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. 46,805 judgments in total from the Sindh High Court.

• Khan Muhammad Versus The State2003 YLR 2175 · Sindh High Court · 2003-01-30
  abduction for ransomconfessional statementretracted confessionextra-judicial confessionjoint trialrecovery of dead bodyballistic expert reportdeath sentence confirmationanti-terrorism court
  Summary & questions settled

  This criminal appeal and confirmation cases arose from a judgment of the Anti-Terrorism Court convicting the appellants for abduction, murder, and related offenses under the Pakistan Penal Code, Anti-Terrorism Act, and Pakistan Arms Ordinance. The core legal questions involved the voluntariness and admissibility of judicial and retracted confessions, whether such confessions were sufficiently corroborated by extra-judicial confessions, discovery of the dead body, medical evidence, and weapon recoveries, and the effect of preliminary police investigation before the lodging of the First Information Report. The Sindh High Court held that the judicial confessions were voluntarily and truly made, duly recorded in compliance with statutory requirements, and well-corroborated by circumstantial, medical, and recovery evidence. The Court affirmed the convictions and death sentences, holding that a retracted judicial confession can form the basis of a conviction when supported by independent corroboration, and that a police officer's procedural irregularities in recording an FIR prematurely do not vitiate an otherwise well-proved prosecution case.

  Questions settled

  • Can a retracted judicial confession form the basis of a conviction if it is supported and corroborated by other independent evidence?
  • Whether a confession made by one co-accused in a joint trial can be considered as circumstantial evidence against other co-accused under Article 43 of the Qanun-e-Shahadat Order, 1984?
  • Does a preliminary investigation or a delay in lodging the First Information Report vitiate an otherwise proven prosecution case based on strong independent evidence?
  • Whether minor discrepancies between medical evidence and ocular or confessional accounts are sufficient to discard the entire prosecution case?
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• Ghulam Ali alias Sadoro Versus S.H.O., Police Station Veehar, District Larkana2003 YLR 2168 · Sindh High Court · 2003-02-06Read full judgment →
• Sikandar Ali Versus The State2003 YLR 2160 · Sindh High Court · 2003-02-27
  post-arrest baildelay in recording statementeyewitness testimonyanti-terrorismmurderrobberybenefit of doubt
  Summary & questions settled

  This is a bail application filed by the applicant Sikandar Ali involved in Special Case No. 71 of 2002 before the Anti-Terrorism Court No. III, Sukkur, concerning offences of murder and robbery. The core legal question was whether the unexplained delay of over two months in recording the statement of the injured eyewitness under section 161, Cr.P.C. created sufficient doubt to warrant the grant of post-arrest bail. The court held that the unexplained and unproved delay in recording the statements of witnesses affects their veracity and creates reasonable grounds for further inquiry into the guilt of the accused. Consequently, the court accepted the application and granted post-arrest bail to the applicant subject to furnishing surety, while granting liberty to the prosecution to move for cancellation of bail if an adverse Ballistic Expert Report was subsequently collected. The key principle laid down is that an unexplained delay in recording police statements of eye-witnesses casts doubt on the prosecution case, entitling the accused to the concession of bail.

  Questions settled

  • Does an unexplained delay in recording the statement of an eyewitness under section 161 of the Code of Criminal Procedure 1898 create sufficient doubt to entitle an accused to post-arrest bail?
  • Whether the failure of the police and medical officer to promptly record the statement of an injured witness admitted in the hospital affects the prosecution case at the bail stage?
  • Can bail be granted when the name of the accused does not appear in the initial First Information Report and is implicated after a considerable lapse of time?
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• Beero Versus The State2003 YLR 2154 · Sindh High Court · 2003-01-20
  robberydock identificationidentification paradefootprint evidencerecovery of stolen propertybenefit of doubtcriminal appeal
  Summary & questions settled

  This criminal appeal challenges the judgment of the VI Additional Sessions Judge, Larkana, convicting the appellants under sections 394 and 34 of the Pakistan Penal Code 1860 for robbery. The core legal questions involve the evidentiary value of dock identification where a formal identification parade was not legally proved, the reliability of recoveries not subjected to identification tests or properly connected to the crime, and the evidentiary worth of footprint identification based solely on memory without moulds. The Sindh High Court held that dock identification months after the event without a valid prior identification parade is of no evidentiary value, unproven recoveries of common items and lack of footprint moulds render those pieces of evidence untrustworthy, and the prosecution failed to establish guilt beyond a reasonable doubt. The court laid down the principle that dock identification cannot cure a failed or unproved judicial identification parade, and footprint evidence based on mere memory after a long delay without moulds must be discarded.

  Questions settled

  • What is the evidentiary value of identifying an accused in court (dock identification) when the prior judicial identification parade has not been legally proved?
  • Can the recovery of common articles from an accused's possession serve as corroborative evidence without being subjected to an identification test or properly linked to the complainant?
  • Is footprint identification reliable when the tracker did not prepare moulds at the scene of the crime and attempted to identify footprints from memory after a significant delay?
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• Ebrahim Sobani Versus Naseem Akhtar Soofi2003 YLR 1821 · Sindh High Court · 2001-02-28Read full judgment →
• Sheikh Ghulam Shah Versus K.D.A.2003 YLR 1501 · Sindh High Court · 2002-04-10Read full judgment →
• Abdul Razzak Versus The State2003 YLR 1271 · Sindh High Court · 2002-11-11
  quashment of proceedingsdouble jeopardyautre fois acquitfugitive from justiceforeign proceedingsbanking offencespecial court
  Summary & questions settled

  This judgment disposes of criminal miscellaneous applications seeking the quashment of criminal proceedings arising out of two FIRs registered against the applicants for unauthorized remittance and fraudulent transactions involving funds of the Muslim Commercial Bank. The core legal questions addressed by the court were whether the applicants were protected against double jeopardy under Section 403 of the Code of Criminal Procedure 1898 and Article 13(a) of the Constitution of Pakistan 1973 based on proceedings in Dubai, and whether criminal proceedings should be quashed or stayed due to pending civil litigation and the applicants' status as fugitives from justice. The court held that the observations and orders of a foreign prosecutor in Dubai did not constitute a trial or acquittal by a court of competent jurisdiction under Pakistani law, and thus the doctrine of double jeopardy did not apply. Furthermore, the court held that as fugitives from justice, the applicants were not entitled to discretionary relief or assistance from the court. The petitions for quashment of the proceedings were accordingly dismissed.

  Questions settled

  • Whether an order or observation by a foreign prosecutor dropping penal action constitutes a trial and acquittal by a court of competent jurisdiction for the purposes of invoking double jeopardy under Section 403 of the Code of Criminal Procedure 1898?
  • Does Article 13(a) of the Constitution of Pakistan 1973 afford protection against double jeopardy based on foreign proceedings that were not conducted by a competent court in Pakistan?
  • Can an accused person who is a fugitive from justice maintain an application for the quashment of criminal proceedings or seek discretionary relief from the court?
  • Does the pendency of civil suits on the same subject-matter automatically operate as a bar to the continuation of criminal proceedings?
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• Ahmed Khan Versus Ghulam Ali2003 YLR 1250 · Sindh High Court · 2002-12-27Read full judgment →
• Rashid Hussain Versus The State2003 YLR 1191 · Sindh High Court · 2002-11-27
  post-arrest bailattempted murderprohibitory clausemedical evidenceocular testimonyrecovery of weaponprima facie case
  Summary & questions settled

  This matter concerns a post-arrest bail application filed by the accused, who was charged under Section 324 of the Pakistan Penal Code 1860 for allegedly causing injuries to the complainant with a sharp-cutting weapon. The core legal question was whether the accused was entitled to bail, given the defense's arguments regarding discrepancies in the timing of the incident between the F.I.R. and the medical certificate, and the contention that the injuries did not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898. The Court held that the prosecution had sufficiently explained the timing discrepancies, noting that the injured was moved between hospitals. Furthermore, the Court found that the ocular testimony of the injured, corroborated by the recovery of a blood-stained weapon and shirt, along with the statements of independent witnesses who saw the accused fleeing the scene, established a prima facie case. Consequently, the Court refused bail, reaffirming the principle that where there are reasonable grounds to believe an accused committed a non-bailable offence, bail should not be granted.

