prima facie case for forgery under Section 468. Furthermore, the Court observed that the offence under Section 420 is bailable, and the offence under Section 468 does not fall within the prohibitory clause of Section 497. The Court emphasized that since the prosecution's case relied on documentary evidence already in police custody, there was no risk of tampering. Consequently, the petition was accepted, and the petitioner was admitted to bail.

  Questions settled

  • Does the offence under Section 468 of the Pakistan Penal Code 1860 fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Is the offence under Section 420 of the Pakistan Penal Code 1860 bailable in nature?
  • Can bail be granted when the prosecution's case is based on documentary evidence already in the custody of the state?
  Read full judgment →
• Muhammad Muazam, etc vs Govt. of the Punjab, etc2021 LHC 1636, 2022 PLC (C.S.) 330 · Lahore High Court · 2021-06-03
  contract employmentextension of contractconstitutional jurisdictionvested rightintra court appealpolice station assistantdiscrimination
  Summary & questions settled

  This Intra Court Appeal challenges a judgment of the learned Single Judge dismissing the Appellants' writ petition, which sought an extension of their contract employment as Police Station Assistants and the setting aside of the non-extension of their contracts. The core legal questions involved whether contractual employees can seek extension of their contracts through constitutional jurisdiction, whether non-extension amounts to a stigma requiring a disciplinary inquiry, and whether the Appellants faced discrimination. The Lahore High Court held that contract employees have no vested right or legal entitlement to claim an extension of an expired contract as a matter of right, that a court cannot force an unwilling employer to extend contracts through constitutional jurisdiction or undertake factual inquiries regarding performance, and that allegations of discrimination or mala fides require strict proof. The Court established the key principles that extension of a contract is a matter of employer discretion governed by terms and conditions, and a legal right or character must emanate from a statute rather than a contract.

  Questions settled

  • Can a contractual employee claim an extension of their contract as a matter of right through constitutional jurisdiction?
  • Whether non-extension of a service contract upon its expiry amounts to a stigma requiring formal disciplinary proceedings?
  • Does a constitutional court have the power to direct an unwilling employer to retain the services of an employee whose contract has expired?
  • What constitutes sufficient proof of discrimination in the context of non-extension of government contracts?
  Read full judgment →
• Muhammad Muavia @ Muaz @ Asmatullah vs StatePLJ 2021 Cr.C. 1014 · Lahore High Court · 2017-04-17
  terrorismdeath sentence confirmationocular accountforensic evidencecriminal appealapprehension at spotdefence plea
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence of the appellant for his involvement in a terrorist attack on a mosque resulting in multiple deaths and injuries. The core legal question was whether the prosecution proved the appellant's guilt beyond reasonable doubt, particularly given the absence of eye-witnesses in court and the appellant's defense that he was framed by state agencies. The court dismissed the appeal and confirmed the death sentence. The ratio of the decision is that the recovery of weapons and explosives from the accused at the scene, supported by police testimony and forensic reports matching weapons to crime scene empties, constitutes reliable evidence sufficient for conviction. The court established that a bare plea of being framed by agencies, unsupported by evidence under Section 340(2) of the Code of Criminal Procedure 1898, is insufficient to rebut strong prosecution evidence. Furthermore, the court held that medical evidence corroborating the ocular account provides a solid basis for conviction, even when primary eye-witnesses are unavailable due to security threats.

  Questions settled

  • Does the failure of eye-witnesses to appear in court due to threats invalidate a conviction when other corroborative evidence exists?
  • Can a bare allegation of abduction and torture by state agencies, without supporting evidence, successfully rebut a prosecution case?
  • Is the recovery of weapons and explosives from an accused at the scene of a crime sufficient to sustain a conviction for terrorism and murder?
  Read full judgment →
• Muhammad Mehran and 3 others vs State and anotherPLJ 2021 Cr.C. 952 · Lahore High Court · 2021-03-29
  pre-arrest bailcross-versioncounter versionsfurther inquirymutual injuriesbrawlrecovery of weaponsmala fide
  Summary & questions settled

  This matter arises from a petition filed under Section 498 of the Code of Criminal Procedure 1898 seeking pre-arrest bail in a cross-version criminal case registered for offences including hurt and rioting. The core legal question is whether pre-arrest bail should be granted in a mutual brawl involving counter versions and suppressed injuries, where it is yet to be determined which party was the aggressor. The Lahore High Court held that cases featuring counter versions from the same incident call for further inquiry and probe under Section 497(2) of the Code of Criminal Procedure 1898, as the determination of the aggressor is a matter for the trial court after recording evidence. The Court confirmed the pre-arrest bail, establishing the principle that counter versions with mutual injuries warrant further inquiry and that the need for weapon recovery does not preclude pre-arrest bail where custodial interrogation is unnecessary.

  Questions settled

  • Does a criminal case involving counter versions and mutual injuries warrant further inquiry under Section 497(2) of the Code of Criminal Procedure 1898 for the purpose of pre-arrest bail?
  • Can pre-arrest bail be refused solely on the ground that weapon recoveries are yet to be effected from the accused?
  • Is the absence of an explanation for injuries sustained by the opposite party in a cross-version case sufficient to infer mala fide at the pre-arrest bail stage?
  Read full judgment →
• Muhammad Masood-Ul-Haq vs Additional District Judge, Bhakar and 22021 PLJ Lahore 237, 2021 YLR 287 · Lahore High Court · 2020-10-22Read full judgment →
• Muhammad Mansha vs Muhammad Usman and others2021 CLC 863 · Lahore High Court · 2020-12-18Read full judgment →
• Muhammad Mansha and others vs State and othersPLJ 2021 Cr.C. 1666 · Lahore High Court · 2021-06-09
  murder appealbenefit of doubtdelayed post-mortemimproving testimonyunproven motiveacquittaldeath sentence referenceeyewitness credibility
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence of the appellant, Muhammad Mansha, under Section 302(b) and Section 452 of the Pakistan Penal Code 1860, along with a connected murder reference and a petition for leave to appeal against the acquittal of co-accused. The core legal questions involved the credibility of eyewitness testimony after the acquittal of co-accused, the effect of delayed post-mortem and medical examinations, withholding of material witnesses, dishonest improvements in the private complaint compared to the initial FIR, and unproven motive. The Lahore High Court held that the prosecution failed to establish its case beyond a reasonable doubt due to major discrepancies, delayed medical reports, unproven motive, and tainted eyewitness accounts. Consequently, the court accepted the appeal, set aside the conviction, acquitted the appellant on the benefit of doubt, answered the murder reference in the negative, and dismissed the petition against the co-accused's acquittal. The key principle laid down is that once prosecution witnesses are disbelieved regarding co-accused, their testimony cannot be relied upon against other accused without independent, unimpeachable corroboration.