  Questions settled

  • Does a discrepancy in the time of the incident between the F.I.R. and the medical report automatically entitle an accused to bail?
  • Is the recovery of a blood-stained weapon and shirt from the accused sufficient to establish a prima facie case at the bail stage?
  • Can bail be refused if the prosecution provides a reasonable explanation for timing discrepancies in the F.I.R.?
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• Muhammad Ismail Versus The State2002 YLR 89 · Sindh High Court · 2002-06-26
  post-arrest bailfurther inquirymurderalibiconflicting statements
  Summary & questions settled

  This is a bail application filed by the applicant Muhammad Ismail in Crime No. 12 of 2001 registered at Police Station Naudero for offences under sections 302, 337-H(2), 148, 149 and 34 of the Pakistan Penal Code 1860. The core legal question involves determining whether the applicant is entitled to post-arrest bail given the conflicting evidence, including a plea of alibi supported by statements under section 164 of the Code of Criminal Procedure 1898 versus direct nomination and role attribution in the F.I.R. The Sindh High Court held that since it was unclear whether the applicant was involved in the incident or attending a wedding at the material time, and whose version of the statements under section 164 of the Code of Criminal Procedure 1898 was correct, the case called for further inquiry. The court laid down the principle that where deep-seated contradictions and rival versions requiring evaluation of evidence exist at the pre-trial stage, the accused makes out a case for further inquiry under section 497(2) of the Code of Criminal Procedure 1898 and is entitled to bail.

  Questions settled

  • Whether post-arrest bail can be granted when the complicity of the accused in the crime requires further inquiry under section 497(2) of the Code of Criminal Procedure 1898?
  • Does a plea of alibi supported by statements under section 164 of the Code of Criminal Procedure 1898 create a case of further inquiry when countered by direct nomination in the F.I.R.?
  • Can bail be granted where multiple co-accused are alleged to have fired and it is difficult at the pre-trial stage to determine whose shot proved fatal?
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• Rafiq Rahim Versus Mrs. Shahida2002 YLR 4002 · Sindh High Court · 2001-11-14Read full judgment →
• Syed Ali Imam Rizvi Versus All Pakistan Textile Mills Association2002 YLR 3946 · Sindh High Court · 2002-01-07Read full judgment →
• Iqbal Hussain Versus Iqbal Masood2002 YLR 3797 · Sindh High Court · 2002-01-10Read full judgment →
• Shafi Muhammad Versus The State2002 YLR 3672 · Sindh High Court · 2002-05-07
  pre-arrest bailvicarious liabilitymurderconspiracydelay in FIRfurther inquiry
  Summary & questions settled

  This application for pre-arrest bail was filed by the applicant, who was implicated under Sections 302, 504, and 34 of the Pakistan Penal Code 1860. The prosecution alleged that the applicant, being the brother-in-law of the principal accused, drove the principal accused to the vicinity of the crime scene in his car and directed him to complete his task, after which the principal accused shot and killed the deceased. The applicant contended that he was falsely implicated due to familial enmity, did not enter the deceased's house, was unarmed, and was initially placed in column No. 2 of the challan. The High Court of Sindh observed that the applicant was unarmed, did not enter the house, and had no overt act attributed to him other than conspiracy. Furthermore, the delay of five hours in lodging the First Information Report left room for deliberation, and the applicability of vicarious liability under Section 34 of the Pakistan Penal Code 1860 remained a matter for trial. Consequently, the Court confirmed the interim pre-arrest bail.

  Questions settled

  • Whether pre-arrest bail can be confirmed where the accused is only charged with conspiracy and driving the principal accused to the scene, without carrying any weapon or committing an overt act?
  • Can vicarious liability under Section 34 of the Pakistan Penal Code 1860 be assumed at the bail stage without positive proof of common intention?
  • Does an unexplained delay of five hours in lodging a First Information Report, combined with familial enmity, justify the grant of pre-arrest bail due to the possibility of false involvement?
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• Sukhio Versus The State2002 YLR 3663 · Sindh High Court · 2002-08-01
  pre-arrest bailanticipatory bailmala fidemurdercriminal procedureFIRevidentiary conflict
  Summary & questions settled

  This matter concerns an application for pre-arrest bail in a case registered under Section 302/34 of the Pakistan Penal Code 1860, following the murder of the complainant's cousin. The core legal question was whether the applicant was entitled to anticipatory bail given the allegations of mala fide, the vague nature of the FIR, and the inconsistency regarding the number of accused persons versus the single injury sustained by the deceased. The Court held that the prosecution's case suffered from significant evidentiary conflicts and appeared to be an afterthought, rendering the applicant's involvement doubtful. Consequently, the Court granted the application for pre-arrest bail. The key principle laid down is that the object of pre-arrest bail is to protect innocent individuals from unnecessary harassment in motivated cases, and the mere mention of an accused's name in an FIR is insufficient to deny bail without a thorough consideration of the surrounding circumstances, including potential mala fides and the lack of cogent material supporting the prosecution's version.

  Questions settled

  • Is the mere mention of an accused's name in an FIR sufficient to deny pre-arrest bail?
  • What is the primary objective of granting pre-arrest bail in criminal cases?
  • Can conflicting versions of prosecution witnesses justify the grant of pre-arrest bail?
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• Muhammad Aslam Versus The State2002 YLR 3591 · Sindh High Court · 2002-04-02
  pre-arrest bailpolice guardtheftdiscretionary reliefcustodial interrogationmala fides
  Summary & questions settled

  This matter concerns an application for pre-arrest bail filed by a police guard accused of theft at the residence of a Judge of the Accountability Court, where he was assigned security duties. The core legal question was whether the applicant was entitled to pre-arrest bail despite the serious nature of the allegations and his subsequent unexplained absence from duty. The Court dismissed the application, holding that pre-arrest bail is an extraordinary discretionary remedy reserved for cases where arrest is motivated by mala fides or harassment. The Court reasoned that the applicant, entrusted with the protection of property, had allegedly betrayed that trust, and his custodial interrogation was necessary for the recovery of stolen cash and jewellery. The key principle laid down is that while the offence may not fall within the prohibitory clause of the Code of Criminal Procedure, 1898, the court must consider the exceptional nature of the case, the necessity of investigation, and the potential for the applicant to hamper the recovery of stolen property when exercising its discretion to grant pre-arrest bail.

  Questions settled

  • Is pre-arrest bail a matter of right even when the offence does not fall within the prohibitory clause of Section 497(1) of the Code of Criminal Procedure 1898?
  • Should pre-arrest bail be granted when the applicant's custodial interrogation is required for the recovery of stolen property?
  • Does the betrayal of trust by a security official in a theft case constitute an exceptional circumstance justifying the refusal of pre-arrest bail?
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• Muhammad Shahid Versus The State2002 YLR 3462 · Sindh High Court · 2002-05-22
  superdaginamainterim custody of propertyrobbed propertycriminal revisiondiscretionary powercase property
  Summary & questions settled

  This criminal revision application challenges an order passed by the IInd Additional Sessions Judge, Karachi South, which dismissed an application filed under Section 516-A of the Code of Criminal Procedure 1898 for the interim custody (superdaginama) of property allegedly robbed from the applicant's residence. The core legal question was whether the trial court correctly exercised its discretion in refusing to return the recovered property to the complainant while the trial was pending. The High Court observed that the applicant was the rightful owner of the property, which had been recovered from the accused, and noted the significant delay in the trial proceedings. Given the State's concession and the applicant's undertaking to produce the articles whenever required by the trial court, the High Court set aside the impugned order. The court held that in circumstances where the ownership is not disputed and the State offers no objection, the trial court should exercise its discretion to release the case property on superdaginama to the rightful owner, subject to conditions ensuring its production during trial.

  Questions settled

  • Can a trial court release robbed property to the complainant on superdaginama during the pendency of a trial?
  • What factors should a court consider when deciding an application for the return of case property under Section 516-A of the Code of Criminal Procedure 1898?
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• Manzoor Versus The State2002 YLR 3451 · Sindh High Court · 2002-06-06
  post-arrest bailprohibitory clausecriminal liabilityhatchet injuriesbail discretionstatutory bailrole of complainant
  Summary & questions settled

  This matter concerns a post-arrest bail application filed by applicants charged with offences under sections 302, 324, 114, 147, 148, and 149 of the Pakistan Penal Code 1860. The core legal question was whether the applicants, who were alleged to be armed with hatchets and caused injuries that did not fall within the prohibitory clause of section 497 of the Code of Criminal Procedure 1898, were entitled to bail. The court held that since the injuries sustained by the victims, as per the medical report, did not attract the prohibitory clause—as the potential sentence for such offences would be less than ten years—the applicants were entitled to the grant of bail. The court emphasized that bail is generally a right and a matter of liberty, to be refused only in cases involving hardened or desperate criminals or where there is a risk of tampering with evidence. It further noted that the role of the complainant, while recognized, must not overshadow the state's primary role in criminal prosecution to ensure neutrality.