  Questions settled

  • Can prosecution witnesses who have been disbelieved with respect to co-accused be relied upon against other accused without independent corroboration?
  • What is the legal effect on the prosecution case when a set-up motive is alleged but fails to be proved?
  • Does a delayed post-mortem examination cast serious doubt on the veracity of the prosecution case?
  • What is the evidentiary value of a weapon recovery when no matching crime empty is sent for forensic comparison?
  Read full judgment →
• Muhammad Liaqat Ali vs Majid Ali, etc2021 LHC 8193, 2022 MLD 1720 · Lahore High Court · 2021-12-20Read full judgment →
• Muhammad Latif vs State etcPLJ 2021 Cr.C. 1136 · Lahore High Court · 2021-03-09
  post-arrest bailfurther inquiryabscondencecriminal proceduremedico-legal evidence
  Summary & questions settled

  This petition concerns a request for post-arrest bail by Muhammad Latif, who was charged under Sections 337-A(iii), 337-L(ii), 354, 148, and 149 of the Pakistan Penal Code, 1860, in relation to an FIR involving allegations of causing injuries, robbery, and outraging modesty. The core legal question was whether the petitioner was entitled to bail given the discrepancies in the prosecution's evidence regarding his presence and specific role in the alleged incident. The Court held that the case against the petitioner warranted further inquiry into his guilt because the medico-legal report contradicted the allegation that the petitioner caused the injuries, and the police report under Section 173 of the Code of Criminal Procedure, 1898, indicated that another accused was responsible for the injuries and that the petitioner was not present at the scene. The Court established that the petitioner's status as a fugitive from law did not automatically disentitle him to bail when his case otherwise qualifies for further inquiry, particularly when the investigation is complete and further incarceration serves no useful purpose.

  Questions settled

  • Does the status of an accused as a fugitive from law automatically disentitle them to the grant of post-arrest bail?
  • When does a criminal case qualify as one of further inquiry for the purpose of bail?
  • Is an accused entitled to bail when the police report under Section 173 of the Code of Criminal Procedure 1898 contradicts the initial allegations regarding their presence at the scene?
  Read full judgment →
• Muhammad Khan, etc vs State etcPLJ 2021 Cr.C. (Lahore) 575 · Lahore High Court · 2021-02-17
  pre-arrest bailmalafidereligious feelingsdelay in FIRcriminal defamationbail confirmation
  Summary & questions settled

  The petitioners sought pre-arrest bail in case FIR No. 411/2020 registered under Sections 501, 506, and later Section 295-A, Pakistan Penal Code 1860, on allegations that they incorrectly described the complainant's religion as Christian in an application arising from prior litigation. The core legal question was whether the ingredients of Section 295-A, Pakistan Penal Code 1860 were prima facie met and whether malafide existed for false implication. The court held that the delayed reporting of over one year and three months without explanation, existing civil/other litigation, and the petitioner's prior stance that the mistake was inadvertent pointed to malafide, making the applicability of Section 295-A, Pakistan Penal Code 1860 a matter for further probe. Consequently, the court confirmed the pre-arrest bail of the petitioners, laying down that pre-arrest bail may be confirmed where mala fide is evident from prior litigation and unexplained delay in registration of the case.

  Questions settled

  • Whether unexplained delay of over a year in lodging an FIR warrants the grant of pre-arrest bail?
  • Does writing a person's religion incorrectly in a legal application prima facie constitute an offense under Section 295-A of the Pakistan Penal Code 1860?
  • Can pre-arrest bail be confirmed when prior litigation between the parties indicates potential malafide and false implication?
  Read full judgment →
• Muhammad Khan vs State Life Insurance Corporation Of Pakistan and 22021 PLC (C.S.) 1217 · Lahore High Court · 2020-11-25
  State Life Insurance CorporationArea ManagerPerformance ReviewRe-categorizationOperational CostSalary DeductionCommercial Employment
  Summary & questions settled

  This judgment disposes of a set of writ petitions filed by Area Managers of the State Life Insurance Corporation challenging their downgrading/re-categorization based on performance reviews and salary deductions made under the head of 'Operational Cost'. The core legal questions involve whether the Corporation can re-categorize employees for poor performance under its service regulations and appointment letters, and whether the Corporation can deduct excess operational costs from the employees' salaries. The Lahore High Court dismissed the petitions, holding that the Corporation's commercial orientation permits strict performance standards, that re-categorization is a valid lesser measure authorized under the regulations and appointment contracts, and that excess operational costs are lawfully recoverable even from salaries as agreed upon and supported by Supreme Court precedents. The key principle laid down is that commercial organizations like the State Life Insurance Corporation have wide latitude to enforce performance-based evaluations, re-categorizations, and cost recoveries in accordance with their governing regulations and contractual terms.

  Questions settled

  • Whether the State Life Insurance Corporation has the authority under its service regulations to re-categorize Area Managers to lower categories due to unsatisfactory performance?
  • Does the inclusion of re-categorization as a penalty in an appointment letter violate the State Life Insurance (Employees) Regulations 1973?
  • Whether deductions of excess 'Operational Cost' can lawfully be made from the monthly salaries of Area Managers?
  • Are commercial performance standards and related disincentives enforceable against employees of the State Life Insurance Corporation?
  Read full judgment →
• Muhammad Khan @ Momin Khan vs Said Alam deceased through LR's etc2021 [M] C L R 292 · Lahore High Court · 2016-09-07Read full judgment →
• Muhammad Khalid vs Magistrate 1st Class and 2 others2021 PLD Lahore 21 · Lahore High Court · 2019-10-09
  constitutional petitionhabeas corpuschild marriagepubertyNikahDar-ul-Amancustody of minor
  Summary & questions settled

  This constitutional petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973 challenged an order of a Magistrate directing a minor wife to be kept in Dar-ul-Aman and handing over her custody to her father. The core legal question was whether a Muslim girl who has attained puberty can contract a marriage of her own free will, whether such a marriage is valid despite the Child Marriage Restraint Act, 1929, and whether she can be detained in a shelter home against her will. The Lahore High Court held that a girl who has attained puberty may contract a valid marriage of her own choice without the consent of her wali, and such a marriage remains valid under Muslim law notwithstanding the provisions of the Child Marriage Restraint Act, 1929. The court laid down the principle that an alkalis or minor girl who has attained puberty and contracted a valid marriage is entitled to liberty, cannot be detained in Dar-ul-Aman against her will, and takes her husband as her lawful guardian rather than her father.

  Questions settled

  • Whether a marriage contracted by a girl who has attained puberty of her own free will is valid under Muslim law?
  • Does the Child Marriage Restraint Act, 1929 render a marriage solemnized after attaining puberty invalid?
  • Can a woman or minor girl be detained in Dar-ul-Aman against her free will after expressing a desire to leave?
  • Who is the lawful guardian of a female minor who has contracted a valid marriage upon attaining puberty?
  Read full judgment →
• Muhammad Khalid and others vs Market Committee Muzaffargarh and others2021 CLC 2022 · Lahore High Court · 2021-07-02Read full judgment →
• Muhammad Kausar vs Government Of The Punjab through Additional2021 PLJ Lahore 629 · Lahore High CourtRead full judgment →
• Muhammad Javed Iqbal vs Rao Shahzeb & 3 others2021 LHC 4871 · Lahore High Court · 2021-09-14Read full judgment →
• Muhammad Javaid vs Munir Ahmad Lodhi and 3 others2021 PLJ Lahore 672 · Lahore High Court · 2021-04-29Read full judgment →
• Muhammad Jahangir Khan vs The State2021 LHC 3710 · Lahore High Court · 2021-08-02
  post-arrest bailnarcotic substancesborderline casefurther inquiryrecovery of narcoticsControl of Narcotic Substances Act
  Summary & questions settled

  The petitioner sought post-arrest bail in a case registered under Section 9(c) of the Control of Narcotic Substances Act, 1997, following the alleged recovery of 1,170 grams of Chars. The core legal question was whether the recovery of a quantity marginally exceeding one kilogram, which places the offence in the category of Section 9(c) rather than Section 9(b), warrants the grant of bail pending trial. The Court observed that the recovery of 1,170 grams constitutes a borderline case between the two sub-sections, particularly where the distinction between net and gross weight remains unclear. Relying on Supreme Court precedents, the Court held that because the quantity only marginally exceeds the threshold and the petitioner is no longer required for investigation, the matter falls within the ambit of further inquiry. Consequently, the Court accepted the bail petition, ruling that the extent of the offence under Section 9(c) is a matter to be determined by the trial court after recording evidence, and admitted the petitioner to post-arrest bail.

  Questions settled

  • Does the recovery of a narcotic quantity marginally exceeding one kilogram constitute a borderline case between Section 9(b) and Section 9(c) of the Control of Narcotic Substances Act 1997?
  • Is a case of narcotic recovery eligible for post-arrest bail when the quantity recovered is a borderline amount and the accused is no longer required for investigation?
  Read full judgment →
• Muhammad Jahan Zaib Khan vs Muhammad Rafique Khan, etc2021 [M] C L R 1112, 2021 LHC 630 · Lahore High Court · 2021-02-18Read full judgment →
• Muhammad Ismail vs State and anotherPLJ 2021 Cr.C. (Lahore) 53 · Lahore High Court · 2020-05-06
  suspension of sentencenarcotic substancesshort sentencepost-conviction bailappellate review
  Summary & questions settled

  This criminal miscellaneous application arises from a conviction under the Control of Narcotic Substances Act, 1997, wherein the petitioner, Muhammad Ismail, was sentenced to four years and six months of rigorous imprisonment. The petitioner sought the suspension of his sentence pending the outcome of his appeal, primarily arguing that the trial court's judgment was based on a misreading and non-reading of the evidence and emphasizing that the awarded sentence was relatively short. The core legal question before the Court was whether the sentence should be suspended during the pendency of the appeal given the likelihood that the petitioner might serve the entire sentence before the appeal could be heard. The Court, observing that the appeal was unlikely to be heard in the near future, held that the sentence should be suspended to prevent the petitioner from potentially serving the full term before his conviction could be reviewed. The key principle laid down is that where an appeal is not likely to be heard in the near future, the suspension of a short sentence is warranted to avoid the risk of the sentence being fully served before the appeal is decided.

  Questions settled

  • Can a sentence be suspended pending appeal if the appeal is unlikely to be heard in the near future?
  • Is the short duration of a sentence a valid ground for suspension of sentence pending appeal?
  • Does the possibility of serving the entire sentence before an appeal is heard justify the grant of bail?
  Read full judgment →
• Muhammad Ismail vs Muhammad Adil2021 PLJ Lahore 388, 2021 LHC 85, 2021 CLD 586, 2022 [M] CLR 1664 · Lahore High Court · 2021-01-19Read full judgment →
• Muhammad Ismail Nadeem vs Additional District Judge, Jhang and 22022 YLR 93 · Lahore High Court · 2021-05-31Read full judgment →
• Muhammad Islam, Sheikh & another vs Pakistan Railway & others2021 [M] C L R 273 · Lahore High Court · 2017-09-19Read full judgment →
• Muhammad Ishtiaq vs Federation Of Pakistan Ministry Energy And Power2021 PLJ Lahore 681 · Lahore High CourtRead full judgment →
• Muhammad Ishaq vs The State and another2021 P Cr. L J 636 · Lahore High Court · 2021-03-15
  pre-arrest baildishonour of chequemala fideextraordinary reliefcriminal breach
  Summary & questions settled

  This matter arises from a petition filed under Section 498 of the Code of Criminal Procedure 1898 seeking pre-arrest bail in respect of FIR No. 44/21 registered under Section 489-F of the Pakistan Penal Code 1860 at Police Station City Samundari, District Faisalabad, concerning the dishonour of a cheque issued for the purchase of poultry feed. The core legal question was whether the petitioner made out a case for the extraordinary relief of pre-arrest bail where the issuance of the cheque and signatures were admitted, and the defense of the cheque being a mere 'guarantee' or the pendency of a civil suit lacked immediate corroboration. The Lahore High Court held that oral pleas regarding a guarantee cannot outweigh the documentary reality at the bail stage, the mere filing of a civil suit does not warrant pre-arrest bail, and the petitioner failed to establish mala fide or ulterior motives on the part of the complainant. The court laid down the principle that pre-arrest bail is an extraordinary remedy meant for innocent persons facing mala fide arrest, and in the absence of malice or ulterior motives, such relief cannot be granted.

  Questions settled

  • Whether pre-arrest bail can be granted solely on the ground that a civil suit seeking cancellation of the disputed cheque has been filed?
  • Does an oral plea that a cheque was issued as a guarantee outweigh the written contents of the instrument at the pre-arrest bail stage?
  • What constitutes sufficient ground for the grant of extraordinary relief of pre-arrest bail in cases involving financial transactions?
  Read full judgment →
• Muhammad Ishaq and 156 others vs Member (Consolidation) Board Of Revenue and 12 others2021 CLC 884 · Lahore High Court · 2020-10-14Read full judgment →
• Muhammad Irshad vs Government of Punjab, etc2021 LHC 748, 2022 PLC (C.S.) 852 · Lahore High Court · 2021-04-06
  civil servicesuperannuationmedical invalidationpast and closed transactionfunctus officioretirement orderintra court appeal
  Summary & questions settled

  This Intra Court Appeal challenges an order passed by a learned Single Judge in Chambers, which dismissed a constitutional petition seeking the modification of the appellant's retirement order. The appellant, a civil servant, sought to change the basis of his retirement from superannuation to medical invalidation, citing a medical certificate issued prior to his superannuation date. The core legal question was whether a retirement order based on superannuation, which had already taken effect, could be modified to reflect retirement on medical grounds after the fact. The Court held that the retirement order based on superannuation had attained finality and constituted a past and closed transaction. It reasoned that the competent authority had become functus officio regarding the retirement decision by the time the medical certificate was processed and received. Furthermore, the Court noted that the appellant had already accepted retirement benefits, precluding him from seeking to reopen the matter. The key principle laid down is that once a retirement order is issued and takes effect, it cannot be reopened or modified, as it becomes a past and closed transaction to which finality attaches.