  Questions settled

  • Does the infliction of injuries not falling under the prohibitory clause of section 497, Code of Criminal Procedure 1898 entitle an accused to bail?
  • Should bail be refused to an accused who is not a hardened or desperate criminal?
  • Does the participation of a complainant in criminal proceedings risk compromising the neutrality of the prosecution?
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• Liaqat Ali Versus The State2002 YLR 3421 · Sindh High Court · 2002-05-06
  post-arrest bailmedical certificate contradictionfurther inquiryconflict in medical evidenceattempt to murdercriminal procedure
  Summary & questions settled

  This is a post-arrest bail application filed by the applicant, Liaqat Ali, in Crime No. 71 of 2001 registered under sections 324, 147, 148, and 114 of the Pakistan Penal Code 1860 at Police Station Gambat. The core legal question revolves around whether the applicant has made out a case for further inquiry under the criminal procedure due to glaring contradictions between the initial medical certificate, subsequent medical certificates, and the radiologist's report regarding the injuries sustained by the injured party. The Sindh High Court held that the significant variance and discrepancies in the medical evidence—specifically the unexplained issuance of a subsequent medical certificate detailing multiple injuries after an initial certificate showed only a head injury and the radiologist found no bony lesions—rendered the prosecution's case doubtful at the bail stage. The court laid down the principle that material contradictions in medical evidence concerning the nature and attribution of injuries create a case of further inquiry under section 497(2) of the Code of Criminal Procedure 1898, entitling the accused to post-arrest bail.

  Questions settled

  • Does a material contradiction between the initial medical certificate and subsequent medical reports create a case for further inquiry under the Code of Criminal Procedure 1898?
  • Whether post-arrest bail can be granted when the weapon attributed to the accused in the FIR conflicts with the nature of injuries described in the medical evidence?
  • Can discrepancies in the medical officer's recording of injuries be ground for granting bail to an accused charged with attempt to murder?
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• Sahib Ali Versus Pakistan Steel Mills Corportation2002 YLR 2653 · Sindh High Court · 2002-08-16Read full judgment →
• Abdul Sattar Versus The State2002 YLR 1773 · Sindh High Court · 2002-08-13
  post-arrest bailheroin smugglingnarcotics traffickingorganizer and financierfurther inquiryprohibitory clause
  Summary & questions settled

  This is a criminal bail application arising from a narcotics case where the applicant, Abdul Sattar, was implicated in organizing and managing the smuggling of 2.3 kilograms of heroin powder through a carrier, Abdul Hakeem, who attempted to board a flight to Jeddah. The core legal question was whether the applicant was entitled to post-arrest bail given the circumstantial evidence connecting him to the arrangement of the carrier's passport and air ticket, and whether the case warranted further inquiry under the Code of Criminal Procedure. The Sindh High Court held that the statement of a witness prima facie connected the applicant to the offense of organizing and financing drug trafficking under the Control of Narcotic Substances Act, 1997, and that no grounds for further inquiry were made out. The court dismissed the bail application, laying down the principle that organizers, managers, and financiers of drug trafficking who utilize carriers fall squarely within the prohibitory clauses of the narcotics laws and are not entitled to bail.

  Questions settled

  • Whether an accused alleged to have arranged travel documents and tickets for a drug carrier can be granted post-arrest bail for an offense under Section 9(c) of the Control of Narcotic Substances Act, 1997?
  • What constitutes reasonable grounds for further inquiry under Section 497(2) of the Code of Criminal Procedure, 1898 in narcotics cases?
  • Are organizers, managers, and financiers of drug trafficking liable under the Control of Narcotic Substances Act, 1997 even if they were not caught carrying the drugs personally?
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• Gul Muhammad Versus State2001 YLR 989 · Sindh High CourtRead full judgment →
• Muhammad Aslam Versus Deputy Commissioner, Larkana2001 YLR 891 · Sindh High Court · 2001-05-10Read full judgment →
• Muhammad Younus Versus State2001 YLR 852 · Sindh High Court · 2001-06-01
  bail cancellationcriminal revisionjudicial discretionmisuse of bailabsence of accused
  Summary & questions settled

  This criminal revision application challenges an order passed by the Special Court (CNS), Karachi, which cancelled the bail of the accused, Muhammad Younus, due to his absence on a single date of hearing. The core legal question was whether the cancellation of bail is justified solely on the basis of a single absence, particularly when the accused had not previously misused the concession of bail since its grant in 1997. The High Court held that cancelling bail for a single day's absence, especially where there is no history of misuse or abscondence, is an excessively harsh and improper exercise of judicial discretion. The Court emphasized that bail cancellation should not be punitive or automatic based on a single procedural lapse. Consequently, the High Court set aside the trial court's order, allowing the revision application and restoring the accused to his previous bail status under the same terms and conditions.

  Questions settled

  • Is the cancellation of bail justified solely on the basis of an accused's absence on a single date of hearing?
  • Does a lack of prior misuse of bail concessions influence the court's decision on a bail cancellation application?
  • Can an order cancelling bail be set aside if it is found to be harsh and improper?
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• Gul Muhammad Mir Bahar Versus N.L.C.2001 YLR 837 · Sindh High Court · 2000-12-18Read full judgment →
• Ghulam Abbas Versus State2001 YLR 801 · Sindh High Court · 2001-05-24
  pre-arrest bailbail dismissalShajjah-e-Madihahcriminal trialhatchet blowprohibitory clause
  Summary & questions settled

  This is a criminal bail application wherein the applicant/accused sought pre-arrest bail in a case arising out of F.I.R. No. 54 of 2000 registered at Police Station Sobhodero, under sections 337-A(i)-(ii), 34, and 504 of the Pakistan Penal Code 1860. The core legal question revolves around whether the applicant is entitled to pre-arrest bail when he is specifically nominated in the F.I.R., has been assigned the specific role of causing a hatchet blow to a vital part of the injured person's body resulting in an injury certified as Shajjah-e-Madihah, and where a motive has been duly disclosed. The court held that the applicant is not entitled to pre-arrest bail simply because the offences charged do not fall within the prohibitory clause of section 497 of the Code of Criminal Procedure 1898, as considerations for pre-arrest bail differ and sufficient prima facie material connects the accused to the crime. The interim pre-arrest bail was consequently recalled and the application dismissed.

  Questions settled

  • Whether an accused nominated in the F.I.R. with a specific role of causing a hatchet injury to a vital part of the body is entitled to pre-arrest bail?
  • Does the mere fact that an offence does not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898 entitle an accused to pre-arrest bail in every case?
  • What are the differentiating considerations for the grant of bail before arrest versus bail after arrest?
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• Ali Nawaz Versus State2001 YLR 774 · Sindh High Court · 2001-05-31
  post-arrest bailstatutory delayconfession before policepointationfurther inquirydelayed FIR
  Summary & questions settled

  This criminal bail application arises from a criminal case registered after an inordinate delay of two years, wherein the applicant was accused of double murder under circumstantial and confessional allegations. The core legal questions pertained to the admissibility of a police confession under the Qanun-e-Shahadat Order, 1984, the evidentiary value of a pointation under Article 40 of the same, and whether prolonged incarceration exceeding three years without trial warrants the grant of bail on the ground of statutory delay. The Sindh High Court held that while the admissibility of the pointation is a matter for trial, the continuous detention of the accused for nearly three years and eight months without commencement of trial or framing of charge constitutes a strong ground for bail under the third proviso to section 497(1) of the Code of Criminal Procedure, 1898, especially given the State's concession. The court laid down the principle that indefinite incarceration without trial violates the spirit of fair dispensation of justice and attracts statutory delay provisions for bail.