  Questions settled

  • Can a retirement order based on superannuation be modified to medical invalidation after the retirement has taken effect?
  • Does a retirement order attain finality as a past and closed transaction once it has been issued and implemented?
  • Can a civil servant seek to modify their retirement status after having accepted the emoluments associated with the original retirement order?
  Read full judgment →
• Muhammad Irshad alias Babi etc vs State etcPLJ 2021 Cr.C. (Lahore) 309 · Lahore High Court · 2020-11-04
  criminal appealmurderbenefit of doubtsuppression of injuriescredibility of witnessesforensic evidenceacquittal
  Summary & questions settled

  This criminal appeal challenges the convictions and sentences imposed by the trial court for murder and attempted murder under the Pakistan Penal Code 1860. The core legal question concerns whether the prosecution successfully established the guilt of the appellants beyond reasonable doubt, particularly in light of allegations that the prosecution suppressed material facts regarding injuries sustained by the accused. The Lahore High Court held that the prosecution's case was fundamentally flawed due to the suppression of fire-arm injuries on the persons of the accused, which were confirmed by medical evidence, thereby shattering the credibility of the eye-witnesses. Additionally, the court found that recoveries of weapons were inconsequential due to the absence of forensic matching. Consequently, the court set aside the convictions, acquitted the appellants, and answered the murder reference in the negative. The judgment reaffirms the principle that if any circumstance creates reasonable doubt in a prudent mind regarding the guilt of the accused, the accused is entitled to the benefit of that doubt as a matter of right, not as a concession.

  Questions settled

  • Does the suppression of injuries sustained by the accused in a criminal case entitle them to the benefit of doubt?
  • Can the testimony of an injured witness be discarded if they are found to have suppressed material facts?
  • Is the recovery of a weapon of offence considered inconsequential in the absence of a positive forensic report?
  Read full judgment →
• Muhammad Irfan vs State and another2021 PLJ Cr.C (Lahore) 796 · Lahore High Court · 2021-01-21
  criminal appealmurderocular accountmedical evidenceenhancement of sentenceappreciation of evidencerelated witnesses
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of the appellant under Section 302(b), PPC, alongside a criminal revision seeking enhancement of the sentence. The core legal question concerns whether the prosecution proved the charge of murder beyond reasonable doubt through ocular account, medical evidence, recoveries, and motive. The court held that the ocular testimony of related witnesses, corroborated by medical evidence, prompt FIR registration, and supporting recoveries, sufficiently established the appellant's guilt, while finding no justification to enhance the life imprisonment sentence to death. The key principle laid down is that the testimony of close relatives cannot be discarded solely on the ground of their relationship, provided it remains consistent, withstands cross-examination, and finds corroboration from other material evidence.

  Questions settled

  • Whether the testimony of close relatives can be discarded merely on the ground of their relationship with the deceased or complainant?
  • Does medical evidence corroborating the locale of injuries and weapon used support the ocular account in a murder trial?
  • Whether a sentence of life imprisonment should be enhanced to death when the reasons recorded by the trial court for awarding lesser punishment are logical?
  • Can prompt registration of an FIR without delay lend credibility to the prosecution's case?
  Read full judgment →
• Muhammad Iqbal, etc vs Jalal Din, etc2021 LHC 5573 · Lahore High Court · 2021-10-25Read full judgment →
• Muhammad Iqbal vs State and anotherPLJ 2021 Cr.C. (Lahore) 274 · Lahore High Court · 2020-11-09
  criminal appealmurder referencebenefit of doubtdishonest improvementswitness credibilityacquittalprivate complaintdeath sentence
  Summary & questions settled

  The appellant challenged his conviction and death sentence under Section 302(b) of the Pakistan Penal Code 1860 for murder. The core legal question was whether the prosecution established guilt beyond reasonable doubt, considering significant discrepancies between the initial FIR and the subsequent private complaint, along with the acquittal of co-accused. The Lahore High Court allowed the appeal, set aside the conviction, and acquitted the appellant, answering the Murder Reference in the negative. The Court held that "dishonest improvements" made by witnesses in their testimony, which contradicted their initial statements, fundamentally shattered their credibility. Additionally, the Court observed that since the co-accused were acquitted on the same evidence and no independent corroboration existed against the appellant, the appellant was entitled to acquittal. The Court reaffirmed the principle that the benefit of the doubt is not a matter of grace but a right, and a single circumstance creating reasonable doubt is sufficient to warrant an acquittal.

  Questions settled

  • Does the acquittal of co-accused on the same evidence necessitate the acquittal of the remaining accused in the absence of independent corroboration?
  • What is the legal effect of 'dishonest improvements' in witness testimony on the credibility of the prosecution's case?
  • Is a delay in medical examination of an injured witness sufficient to shatter their credibility?
  • Does the failure to prepare a parcel of a recovered weapon at the time of recovery render the recovery evidence unreliable?
  Read full judgment →
• Muhammad Iqbal vs Mst. Kalsoom Bibi and Three others2021 LHC 5389 · Lahore High Court · 2021-10-21Read full judgment →
• Muhammad Iqbal Brar vs National Bank Of Pakistan through President_Chief Executive and others2021 PL C (C.S.) 158 · Lahore High Court
  bank employee demotionstatutory remedyFederal Service TribunalRemoval from Service (Special Powers) Ordinance 2000fiduciary dutylachesmaintainability of writ petition
  Summary & questions settled

  This matter concerns constitutional petitions challenging the demotion of bank employees from the post of Assistant Vice President to Officer Grade-I by the National Bank of Pakistan. The petitioners contended that the orders were passed by an incompetent authority and that the mandatory Show-Cause Notice procedure under the Removal from Service (Special Powers) Ordinance, 2000, was not followed. Conversely, the respondent bank argued that the petitions were barred by laches, that the petitioners had retired, and that the High Court lacked jurisdiction as the petitioners failed to exhaust the statutory remedy of appeal before the Federal Service Tribunal under the Ordinance. The Court held that the petitions were not maintainable because the petitioners failed to avail the statutory remedy provided under the law. Furthermore, addressing the merits, the Court observed that the petitioners had flouted bank policies and SOPs, noting that the fiduciary nature of banking requires strict adherence to trust and policy. Consequently, the Court dismissed the petitions, emphasizing that bank employees involved in policy violations deserve no leniency.

  Questions settled

  • Does the High Court have jurisdiction to entertain a challenge to a service order when the petitioner has failed to exhaust the statutory remedy of appeal before the Federal Service Tribunal?
  • Is a bank employee's failure to follow internal policies and SOPs a valid ground for disciplinary action?
  • Does the principle of laches apply to service matters where the petitioner has delayed challenging a demotion order?
  Read full judgment →
• Muhammad Iqbal and another vs The State and another2021 LHC 218 · Lahore High Court · 2021-02-10
  post-arrest bailrule of consistencyvicarious liabilitycommon intentioncriminal procedurebail application
  Summary & questions settled

  This petition for post-arrest bail arises from F.I.R. No. 189/2020, involving charges under Sections 302, 324, 148, 149, 337-F(i), 337-F(iii), 337-F(vi), 337-A(i), 337-A(ii), and 337-L(2) of the Pakistan Penal Code 1860. The core legal question was whether the petitioners were entitled to bail despite the allegations against them, given that co-accused persons with identical roles had already been granted bail. The Court held that the petitioners were entitled to post-arrest bail. The ratio of the decision rests on the "rule of consistency," which dictates that where co-accused persons attributed with similar or identical roles in an F.I.R. have been granted bail, the petitioner cannot be denied the same relief merely because the police investigation found them guilty. The Court further noted that the evidentiary value of alleged recoveries and the issue of vicarious liability under common intention are matters to be determined by the trial court after recording evidence, rather than at the bail stage. Consequently, the petition was accepted subject to the furnishing of bail bonds.