  Questions settled

  • Whether a confession made before the police is admissible in evidence against an accused?
  • Does incarceration for a period of three years and eight months without trial entitle an accused to post-arrest bail on the ground of statutory delay?
  • Whether pointation of a place already known to the police falls within the scope of Article 40 of the Qanun-e-Shahadat Order, 1984?
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• Haq Nawaz Versus State2001 YLR 634 · Sindh High Court · 2001-04-30
  post-arrest bailovert actfurther inquirycriminal procedurecommon intentionbail application
  Summary & questions settled

  This is a criminal bail application filed before the Sindh High Court by the applicant Haq Nawaz, seeking post-arrest bail in Crime No. 142 of 2000 registered at Police Station Shahdadkot under various provisions including section 334 of the Q.D Ordinance and sections 504, 147, 148, and 114 of the Pakistan Penal Code 1860. The core legal question was whether the applicant was entitled to bail where he was merely alleged to have caught hold of the injured person by the arm without any active overt act, and co-accused had been placed in column No. 2 of the challan. The Court held that since no overt act was attributed to the applicant and his case fell within the purview of further inquiry under section 497(2) of the Code of Criminal Procedure 1898, a prima facie case for bail was made out. The key principle laid down is that an accused assigned a role of merely catching hold of an injured person without any further overt act, alongside uncertainty regarding co-accused, is entitled to post-arrest bail under subsection (2) of section 497 of the Code of Criminal Procedure 1898.

  Questions settled

  • Is an accused entitled to post-arrest bail when only assigned the role of catching hold of the injured person without any active overt act?
  • Does the placing of co-accused in column No. 2 of the challan create a case of further inquiry under section 497(2) of the Code of Criminal Procedure 1898 for remaining co-accused?
  • Whether bail should be granted when the prosecution's case suffers from uncertainty regarding the role and involvement of the majority of accused persons named in the first information report?
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• Hazar Khan Versus State2001 YLR 631 · Sindh High Court · 2001-04-27
  post-arrest bailidentification paradenighttime incidentpolice encountercriminal jurisprudencebail application
  Summary & questions settled

  This bail application arises from Crime No. 103 of 2000 registered at Police Station Buxapur, District Jacobabad, for an alleged incident involving firing at a police patrol in the middle of the night. The Additional Sessions Judge, Kashmore, had previously rejected the applicant's bail petition. The core legal question before the Sindh High Court was whether the identification of the accused by police witnesses under suspicious and difficult conditions—namely, pitch darkness at midnight with only vehicle headlights as illumination—was prima facie reliable enough to warrant withholding post-arrest bail. The High Court held that the identification of the accused after a delay of one month under such circumstances was highly doubtful, as human instinct for survival during cross-firing would preclude focused observation. Consequently, the court confirmed the bail granted earlier to the applicant. The key principle laid down is that while heinous crimes must be dealt with strictly, courts of law must apply statutory principles alongside common sense and reasoning in the prima facie appreciation of evidence when deciding bail matters.

  Questions settled

  • Whether post-arrest bail should be granted when the identification of the accused by police witnesses is shrouded in doubt due to nighttime conditions and delayed identification?
  • Does the appreciation of evidence at the bail stage permit evaluating the plausibility of police identification under pitch dark conditions?
  • Whether the gravity of an offense alone is sufficient to deny bail when the prosecution's case suffers from prima facie improbability?
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• Ghulam Qadir Versus State2001 YLR 623 · Sindh High Court · 2001-02-20
  post-arrest baildacoityabsconsionHudood Ordinanceco-accused acquittalstatement under section 161 Cr.P.C.statement under section 164 Cr.P.C.
  Summary & questions settled

  This criminal bail application arises out of an FIR registered under sections 17/2 and 3 of the Offences Against Property (Enforcement of Hudood) Ordinance, 1979 and sections 148, 149 and 427 of the Pakistan Penal Code 1860, concerning dacoity and assault at a petrol pump. The core legal question was whether the applicant was entitled to post-arrest bail on the grounds of acquittal of co-accused, affidavits of exoneration, and subsequent retraction of statements by witnesses, despite the applicant's prior absconsion and implication under sections 161 and 164 of the Code of Criminal Procedure 1898. The Sindh High Court dismissed the bail application, holding that the applicant's case was distinguishable from the acquitted and bailed co-accused as the evidence implicated him through statements under sections 161 and 164 Cr.P.C. and he had remained a fugitive from law. The court laid down that absconsion and specific incriminating statements under sections 161 and 164 Cr.P.C. disentitle an accused to post-arrest bail notwithstanding subsequent compromises or acquittals of co-accused on different footings.

  Questions settled

  • Whether an accused is entitled to post-arrest bail merely because co-accused facing the same charge have been acquitted or granted bail?
  • Does the absconsion of an accused during trial disentitle them to the grant of post-arrest bail?
  • Can statements recorded under sections 161 and 164 of the Code of Criminal Procedure 1898 form a valid basis for refusing post-arrest bail?
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• Muhammad Anwar Versus State2001 YLR 611 · Sindh High Court · 2001-05-16
  post-arrest baildelay in trialnarcotics casecharasstatutory custody
  Summary & questions settled

  This is a criminal bail application filed by the applicant Muhammad Anwar seeking post-arrest bail in a narcotics case involving a large quantity of charas registered at Police Station ANF-1, Karachi. The core legal question revolves around whether the accused is entitled to bail on the statutory and factual grounds of excessive and undue delay in the conclusion of the trial, particularly when he has been in continuous custody for over two years and the trial court failed to examine any witnesses despite explicit directions from the High Court. The Sindh High Court allowed the bail application, holding that the prolonged incarceration without material progress in the trial, coupled with precedent regarding delay in conclusion of trials, warranted the grant of bail. The key principle laid down is that protracted and unjustified delay in the conclusion of trial constitutes a sufficient ground for granting post-arrest bail, even in heinous narcotics offenses.

  Questions settled

  • Whether prolonged and unjustified delay in the conclusion of a trial constitutes a sufficient ground for granting post-arrest bail in a narcotics case?
  • Does the failure of the trial court to conclude the trial within the timeframe directed by the High Court entitle an accused to bail?
  • Can bail be granted in cases involving large quantities of narcotics on the ground of protracted detention?
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• P(Isar Ahmed Versus State2001 YLR 551 · Sindh High Court · 2001-05-02
  surety bondforfeiture of bondabscondence of accusedcriminal revisionbailsurety liability
  Summary & questions settled

  These Criminal Revision Applications were filed by a surety challenging the forfeiture of surety bonds following the abscondence of the accused. The core legal question was whether a surety, having failed to produce the accused despite being granted opportunities by the trial court, is entitled to leniency regarding the penalty imposed under the forfeiture of the bond. The court held that bail constitutes a transfer of custody to the surety, who bears the responsibility for the accused's presence. Consequently, where a surety fails to fulfill this obligation despite being afforded sufficient opportunity to produce the accused, the forfeiture of the bond is justified. The court affirmed that the surety is liable for the penalty prescribed by law and dismissed the applications, directing the surety to deposit the full amount of the bond within two months, failing which the trial court would proceed in accordance with the law.

  Questions settled

  • Is a surety liable for the full amount of a bond if they fail to produce the accused in court?
  • Does a court have the discretion to grant leniency to a surety who fails to produce an absconding accused?
  • What is the legal nature of the relationship between an accused, the court, and a surety?
  Read full judgment →
• 2001 Ylr 3412001 YLR 341 · Sindh High Court · 2001-07-02
  post-arrest bailineffective firingvicarious liabilitymurderfurther inquirycriminal procedure
  Summary & questions settled

  The present applicant sought post-arrest bail in Crime No. 10 of 2000 registered at Police Station Johi under sections 302 and 324 of the Pakistan Penal Code. The core legal question was whether an accused person to whom only ineffective firing is attributed, while fatal shots are attributed to an absconding co-accused, is entitled to bail pending trial when the question of vicarious liability requires further inquiry. The Sindh High Court held that since the applicant was only attributed with ineffective firing and no injuries were caused by him, his case called for further inquiry into his vicarious liability, which is to be adjudged by the Trial Court. Consequently, the court granted post-arrest bail to the applicant subject to furnishing security, laying down the principle that bail may be granted where an accused is assigned the role of ineffective firing and the determination of constructive or vicarious liability is deferred to the trial stage.