  Questions settled

  • Does the fact that an accused was found guilty during the police investigation justify denying bail when co-accused with identical roles have been granted bail?
  • Can the rule of consistency be applied to grant bail to an accused when co-accused persons with similar roles have already been released on bail?
  • Should the evidentiary value of recoveries be determined at the bail stage or during the trial?
  Read full judgment →
• Muhammad Imran vs StatePLJ 2021 Cr.C. 1311 · Lahore High Court · 2021-06-07
  murder referencedeath sentencebenefit of doubtchance witnessFIR delaySection 342 statementacquittal
  Summary & questions settled

  This criminal appeal arises from a conviction and death sentence imposed by the trial court for murder under Section 302(b) of the Pakistan Penal Code 1860. The core legal question was whether the prosecution had proven the appellant's guilt beyond a reasonable doubt, given significant discrepancies in the FIR, the credibility of eye-witnesses, and the lack of forensic evidence. The Lahore High Court held that the prosecution failed to establish its case. The Court identified multiple fatal flaws: the FIR was likely fabricated post-facto, the eye-witnesses were chance witnesses who failed to justify their presence, and there were dishonest improvements in testimony regarding the source of light and the sequence of events. Furthermore, the recovery of the weapon was rendered inconsequential due to the absence of a positive forensic report matching the crime empties. The Court reaffirmed that if the prosecution fails to prove its case, the accused must be acquitted, regardless of any plea taken under Section 342 of the Code of Criminal Procedure 1898, which must be accepted or rejected in its entirety.

  Questions settled

  • Does a statement made by an accused under Section 342 of the Code of Criminal Procedure 1898 have to be accepted or rejected in its entirety?
  • If the prosecution fails to prove its case, must an accused be acquitted even if they admitted their presence at the scene in their defence plea?
  • Is the recovery of a weapon consequential if there is no positive forensic report matching the crime empties to the weapon?
  • Can the credibility of eye-witnesses be undermined by dishonest improvements made during trial testimony compared to the initial FIR?
  Read full judgment →
• Muhammad Imran vs State etcPLJ 2021 Cr.C. 946 · Lahore High Court · 2021-03-16
  Qatal-e-Amdchance witnessesburden of proofbenefit of doubtmatrimonial homecriminal appealmurder reference
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence of the appellant for the murder of his wife and causing injuries to his daughter. The core legal question was whether the prosecution successfully established the appellant's guilt beyond reasonable doubt, given the testimony of alleged eye-witnesses and the circumstances of the death. The Lahore High Court held that the prosecution failed to discharge its initial burden of proof. The Court observed that the eye-witnesses were "chance witnesses" whose testimony was unreliable because they failed to explain multiple injuries found on the deceased. Furthermore, the Court clarified that while an unnatural death within a matrimonial home is a relevant circumstance, it does not shift the burden of proof to the accused if the prosecution’s case is fundamentally weak. Emphasizing that the burden of proof remains with the prosecution throughout the trial, the Court held that any reasonable doubt entitles the accused to acquittal as a matter of right. Consequently, the conviction was set aside, and the appellant was acquitted.

  Questions settled

  • Does the burden of proof shift to the accused when a wife is found murdered within the matrimonial home?
  • Are eye-witnesses who fail to explain all injuries on the deceased considered reliable?
  • Is an accused entitled to acquittal if there is a single circumstance creating reasonable doubt in the prosecution's case?
  • Can a conviction be maintained if the prosecution fails to discharge its initial burden of proof?
  Read full judgment →
• Muhammad Imran vs Full Bench National Industrial Relations Commission2021 PLC 263, 2022 PLJ Lahore 40 · Lahore High Court · 2021-05-24
  workman statusmanagerial capacityindustrial relationspower of attorney interpretationNIRC jurisdictionbank employeeconstitutional petition
  Summary & questions settled

  This constitutional petition challenged an order of the Full Bench of the National Industrial Relations Commission (NIRC) which had overturned a Single Bench decision reinstating the petitioner, a former bank employee. The core legal question was whether the petitioner, an Officer Grade-I, qualified as a 'workman' under Section 2(xxxiii) of the Industrial Relations Act, 2012, thereby entitling him to invoke the NIRC's jurisdiction. The High Court held that the petitioner was not a workman. The ratio of the decision is that the status of an employee is determined by the nature of their duties and the scope of their authority, not merely by restrictive clauses in a power of attorney. By examining the Power of Attorney as a whole, the Court found the petitioner was entrusted with significant managerial and supervisory functions, such as negotiating bills and operating accounts, which are inconsistent with the definition of a workman. The Court affirmed that reading a document in its entirety, rather than isolating prohibitory clauses, is the cardinal principle of interpretation.

  Questions settled

  • Whether an Officer Grade-I in a bank qualifies as a 'workman' under the Industrial Relations Act, 2012?
  • Does the presence of a prohibitory clause in a power of attorney negate the managerial nature of an employee's duties?
  • Should a power of attorney be interpreted by reading it as a whole to determine the status of an employee?
  Read full judgment →
• Muhammad Imran vs Additional District Judge etc2021 PLJ Lahore 616 · Lahore High Court · 2017-08-08Read full judgment →
• Muhammad Imran and others vs The State2021 YLR 95 · Lahore High Court · 2020-03-03
  murder referencebenefit of doubtidentification paradeunexplained delay in FIRforensic science laboratoryrecovery of crime weaponocular account improvement
  Summary & questions settled

  This criminal appeal and murder reference arose from the judgment of the Additional Sessions Judge, Sialkot, convicting the appellants under Sections 302(b) and 394 read with Section 34, P.P.C. The core legal questions pertained to the evidentiary value of an unexplained delay in lodging the FIR, ocular testimony with material improvements, an identification parade conducted jointly without prior physical descriptions in the FIR, and recoveries sent to the forensic laboratory post-arrest. The Lahore High Court allowed the appeal, answered the murder reference in the negative, set aside the convictions, and acquitted the appellants. The Court held that an unexplained FIR delay suggests consultation; ocular testimony lacking source-of-light details and varying from the initial FIR is unreliable; a joint identification parade without prior descriptions lacks legal value; sending crime empties to the forensic laboratory after an accused's arrest vitiates the laboratory report; and medical evidence cannot establish the identity of assailants. Consequently, the appellants were entitled to the benefit of doubt as a matter of right.

  Questions settled

  • What is the legal effect of an unexplained delay in lodging an FIR when the police station is situated in close proximity to the place of occurrence?
  • Does a test identification parade possess evidentiary value if the physical features or descriptions of unknown accused persons were omitted in the initial FIR?
  • Can a joint identification parade of multiple accused persons conducted in one go be legally sustained?
  • What is the evidentiary value of a positive Forensic Science Laboratory report when the crime empty is dispatched after the arrest of the accused?
  Read full judgment →
• Muhammad Imran and others vs State and anotherPLJ 2021 Cr.C. (Lahore) 542 · Lahore High Court · 2020-06-19
  pre-arrest bailcriminal procedureFIR registrationjudicial discretionpenal provisionsbail application
  Summary & questions settled

  This is a petition for pre-arrest bail filed by the accused in a criminal case registered under Sections 341, 342, 148, and 149 of the Pakistan Penal Code 1860. The core legal question was whether a trial court, while adjudicating a bail application, possesses the authority to unilaterally import a penal provision—specifically Section 365 of the Pakistan Penal Code 1860—into an FIR when the police have not initially charged the accused with that offence. The High Court held that the trial court acted improperly by importing a new offence not charged by the police. Consequently, the court accepted the bail application and confirmed the interim pre-arrest bail previously granted to the petitioners. The established legal principle is that a court cannot import a new offence into an FIR that the accused has not been charged with by the investigating agency. Adjudication must remain confined to the specific charges brought by the prosecution, as expanding the scope of the FIR during bail proceedings is legally impermissible and prejudices the accused.

  Questions settled

  • Can a trial court unilaterally import a penal provision into an FIR during bail proceedings?
  • Is a court permitted to add charges to an FIR that were not included by the police?
  • Does the addition of a non-bailable offence by the court, where none was charged by the police, justify the denial of bail?
  Read full judgment →
• Muhammad Ikram vs State and anotherPLJ 2021 Cr.C. 1325 · Lahore High Court · 2021-03-03
  post-arrest baildishonoured chequeSection 489-F PPCburden of prooffurther probecriminal liabilityrecovery of money
  Summary & questions settled

  This matter concerns a petition for post-arrest bail filed by the accused, Muhammad Ikram, in a criminal case registered under Section 489-F of the Pakistan Penal Code 1860 for the dishonour of a cheque. The core legal question was whether the essential ingredients of Section 489-F, specifically the existence of a loan or an obligation for which the cheque was issued, were established by the prosecution to justify continued incarceration. The Court held that the prosecution failed to produce any documentary evidence, such as a khata register or receipts, to substantiate the alleged business transaction or the underlying obligation. Consequently, the Court found the applicability of the penal provision to be a matter of further probe, bringing the case within the ambit of Section 497(2) of the Code of Criminal Procedure 1898. The Court laid down the principle that Section 489-F cannot be utilized as a tool for the recovery of money, and that mere issuance and dishonour of a cheque are insufficient for conviction without proof of an underlying obligation.

  Questions settled

  • Is the mere issuance and dishonour of a cheque sufficient to establish an offence under Section 489-F of the Pakistan Penal Code 1860?
  • Does the prosecution need to prove an underlying loan or obligation to sustain a charge under Section 489-F of the Pakistan Penal Code 1860?
  • Can Section 489-F of the Pakistan Penal Code 1860 be utilized as a mechanism for the recovery of money?
  Read full judgment →
• Muhammad Ijaz vs Government of Punjab, etc2021 PLC (C.S.) 1154, 2021 LHC 1518 · Lahore High Court · 2021-06-03
  Rule 17-Abeneficial legislationcivil servicejudicial reviewadministrative instructionsvested rightsincapacitationretrospective application
  Summary & questions settled

  This matter concerns the validity of an administrative notification issued by the Regulations Wing of the S&GAD, which sought to restrict the scope of Rule 17-A of the Punjab Civil Servants (Appointment and Conditions of Service) Rules, 1974. The notification attempted to exclude children of government servants retired on medical grounds in 'category B' from the benefits of Rule 17-A, citing concerns over the misuse of the facility. The petitioners, who had already been appointed under this rule, challenged the denial of their employment and salary following this notification. The Court held that Rule 17-A is a piece of beneficial legislation designed to provide relief to families of civil servants who die or are incapacitated during service. The Court ruled that administrative instructions cannot override or restrict statutory rules, nor can they introduce classifications (such as medical categories) not present in the rule itself. Furthermore, the Court held that such instructions cannot operate retrospectively to impair vested rights. Consequently, the notification was struck down as illegal, and the respondents were directed to reinstate the petitioners.

  Questions settled

  • Can administrative instructions or notifications restrict the scope of a statutory rule?
  • Does Rule 17-A of the Punjab Civil Servants (Appointment and Conditions of Service) Rules, 1974, permit the categorization of medical invalidation into 'category A' and 'category B' for the purpose of denying benefits?
  • Can administrative instructions operate retrospectively to take away vested rights already granted under a statutory rule?
  • Is the denial of benefits under Rule 17-A based on administrative categorization subject to judicial review?
  Read full judgment →
• Muhammad Ijaz and 2 others vs Amanat Ali2021 YLR 1116 · Lahore High Court · 2020-11-12Read full judgment →
• Muhammad Idrees vs The State and another2021 YLR 766 · Lahore High Court · 2019-12-19
  narcotic controlcharas recoverypolice witnessesforensic science agency reportmandatory and directory rulescriminal appealpost-arrest bail
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of the appellant under section 9(c) of the Control of Narcotic Substances Act, 1997, handed down by the trial court for the recovery of 1630 grams of Charas. The core legal questions involved the credibility of police witnesses in the absence of public witnesses, the mandatory versus directory nature of the Control of Narcotic Substances (Government Analysts) Rules, 2001 (specifically regarding the time limit for dispatching samples), and the evidentiary value of the Punjab Forensic Science Agency report. The Lahore High Court dismissed the appeal and upheld the conviction, holding that Section 25 of the Control of Narcotic Substances Act, 1997 excludes Section 103 of the Code of Criminal Procedure, 1898, making public witnesses unnecessary, and that the timeline rules under the CNS Rules are directory rather than mandatory, requiring only substantial compliance. Furthermore, the court held that the use of Gas Chromatography-Mass Spectrometry as a confirmatory test provides conclusive proof of the nature of the recovered substance.