  Questions settled

  • Is an accused person entitled to bail when only ineffective firing is attributed to them and fatal shots are assigned to an absconding co-accused?
  • Whether the question of vicarious liability of an accused who allegedly made ineffective firing can be determined at the bail stage or at the trial?
  Read full judgment →
• All Muhammad Versus State2001 YLR 3313 · Sindh High Court · 2001-07-13Read full judgment →
• Zafarullah Janjua Versus Jehan Ara2001 YLR 3176 · Sindh High Court · 2000-12-12Read full judgment →
• Wahid Bux Versus State2001 YLR 2958 · Sindh High Court · 2001-07-03
  narcoticsbenefit of doubtjoint trial under different statuteschemical examiner delaycompetency of investigating officerproduction of case property
  Summary & questions settled

  This criminal appeal challenges the judgment of the Special Judge, Control of Narcotic Substances, Dadu, convicting the appellant under Articles 3 and 4 of the Prohibition (Enforcement of Hadd) Order 1979 and Section 9(b) of the Control of Narcotic Substances Act 1997. The case arose from the alleged recovery of 570 grams of Charas from the appellant in a train compartment. The primary legal questions concerned the validity of framing charges under two distinct statutes simultaneously, the competence of an Assistant Sub-Inspector under Section 21 of the Control of Narcotic Substances Act 1997 to take cognizance, and the impact of evidentiary deficiencies such as unexplained delay in chemical analysis, lack of independent recovery witnesses, and non-production of case property during Section 342 Cr.P.C. examination. The High Court held that trying the accused simultaneously under two distinct statutes without clear application of judicial mind vitiated the trial. Furthermore, unexplained delay in sending the contraband to the chemical examiner and failure to produce case property during examination created reasonable doubt. Granting the benefit of doubt as a matter of right, the Court set aside the conviction and sentence.

  Questions settled

  • Does charging and trying an accused under two different statutes without clear application of judicial mind vitiate the trial?
  • Is an Assistant Sub-Inspector competent to take cognizance under Section 21 of the Control of Narcotic Substances Act 1997?
  • Does an unexplained delay in sending recovered narcotics to the chemical examiner entitle the accused to the benefit of doubt?
  • What is the effect of failing to produce the case property before the court and show it to the accused during examination under Section 342 Cr.P.C.?
  Read full judgment →
• Muhammad Aslam Versus State2001 YLR 293 · Sindh High Court · 2001-04-11
  post-arrest bailidentification paradedelay in trialfurther inquirydacoity
  Summary & questions settled

  The applicant sought post-arrest bail in Crime No. 247 of 1999 registered under Section 395/34 of the Pakistan Penal Code at Police Station Korangi Industrial Area. The core legal question concerned whether the applicant was entitled to bail given the delayed identification parade and lack of specific role attribution. The Sindh High Court held that the identification parade held after a delay of sixteen days without explanation and without ascribing a specific role to the accused lost its sanctity, making the case one of further inquiry under Section 497(2) of the Code of Criminal Procedure 1898. Furthermore, considering the prolonged incarceration without the applicant being at fault for trial delays, bail was granted. The key principle laid down is that unexplained delay in holding an identification parade coupled with the absence of specific role attribution weakens the prosecution's case, justifying the grant of post-arrest bail on the principle of further inquiry.

  Questions settled

  • Does an unexplained delay in holding an identification parade affect its sanctity?
  • Whether failure to ascribe a specific role to an accused during an identification parade makes the case one for further inquiry?
  • Is an accused entitled to post-arrest bail when prolonged incarceration occurs without fault on their part and the trial is delayed?
  Read full judgment →
• Piral Alias Peero Versus The State2001 YLR 2881 · Sindh High Court
  post-arrest bailstatutory delaySection 497 Cr.P.C.hardened and desperate criminalscontinuous incarcerationpendency of other caseskidnapping for ransom
  Summary & questions settled

  This order resolves two bail applications arising from an FIR registered under Section 365-A/34 of the Pakistan Penal Code 1860. The applicants sought bail on the ground of statutory delay, having remained continuously incarcerated for over two years without a single prosecution witness being examined, while the delay was not attributable to them. The trial court had refused bail under the fourth proviso to Section 497(1) of the Code of Criminal Procedure 1898 on the ground that the applicants were hardened and desperate criminals, relying on a police report indicating their involvement in another case. The High Court observed that release on bail under the third proviso to Section 497(1) is a statutory right, not a matter of court discretion, and can only be denied if delay is occasioned by the accused or if objective material proves they are hardened, desperate, or dangerous criminals. Finding neither previous convictions nor a criminal history, the Court held that mere pendency of another case cannot justify indefinite incarceration. The bail applications were accordingly granted.

  Questions settled

  • Is the grant of bail on the ground of statutory delay under the third proviso to Section 497(1) of the Code of Criminal Procedure 1898 a statutory right or a discretionary matter?
  • Can the mere pendency of another criminal case be sufficient ground to treat an accused as a hardened and desperate criminal under the fourth proviso to Section 497(1) of the Code of Criminal Procedure 1898?
  • Under what circumstances can a court form an opinion that an accused is a hardened, desperate, or dangerous criminal to refuse bail under the fourth proviso to Section 497(1) of the Code of Criminal Procedure 1898?
  Read full judgment →
• Muhammad Ali Versus State2001 YLR 2843 · Sindh High Court
  post-arrest bailOffences of Zinaabductionfree-will marriageNikahnamadelay in F.I.R.
  Summary & questions settled

  This matter arises from a bail application filed by the applicants booked under sections 11 and 10 of the Offences of Zina (Enforcement of Hudood) Ordinance, 1979 after their bail was refused by the trial court. The core legal question is whether the applicants are entitled to post-arrest bail in view of the unexplained delay in lodging the F.I.R., the statement and affidavit of the abductee absolving the applicant and stating she contracted a free-will marriage, and the absence of any allegation of Zina. The Sindh High Court held that the case prima facie falls within the prohibitory clause of section 497, Code of Criminal Procedure 1898, noting that the abductee appeared to be a consenting party and had married the applicant. The court laid down the principle that where an abductee's statement and affidavit show free-will marriage and no coercion, and there is unexplained delay in the F.I.R., the accused makes out a case for further inquiry warranting the grant of post-arrest bail.

  Questions settled

  • Whether post-arrest bail can be granted when the abductee states in her statement under section 164 Cr.P.C. and affidavit that she contracted a free-will marriage with the accused?
  • Does an unexplained delay of four days in lodging the F.I.R. provide grounds for granting bail in an abduction case?
  • Whether the case falls within the ambit of section 497, Part II, Code of Criminal Procedure 1898 when the prosecution evidence shows the abductee to be a consenting party?
  Read full judgment →
• Noor Muhammad Versus State2001 YLR 2826 · Sindh High Court · 2001-04-12
  judicial confessioncircumstantial evidenceQatl-shibh-i-amdrobberycriminal appealdeath sentence confirmationappreciation of evidence
  Summary & questions settled

  This criminal appeal challenges a conviction for murder and robbery, where the appellant was sentenced to death by an Anti-Terrorism Court. The core legal question was whether the appellant's judicial confession, coupled with circumstantial evidence, was sufficient to sustain a conviction for Qatl-e-Amd (intentional murder) or if the evidence supported a lesser charge. The Court held that while the judicial confession was voluntary and reliable, it did not establish the intent required for Qatl-e-Amd. Instead, the Court found the evidence established an offence of Qatl-shibh-i-amd (unintentional homicide) under Section 316, Pakistan Penal Code 1860. The key principle laid down is that a judicial confession must be accepted or rejected in its entirety in the absence of other direct evidence, and that where an accused causes death during the commission of a theft without the specific intent to kill, the offence falls under Section 316 rather than Qatl-e-Amd. Consequently, the death sentence was set aside, and the appellant was sentenced to 14 years of rigorous imprisonment.

  Questions settled

  • Can a judicial confession be accepted in part and rejected in part by the court?
  • Does the act of causing death during a theft without specific intent to kill constitute Qatl-e-Amd or Qatl-shibh-i-amd?
  • What is the distinction between theft and robbery under the Pakistan Penal Code 1860?
  • Is a judicial confession admissible if the accused alleges police maltreatment during the investigation?
  Read full judgment →
• Falaknaz Builders Versus Karachi Building Control Authority2001 YLR 2542 · Sindh High Court · 2000-05-20Read full judgment →
• Abdul Sattar Versus State2001 YLR 2445 · Sindh High Court · 2001-03-22
  criminal appealconviction for minor offenceillegal convictioncharge framingbenefit of doubtcriminal intimidation
  Summary & questions settled

  This criminal appeal challenges the judgment of the IInd Additional Sessions Judge, Nawabshah, which convicted the appellants under Section 506(2) of the Pakistan Penal Code 1860, despite the appellants having been originally charged with more serious offences under Sections 307 and 34 of the Pakistan Penal Code 1860, Section 324 of the Qisas and Diyat Ordinance, and Section 13-D of the Arms Ordinance. The core legal question was whether a trial court can legally convict an accused for a minor offence when the charge framed against them was exclusively for major offences that did not necessarily constitute notice of the minor offence. The High Court held that the conviction was illegal and void, as the prosecution failed to prove the major charges and the trial court erred in convicting the appellants for a distinct minor offence without proper notice. The court set aside the conviction and sentence, emphasizing that a conviction for a minor offence is legally unsustainable where the charge for the major offence does not inherently provide notice of the minor offence.

  Questions settled

  • Can a trial court legally convict an accused for a minor offence when the charge framed was exclusively for major offences?
  • Is a conviction for a minor offence sustainable if the charge for the major offence does not provide notice of the minor offence?
  • Does the absence of injury to the complainant in a shooting incident negate the intent required for attempted murder charges?
  Read full judgment →
• Talib Hussain Versus State2001 YLR 2423 · Sindh High Court · 2001-06-12
  murderbenefit of doubtdelayed FIReyewitness credibilitycircumstantial evidenceweapon recoveryperjurycriminal appeal
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of life imprisonment awarded to the appellant, Talib Hussain, by the trial court under Section 302 of the Pakistan Penal Code 1860 for the murder of Mumtaz Ali. The core legal questions involved the credibility of delayed eyewitness testimony, the reliability of circumstantial and recovery evidence, and whether a conviction can be sustained on evidence identical to that which resulted in the acquittal of a co-accused. The Sindh High Court held that the prosecution miserably failed to establish the charge beyond a reasonable doubt, noting that the alleged eyewitnesses were not present at the scene, their statements under Section 161 of the Code of Criminal Procedure 1898 were recorded after an unexplained delay of eleven days, the recovery of the weapon was highly doubtful with the recovery witness having been proceeded against for perjury under Section 193 of the Pakistan Penal Code 1860, and the co-accused had already been acquitted on the same evidence. The court laid down the principle that to sustain a conviction on a capital charge, the prosecution must produce high-quality, trustworthy, and confidence-inspiring evidence free from material contradictions, and that benefit of doubt must be extended where ocular and circumstantial evidence is fabricated and unreliable.

  Questions settled

  • Whether a conviction for murder can be sustained when the testimony of alleged eyewitnesses is recorded after an unexplained delay and their presence at the crime scene is proven doubtful?
  • Can an accused be convicted on evidence identical to that upon which a co-accused has already been acquitted by the trial court?
  • Is a recovery of an incriminating weapon reliable when the mashir of recovery admits the accused was in prior custody and is subjected to perjury proceedings by the court?
  • What is the standard of proof required from the prosecution to maintain a capital conviction in criminal cases?
  Read full judgment →
• Abdul Majeed Versus State2001 YLR 2128 · Sindh High Court · 2001-07-13
  death sentencedefective chargeSection 342 statementprocedural irregularityremandcriminal appealmandatory provisions
  Summary & questions settled

  This criminal appeal challenges a conviction and death sentence imposed by the Sessions Judge for murder. The appellant contended that the trial was fundamentally flawed due to procedural irregularities. Specifically, the court addressed whether the framing of a charge under Section 302, Pakistan Penal Code 1860, without specifying the applicable subsection (a, b, or c), prejudiced the accused's right to be informed of the precise allegations. Furthermore, the court examined whether the failure to comply with the mandatory requirements of Section 364(2), Code of Criminal Procedure 1898—specifically the absence of the accused's signature on the statement recorded under Section 342, Code of Criminal Procedure 1898, and the failure of the presiding officer to write the required certificate in their own handwriting—constituted a curable irregularity. The court held that these procedural lapses were fatal to the conviction, as they violated mandatory statutory provisions. Consequently, the court set aside the conviction and sentence, rejected the death reference, and remanded the case to the trial court to restart proceedings from the stage of framing the charge and recording the accused's statement.

  Questions settled

  • Does a failure to specify the subsection of Section 302, Pakistan Penal Code 1860, in a charge sheet render the charge defective?
  • Is the failure to obtain the accused's signature on a statement recorded under Section 342, Code of Criminal Procedure 1898, a curable irregularity?
  • Does the failure of a presiding officer to write the certificate required by Section 364(2), Code of Criminal Procedure 1898, in their own handwriting vitiate the trial?
  Read full judgment →
• Hazoor Bakhsh Versus State2001 YLR 2089 · Sindh High Court · 2001-06-22
  post-arrest bailmurderprinciple of consistencybenefit of doubtfurther inquiryidentification parade
  Summary & questions settled

  This matter concerns a bail application filed by an accused, Hazoor Bux, facing trial for murder. The core legal question is whether the accused is entitled to post-arrest bail based on the principle of consistency and the benefit of doubt at the bail stage, particularly where the accused was not named in the initial FIR, witness statements were recorded with significant delay, and co-accused persons facing similar allegations had already been granted bail. The Court held that the prosecution's case against the applicant was weakened by the absence of his name in the FIR, the lack of specific overt acts attributed to him, and the unexplained delay in recording the statements of prosecution witnesses. Furthermore, the Court observed that the applicant's case was on par with co-accused who had already been granted bail. Consequently, the Court granted bail, establishing the principle that where the prosecution's case against an accused is not distinguishable from that of co-accused already released on bail, and where significant evidentiary gaps exist, the case warrants further inquiry, entitling the accused to the benefit of doubt at the bail stage.

  Questions settled

  • Whether an accused is entitled to bail on the principle of consistency when co-accused facing similar allegations have already been granted bail?
  • Does a delay in recording the statements of prosecution witnesses provide sufficient grounds to grant bail to an accused?
  • Is an accused entitled to bail when the FIR does not name them and there is no specific overt act attributed to them?
  Read full judgment →
• Ghulam Rasool Versus State2001 YLR 208 · Sindh High Court · 2001-04-24
  post-arrest bailstatutory delaydelay in conclusion of trialpolice negligencemandatory bailcriminal procedure
  Summary & questions settled

  This is a criminal bail application filed before the Sindh High Court by an accused person facing trial under section 302/324 of the Pakistan Penal Code 1860 in F.I.R. No. 85/98. The core legal question concerns whether the applicant is entitled to the concession of post-arrest bail on the ground of statutory delay under the third proviso to section 497(1) of the Code of Criminal Procedure 1898, given that he remained in continuous custody for over two years without a challan or charge-sheet being submitted, and the delay was not attributable to him. The High Court held that the right of an accused to be enlarged on bail under the third proviso to section 497(1) of the Code of Criminal Procedure 1898 is a mandatory statutory right that cannot be denied through the discretionary powers of the court. The court laid down the principle that where an accused person has suffered prolonged incarceration exceeding the statutory period without any fault or delay on their part due to the negligence of investigating authorities in submitting a timely charge-sheet, they are entitled to the grant of bail as a matter of right.

  Questions settled

  • Is the right to be released on bail under the third proviso to section 497(1) of the Code of Criminal Procedure 1898 mandatory or discretionary?
  • Does an accused become entitled to statutory bail when the delay in the conclusion of the trial or submission of the challan is not attributable to him?
  • Can an accused be denied statutory bail under section 497 of the Code of Criminal Procedure 1898 due to the negligence of the investigating officer in filing a timely charge-sheet?
  Read full judgment →
• Talib Hussain Versus State2001 YLR 1900 · Sindh High Court · 2001-04-03
  post-arrest bailstatutory delayrule of consistencymurderprolonged incarcerationcriminal trial
  Summary & questions settled

  This matter concerns a bail application filed by the accused, Talib Hussain, who was charged under Section 302/34 of the Pakistan Penal Code 1860 for the murder of his in-laws. The core legal question was whether the applicant was entitled to bail based on the statutory delay in the conclusion of his trial, particularly given that his co-accused, who was attributed the fatal injuries, had already been granted bail on similar grounds. The Court observed that the applicant had been in custody for over four years, with no delay in the trial attributable to him. Furthermore, the Court noted that the applicant was not a hardened criminal, had no prior convictions, and was assigned a lesser role in the incident compared to his co-accused. The Court held that the applicant had earned a statutory right to bail due to the prolonged incarceration without trial conclusion. Applying the rule of consistency, the Court granted bail, finding no evidence to support the prosecution's apprehensions regarding witness tampering or potential harm to the complainant.