  Questions settled

  • Whether association of public witnesses is mandatory during the recovery of narcotics under the Control of Narcotic Substances Act, 1997?
  • Are the timelines prescribed under the Control of Narcotic Substances (Government Analysts) Rules, 2001 for sending samples to the laboratory mandatory or directory?
  • What is the evidentiary value of a Punjab Forensic Science Agency report utilizing Gas Chromatography-Mass Spectrometry for narcotics identification?
  • Does the testimony of police officials alone suffice to maintain a conviction under the Control of Narcotic Substances Act, 1997 in the absence of corroboration by private witnesses?
  Read full judgment →
• Muhammad Idrees vs State etcPLJ 2021 Cr.C. (Lahore) 722 · Lahore High Court · 2021-03-02
  criminal revisiondishonestly issuing a chequecompromiseacquittalcompoundable offence
  Summary & questions settled

  The petitioner, Muhammad Idrees, challenged his conviction and sentence under Section 489-F of the Pakistan Penal Code 1860, arising from FIR No. 462/2017 registered at Police Station Baseerpur, District Okara. Following his conviction by the Magistrate Section-30 (MTMC) Depalpur and the subsequent dismissal of his criminal appeal by the Additional Sessions Judge, Depalpur, the petitioner approached the Lahore High Court. At the hearing, the complainant stated that a compromise had been effected between the parties and that he had no objection to the petitioner's acquittal. The court observed that the subject offence is compoundable. Consequently, the court accepted the petition, set aside the judgments of the lower courts, and acquitted the petitioner of the charge, directing his immediate release unless required in any other case.

  Questions settled

  • Can a conviction under Section 489-F of the Pakistan Penal Code 1860 be set aside on the basis of a compromise between the parties?
  • Whether an accused can be acquitted in a compoundable criminal case when the complainant states that the matter has been patched up and has no objection to the acceptance of the petition?
  Read full judgment →
• Muhammad Ibrahim Khosa and another vs Federation Of Pakistan through Secretary Ministry of Interior Islamabad and 5 others2021 PLJ Lahore 558 · Lahore High Court · 2020-12-08Read full judgment →
• Muhammad Ibrahim Ghazali vs Chairman, LDA, Lahore etc2021 PLJ Lahore 569 · Lahore High Court · 2021-03-10Read full judgment →
• Muhammad Hussain vs Government Of Punjab, through Secretary Housing2021 PLJ Lahore 796, 2021 PLJ Lahore 356 · Lahore High Court · 2020-12-24Read full judgment →
• Muhammad Hayat etc vs State etcPLJ 2021 Cr.C. 1295 · Lahore High Court · 2021-06-25
  murderbenefit of the doubtocular accountcontradictory evidencedelayed FIRmotivecriminal appealmedical evidence
  Summary & questions settled

  This criminal appeal challenges the convictions and sentences of the appellants for murder and murderous assault under Sections 302, 324, 452, 109, 148, and 149 of the Pakistan Penal Code 1860, while a connected criminal revision seeks enhancement of sentences. The core legal questions involve the assessment of ocular testimony with delayed statements under Section 161 of the Code of Criminal Procedure 1898, the evidentiary value of FIRs containing minutely detailed descriptions of an unwitnessed occurrence, the corroborative scope of medical evidence, and the application of the benefit of the doubt. The Lahore High Court held that the prosecution failed to prove its case beyond reasonable doubt due to material contradictions, delayed police reporting, exaggerated ocular accounts lacking corroboration, and an unproven motive. Consequently, the court allowed the appeal, set aside the convictions and sentences, acquitted the appellants on the basis of benefit of the doubt, and dismissed the revision for sentence enhancement. The key principles established emphasize that a single reasonable doubt entitles the accused to acquittal, that the prosecution must stand on its own legs, and that medical evidence alone cannot identify perpetrators.

  Questions settled

  • Whether an ocular account containing minutely detailed descriptions of an unwitnessed occurrence is sufficient to sustain a conviction?
  • Can the prosecution take benefit from the weaknesses of the defence case?
  • Does the presence of injuries on the body of a witness automatically stamp them as a truthful witness?
  • What is the evidentiary scope of medical evidence regarding the identity of assailants?
  Read full judgment →
• Muhammad Hassan alias Aamir vs The State and others2022 YLR 805 · Lahore High Court · 2021-06-24
  criminal appealmurderabundant cautionadverse inferenceocular evidencemotiveprivate complaintforensic evidence
  Summary & questions settled

  This matter concerns a criminal appeal against a conviction for murder, a revision petition for sentence enhancement, and a petition for leave to appeal against the acquittal of co-accused. The core legal questions involved the impact of non-producing an injured witness, the effect of forensic report discrepancies, and whether the acquittal of co-accused mandates the acquittal of the principal offender. The Court held that the prosecution successfully proved the appellant's guilt through consistent ocular testimony and established motive, despite the acquittal of co-accused. The Court affirmed the conviction, dismissing the appeal, revision, and PSLA. Key principles laid down include: first, that the non-production of an injured witness does not automatically warrant an adverse inference under Article 129(g) of the Qanun-e-Shahadat Order 1984, as courts may summon such witnesses; second, that the acquittal of co-accused based on the doctrine of abundant caution does not invalidate the prosecution's case against the principal offender; and third, that motive is a double-edged weapon requiring assessment based on the specific circumstances of each case.

  Questions settled

  • Does the non-production of an injured witness by the prosecution automatically warrant an adverse inference under Article 129(g) of the Qanun-e-Shahadat Order 1984?
  • Can the acquittal of co-accused based on the doctrine of abundant caution invalidate the conviction of the principal offender?
  • Is the statement of an accused recorded under Section 342 of the Code of Criminal Procedure 1898 more reliable than a statement recorded under Section 164 of the Code of Criminal Procedure 1898?
  • Does a delay in conducting a post-mortem examination necessarily render the prosecution's case doubtful?
  Read full judgment →
• Muhammad Hashim Khan vs State and anotherPLJ 2021 Cr.C. (Lahore) 99 · Lahore High Court · 2019-10-14
  post-arrest bailmurderprohibitory clauseocular accountmedical evidencedeeper appreciation of evidence
  Summary & questions settled

  This petition for post-arrest bail arises from FIR No. 110/2019, registered under Sections 302 and 34 of the Pakistan Penal Code 1860, concerning the murder of Adnan Haider. The petitioner was accused of firing a fatal shot at the deceased, an allegation supported by the FIR, ocular accounts, and medical evidence confirming the cause of death. The core legal question was whether the petitioner was entitled to post-arrest bail given the incriminating material on record. The Court held that the petitioner was nominated in the FIR with a specific role, and the medical evidence corroborated the prosecution's case, including the recovery of the weapon. Consequently, the Court dismissed the bail petition, finding that the offence fell within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898. The key principle laid down is that where there is prima facie evidence of involvement in a capital offence, and the contentions raised require a deeper appreciation of evidence, bail is not warranted at the pre-trial stage, as such evaluation is impermissible during bail proceedings.