  Questions settled

  • Whether an accused is entitled to bail on the ground of statutory delay if the trial has not concluded within a reasonable period?
  • Does the principle of consistency apply to the grant of bail when a co-accused with a more serious role has already been released?
  • Can bail be denied solely on the basis of unsubstantiated apprehensions of witness tampering or future harm?
  Read full judgment →
• Jamil Ahmed Versus Province of Sindh2001 YLR 1837 · Sindh High Court · 1999-08-19Read full judgment →
• Amanullah Versus Province of Sindh2001 YLR 1808 · Sindh High Court · 2000-09-10Read full judgment →
• 2001 Ylr 17342001 YLR 1734 · Sindh High CourtRead full judgment →
• Abdullah Versus State2001 YLR 1731 · Sindh High Court · 2001-05-15
  post-arrest bailinstigationcommon intentionfurther inquirymurdergun pointation
  Summary & questions settled

  This matter comes before the Sindh High Court upon a post-arrest bail application filed by the applicant, Abdullah, who is facing trial in Sessions Case No.292 of 2000 arising from Crime No.45 of 2000 registered at Police Station Dharmah. The core legal question concerns whether an accused attributed only with instigation (lalkara), pointing a gun without firing, and a generalized common intention in a murder case is entitled to bail pending trial when fatal knife injuries were inflicted by co-accused. The court held that where no overt fatal act is attributed to the applicant and the case involves a question of shared common intention, the matter falls within the scope of further inquiry under section 497(2) of the Code of Criminal Procedure 1898. Relying on established precedents, the court admitted the applicant to bail, establishing that the mere attribution of instigation and possession of a weapon not used to cause fatal injury warrants further inquiry into the accused's culpability.

  Questions settled

  • Is an accused person attributed only with instigation and pointing a gun without firing entitled to post-arrest bail when fatal injuries are caused by co-accused?
  • Does the question of sharing common intention in a murder case bring the case of an accused within the purview of further inquiry?
  • Whether bail should be granted when the State raises no objection to the release of the applicant?
  Read full judgment →
• Muhammad Siddiq Versus Muhammad Sharif2001 YLR 1701 · Sindh High Court · 2001-05-16Read full judgment →
• Aijaz Ali Versus State2001 YLR 1493 · Sindh High Court · 2001-03-15
  narcotics possessionbenefit of doubtchemical examiner reportprocedural irregularitycriminal appealrecovery of contrabandpolice station entry
  Summary & questions settled

  This criminal appeal challenges the conviction of the appellant under Section 9(b) of the Control of Narcotic Substances Act 1997, for the alleged possession of half a kilogram of Charas. The core legal question was whether the prosecution successfully established the guilt of the accused beyond reasonable doubt, given several procedural lapses during the investigation. The Sindh High Court held that the prosecution failed to prove its case. The Court found that the failure to seal the recovered narcotics on the spot, an unexplained one-month delay in sending the substance to the Chemical Examiner, and the non-production of the police station departure entry to verify the police party's movement, collectively vitiated the trial. Consequently, the Court set aside the conviction and sentence, granting the appellant the benefit of doubt. The judgment reinforces the principle that procedural irregularities in handling recovered contraband and failure to produce essential documentary evidence regarding police movement create significant doubt, necessitating acquittal in criminal narcotics cases.

  Questions settled

  • Does the failure to seal recovered narcotics on the spot vitiate a conviction under the Control of Narcotic Substances Act 1997?
  • What is the legal effect of an unexplained delay in sending a narcotic sample to the Chemical Examiner?
  • Is the non-production of the police station departure entry fatal to the prosecution's case in a narcotics recovery trial?
  Read full judgment →
• Muhammad Versus State2001 YLR 1442 · Sindh High Court · 2001-03-09
  benefit of doubtocular testimonymaterial contradictionscriminal appealprocedural irregularitylast seen evidenceacquittal
  Summary & questions settled

  This criminal appeal challenges the judgment of the Additional Sessions Judge, Kotri, which convicted the appellant for murder under section 302 of the Pakistan Penal Code 1860, sentencing him to life imprisonment. The core legal questions concern the sufficiency of evidence in an unwitnessed incident, the impact of material improvements in ocular testimony, the failure to put incriminating evidence to the accused during examination under section 342 of the Code of Criminal Procedure 1898, and the procedural validity of the trial court's judgment. The High Court held that the prosecution failed to prove its case beyond reasonable doubt. The court found that the sole eyewitness made material improvements contradicting the F.I.R., the recovery of the weapon was doubtful, and the trial court failed to comply with mandatory procedural requirements, including section 364(2) of the Code of Criminal Procedure 1898. Furthermore, the court noted that co-accused were acquitted on the same evidence. Consequently, the court set aside the conviction, laying down the principle that a conviction cannot be sustained where the prosecution evidence is riddled with material contradictions, procedural lapses occur in the examination of the accused, and the state fails to support the conviction.

  Questions settled

  • Does the failure to put incriminating evidence to an accused during examination under section 342 of the Code of Criminal Procedure 1898 vitiate the trial?
  • Can a conviction be sustained when the prosecution evidence is riddled with material contradictions and improvements?
  • Is it permissible to convict an accused on the same set of evidence upon which co-accused have already been acquitted?
  Read full judgment →
• Moula Bux Versus State2001 YLR 1374 · Sindh High Court · 2001-05-29
  criminal appealbenefit of doubtocular testimonyhostile witnessweapon recoveryballistic expertmotive
  Summary & questions settled

  This criminal appeal challenges the judgment of the Additional Sessions Judge Ratodero convicting the appellant under section 302/34 PPC (though provisions are referred generally; specific sections of Cr.P.C. are cited) and sentencing him to life imprisonment. The core legal questions involved the reliability of ocular testimony where an eye-witness turned hostile, the evidentiary value of a belated and unsealed weapon recovery not sent to a ballistic expert, the non-compliance with mandatory provisions regarding statements recorded under section 164 Cr.P.C., and the validity of a slipshod judgment under section 367 Cr.P.C. The Sindh High Court held that material improvements in the complainant's statement, contradictions between ocular and medical evidence, hostility of an eye-witness, and delayed unsealed recovery without ballistic report created serious doubts in the prosecution's case. Consequently, the court set aside the conviction and sentence, extending the benefit of doubt to the appellant. The key principle laid down is that where prosecution witnesses fail to speak the truth and major evidentiary links are missing or compromised, the benefit of reasonable doubt must be extended to the accused as a matter of right.

  Questions settled

  • Whether the testimony of an eye-witness who does not support the prosecution case renders the presence of other eye-witnesses doubtful?
  • Does a delayed recovery of a weapon from an open space not in exclusive possession, without sealing and a ballistic report, create a reasonable doubt?
  • Whether material improvements in the ocular account compared to the police statement vitiate the reliability of the witness?
  • Is a judgment written in a slipshod manner without evaluating the entire evidence sustainable under section 367 of the Code of Criminal Procedure 1898?
  Read full judgment →
• Munir Ahmed Versus State2001 YLR 1249 · Sindh High Court · 2001-08-13
  narcotics possessionchemical examiner reportprocedural irregularitycurable irregularitySection 342 CrPCSection 364 CrPCSection 537 CrPCfair trial
  Summary & questions settled

  This appeal challenges the conviction of the appellant under Section 9(c) of the Control of Narcotics Substances Act, 1997, for possession of narcotics. The core legal questions concerned whether a trial court may seek a second chemical examination when the first report is suspected of being tainted by corruption, and whether procedural omissions—specifically the failure to amend the charge regarding quantity and the absence of a handwritten certificate under Section 364(2) of the Code of Criminal Procedure 1898—vitiate the trial. The Court held that the trial court acted within its jurisdiction to ensure justice by seeking a second, reliable chemical report. Furthermore, the Court ruled that procedural defects, such as the omission of a handwritten certificate under Section 364(2), constitute curable irregularities under Sections 533 and 537 of the Code of Criminal Procedure 1898, provided no prejudice is caused to the accused. The key principle laid down is that procedural irregularities in recording an accused's statement do not vitiate a trial unless they occasion a failure of justice or prejudice the defense on the merits.