  Questions settled

  • Does an offence under Section 302 of the Pakistan Penal Code 1860 fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Is a deeper appreciation of evidence permissible at the stage of deciding a post-arrest bail petition?
  • Can bail be granted when the petitioner is nominated in the FIR with a specific role and medical evidence corroborates the prosecution's version?
  Read full judgment →
• Muhammad Haroon @ Haroon Machhi vs State etcPLJ 2021 Cr.C. (Lahore) 196 · Lahore High Court · 2020-07-16
  post-arrest bailsodomyfurther inquiryforensic evidencecorroborationcriminal antecedentstentative assessment
  Summary & questions settled

  This petition for post-arrest bail arises from an F.I.R. registered under Section 377 of the Pakistan Penal Code 1860, involving allegations of sodomy. The petitioner sought bail after being incarcerated, contending that the prosecution's case lacked sufficient evidence. The core legal question was whether the petitioner was entitled to bail based on the tentative assessment of the available evidence. Upon review, the Court observed that the medical examination of the victim revealed no signs of violence, and the Punjab Forensic Science Agency report failed to detect seminal material, rendering DNA analysis inconclusive. Consequently, the Court held that the prosecution's version lacked prima facie corroboration, making the case one of further inquiry under Section 497(2) of the Code of Criminal Procedure 1898. The Court further noted the petitioner's lack of criminal antecedents and that his custody was no longer required for investigation. The petition was allowed, and the petitioner was admitted to bail subject to furnishing bail bonds, establishing the principle that the absence of corroborative forensic or medical evidence at the bail stage warrants the grant of bail under the 'further inquiry' provision.

  Questions settled

  • Does the absence of seminal material in a forensic report constitute grounds for bail in a sodomy case?
  • When does a criminal case qualify as one of 'further inquiry' under Section 497(2) of the Code of Criminal Procedure 1898?
  • Is a deeper appreciation of evidence permissible at the bail stage?
  Read full judgment →
• Muhammad Hamza Khan vs Pakistan Medical And Dental Council through Registrar and 2 others2021 CLC 546 · Lahore High Court · 2020-11-02Read full judgment →
• Muhammad Hamad ur Rehman vs Director FIA, etc2021 LHC 4371, 2022 PLD Lahore 177 · Lahore High Court · 2021-09-02
  constitutional petitiondoctrine of ripenessprematurityinvestigationSection 160 Cr.P.C.judicial reviewFIA inquiry
  Summary & questions settled

  This constitutional petition challenged a notice issued by the Federal Investigation Agency (FIA) under Section 160 of the Code of Criminal Procedure 1898, requiring the petitioner to appear for an inquiry. The petitioner sought to quash the notice, fearing arrest and harassment. The core legal question was whether a constitutional petition is maintainable against a preliminary notice issued by an investigating agency during an inquiry. The Court held that the petition was premature and not ripe for adjudication. It reasoned that the issuance of a notice for the purpose of participating in an ongoing inquiry is a statutory obligation of the investigating agency and does not constitute an adverse action impacting the petitioner's rights. The Court affirmed that an investigating officer can summon any person, including an accused or suspect, to provide information relevant to a crime. The key principle laid down is the doctrine of prematurity and ripeness: courts will not interfere in constitutional jurisdiction against preliminary administrative or investigative measures, as doing so would improperly stultify statutory duties before a final, adverse decision is reached.

  Questions settled

  • Is a constitutional petition maintainable against a notice issued by an investigating agency under Section 160 of the Code of Criminal Procedure 1898?
  • Does the term 'any person' in Section 160 of the Code of Criminal Procedure 1898 include an accused or a suspect?
  • Can a court interfere in the investigative process of a statutory body before a final decision is reached?
  • What is the scope of the doctrine of prematurity and ripeness in the context of judicial review of administrative actions?
  Read full judgment →
• Muhammad Haleem vs Mst. Safa Shabbir and 2 others2021 PLJ Lahore 415 · Lahore High Court · 2019-01-17Read full judgment →
• Muhammad Ghazanfar Naveed vs The State etc2021 LHC 8241, 2022 PLJ Lahore 166 · Lahore High Court · 2021-12-23Read full judgment →
• Muhammad Feroz and another vs State and another2021 PLJ Cr.C (Lahore) 891 · Lahore High Court · 2021-03-01
  murderdeath sentencebenefit of the doubtchance witnessmedical and ocular conflictdelayed FIRweapon recoverycriminal appeal
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence of the appellants under Section 302(b), PPC for murder, alongside a murder reference and an appeal against the acquittal of a co-accused. The core legal questions involved the reliability of chance witnesses, delayed FIR reporting, inconsistencies between ocular and medical evidence, and the evidentiary value of delayed forensic reports and recoveries. The Lahore High Court held that the prosecution failed to establish its case beyond a reasonable doubt due to inordinate unexplained delay in reporting the crime, doubtful presence and testimony of chance witnesses, direct conflict between ocular and medical evidence, unproven motive, and flawed weapon recoveries. Consequently, the court set aside the convictions and death sentences, extending the benefit of the doubt to the appellants and dismissing the appeal against the co-accused's acquittal. The key principle laid down is that multiple circumstances creating doubt in the prosecution's narrative entitle the accused to the benefit of the doubt, and prosecution must stand on its own legs.

  Questions settled

  • Whether inordinate delay in reporting a crime without plausible explanation damages the veracity of the prosecution case?
  • Can the testimony of chance witnesses be relied upon without convincing explanations for their presence at the crime scene?
  • Does a positive forensic report lose its evidentiary value if crime empties are sent to the laboratory after the arrest of the accused?
  • Whether inconsistencies between ocular testimony and medical evidence are sufficient to create doubt regarding the prosecution's version?
  Read full judgment →
• Muhammad Fayyaz vs Federation Of Pakistan and others2022 PTD 399 · Lahore High Court · 2021-02-22
  anti-dumping dutiesconstitutional petitionexhaustion of remediesstatutory appellate tribunalcoercive measuresinterim reliefdue processNational Tariff Commission
  Summary & questions settled

  This constitutional petition challenged the final determination and instructions issued by the National Tariff Commission (NTC) regarding anti-dumping duties on imported cold rolled coils/sheets/strips. The petitioner argued that the NTC failed to follow the procedural requirements of the Anti-Dumping Duties Act, 2015, specifically regarding notice and investigation, thereby violating fundamental rights under the Constitution of Pakistan, 1973. The respondents raised a preliminary objection regarding the maintainability of the petition, noting that the petitioner had already filed an appeal before the Anti-Dumping Appellate Tribunal, which is the proper statutory forum. The Court observed that the Anti-Dumping Duties Act, 2015 provides a comprehensive mechanism for adjudication and appeals, including provisions for priority handling of appeals and interim relief. Consequently, the Court declined to interfere in the merits of the case, holding that the petitioner must exhaust the statutory appellate remedy. However, as a stopgap measure, the Court directed the Tribunal to decide the pending interim relief application within one week and restrained the authorities from taking coercive measures against the petitioner until such decision is rendered.

  Questions settled

  • Can a High Court entertain a constitutional petition when an appeal is already pending before the Anti-Dumping Appellate Tribunal?
  • Is a petitioner entitled to interim relief from the High Court while an appeal is pending before the statutory appellate forum?
  • Does the Anti-Dumping Duties Act 2015 mandate a specific timeline for the disposal of appeals by the Appellate Tribunal?
  • Can coercive recovery measures be taken against a taxpayer while their appeal and stay application are pending before the competent appellate authority?
  Read full judgment →
• Muhammad Farooq Ahmed vs Riffat Bibi etc2021 PLJ Lahore 239 · Lahore High Court · 2020-01-27Read full judgment →