  Questions settled

  • Can a trial court order a second chemical examination of narcotics if the initial report is suspected of being tainted by corruption?
  • Does the failure to amend a charge regarding the quantity of narcotics vitiate the trial if the punishment remains the same?
  • Is the omission of a handwritten certificate under Section 364(2) of the Code of Criminal Procedure 1898 an incurable illegality or a curable irregularity?
  • Under what circumstances does a procedural irregularity in the trial court proceedings warrant the reversal of a conviction?
  Read full judgment →
• Muhammad Saleem Versus State2001 YLR 1084 · Sindh High Court · 1999-01-18
  post-arrest bailstolen propertyfurther inquiryconcession of bailcriminal liability
  Summary & questions settled

  This matter concerns a bail application filed by the applicant, Muhammad Saleem, challenging the order of the Sessions Judge, Malir, Karachi, which had previously rejected his bail plea in a case involving the purchase of stolen watches. The core legal question was whether the applicant, who allegedly purchased stolen property but returned it upon discovering its illicit origin, was entitled to the concession of bail, particularly when the State did not oppose the application. The High Court observed that the applicant was not involved in the actual theft but had purchased the items from the perpetrators. Given that the applicant had returned the stolen goods upon learning of their background and the State counsel conceded that the case required further inquiry, the Court exercised its discretion to grant bail. The judgment affirms the principle that where an accused is not directly involved in the commission of the primary offence (theft) and the case against them warrants further investigation, the concession of bail is appropriate, provided the applicant furnishes the required surety.

  Questions settled

  • Is an accused entitled to bail when they purchased stolen property but returned it upon discovering its origin?
  • Does a case warrant further inquiry when the State counsel does not oppose the grant of bail?
  • Can bail be granted when the offence does not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  Read full judgment →
• Muhammad Imran Versus The State2000 YLR 50 · Sindh High Court · 1999-08-11
  unlicensed weaponarms ordinancerecovery witnessmashirmilitary personnel as witnesscriminal appealbail cancellation
  Summary & questions settled

  This criminal appeal challenges the judgment of the Special Court convicting the appellant under Section 13-D of the Arms Ordinance for the recovery of an unlicensed sten-gun. The core legal questions involved whether the absence of private witnesses vitiates the recovery under Section 103 of the Code of Criminal Procedure 1898, and whether acquittal in the main robbery case affects the separate recovery case. The Sindh High Court held that Army personnel acting as mashirs are independent witnesses whose testimony is reliable, especially in circumstances where public witnesses are unavailable, and that acquittal in a main robbery case does not automatically negate a lawful recovery. The court dismissed the appeal, upholding the conviction and sentence while granting the benefit of Section 382-B of the Code of Criminal Procedure 1898.

  Questions settled

  • Whether army personnel can act as independent mashirs for a weapon recovery under Section 103 of the Code of Criminal Procedure 1898?
  • Does the acquittal of an accused in a main robbery case have an adverse impact on a separate conviction for the recovery of a weapon?
  • Can the evidence of official witnesses be discarded solely due to the absence of private public witnesses during a recovery?
  Read full judgment →
• Noor Muhammad Versus The State2000 YLR 2850 · Sindh High Court
  post-arrest bailpolice encounterfurther inquiryunlicensed pistolcriminal procedure
  Summary & questions settled

  The applicant Noor Muhammad sought post-arrest bail in Crime No. 51 of 1999 registered under sections 324, 353 and 34 of the Pakistan Penal Code at Police Station Shahrah-e-Noor Jehan, Karachi. The core legal question was whether the case against the applicant, involving an alleged police encounter and recovery of an unlicensed pistol, warranted further inquiry under section 497(2) of the Code of Criminal Procedure 1898. The Sindh High Court considered the contentions that no empties were recovered from the spot and that the State did not oppose the grant of bail. The court held that the case called for further inquiry and accordingly admitted the applicant to bail upon furnishing the requisite surety bonds, laying down the principle that where material aspects of a police encounter are subject to doubt and the State does not oppose bail, the accused is entitled to the concession of post-arrest bail pending trial.

  Questions settled

  • Whether the circumstances of an alleged police encounter involving doubtful recoveries warrant further inquiry for the grant of bail?
  • Is an accused entitled to post-arrest bail when the State does not oppose the bail application?
  Read full judgment →
• Federal Government Versus Dawood2000 YLR 2377 · Sindh High Court · 2000-03-22
  acquittal appealmaintainabilityCentral Law OfficersCustoms Actdelegation of authoritylocus standi
  Summary & questions settled

  This matter involves multiple special criminal appeals and miscellaneous applications filed by the Federal Government, State, and Customs authorities against orders of acquittal and bail passed by the Special Judge (Customs and Taxation), Karachi. The core legal question was whether these appeals were competently filed and maintainable when not instituted by Central Law Officers authorized under the relevant law. The Sindh High Court held that under Section 4-A of the Central Law Officers Ordinance 1970 (as amended by Act XVII of 1985), only designated Central Law Officers such as Additional Attorneys-General, Deputy Attorneys-General, and Standing Counsel are deemed public prosecutors competent to institute and conduct proceedings and appeals on behalf of the Federal Government. Consequently, appeals filed by unauthorized advocates, collectors, or other officials without proper statutory authorization are incompetent and not maintainable. The key principle laid down is that criminal appeals and revisions on behalf of the Federal Government before courts and tribunals must strictly be instituted by the statutorily authorized Central Law Officers.

  Questions settled

  • Whether appeals and revisions on behalf of the Federal Government can be instituted by persons other than the Central Law Officers specified under Section 4-A of the Central Law Officers Ordinance 1970?
  • Are acquittal appeals filed by unauthorized advocates or officials on behalf of the State maintainable before the High Court?
  • Does Section 185F(1) of the Customs Act 1969 override the specific requirements for filing appeals through authorized Central Law Officers?
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• Amjad All Versus The State2000 YLR 224 · Sindh High Court · 1999-08-02
  post-arrest bailrule of consistencyrobberyidentification paradefurther inquiry
  Summary & questions settled

  The applicant, Amjad Ali, sought post-arrest bail in a case registered under Section 392/34 of the Pakistan Penal Code 1860 arising from an FIR concerning robbery at a jewellery shop. The core legal question was whether the applicant was entitled to bail on the basis of the rule of consistency and lack of identification by the complainant during trial, particularly when a co-accused from whom recovery was made had already been enlarged on bail. The Sindh High Court held that since the co-accused was granted bail and the complainant failed to identify the applicant during the trial, the applicant's case called for further inquiry. The Court laid down the principle that an accused person is entitled to bail on the ground of consistency when situated similarly to a co-accused already granted bail, and where the primary identifying witness fails to identify the accused during deposition before the trial court.

  Questions settled

  • Whether an accused is entitled to post-arrest bail on the principle of consistency when a co-accused facing similar allegations has already been released on bail?
  • Does the failure of the complainant to identify the accused during the trial proceedings make the case one of further inquiry under criminal jurisprudence?
  • Can bail be denied solely on apprehension of abscondence when the evidentiary value of the identification evidence has been substantially weakened at trial?
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• Mirza Muhammad Qasim Bail Versus Government of Sindh2000 YLR 1609 · Sindh High CourtRead full judgment →
• Ziauddin Versus Roze-Ud-Din1999 YLR 978 · Sindh High Court · 1999-05-18Read full judgment →
• Ejaz Ahmed Versus State1999 YLR 946 · Sindh High Court · 1999-03-03Read full judgment →
• Jahangir Versus State1999 YLR 933 · Sindh High Court · 1999-02-01Read full judgment →
• Excel] Builders Versus The Karachi Metropolitan Corporation, K.M.C.1999 YLR 2659 · Sindh High Court · 1999-04-09Read full judgment →
• Muhammad Ramzan Versus XLTH Civil and Family Judge, Karachi (East)1999 YLR 2651 · Sindh High Court · 1999-03-31Read full judgment →
• Muhammad Naeem Versus State1999 YLR 2245 · Sindh High Court · 1999-03-19Read full judgment →
• Mujeeb-Ur-Rehman Bhayo Versus Federation of Pakistan through Secretary Ministry of Energy, Islamabad2025 PLC 222 · Sindh High Court · 2024-05-21
  constitutional petitionNational Industrial Relation Commissionalternative remedymaintainabilityservice terminationemployees quota
  Summary & questions settled

  The petitioner filed a constitutional petition under Article 199 of the Constitution of the Islamic Republic of Pakistan, 1973, seeking a writ of certiorari against the decision of a single Member Bench of the National Industrial Relation Commission (NIRC) and directions for reinstatement following the termination of his employment with Sukkur Electric Power Company (SEPCO). The core legal questions involved the maintainability of a constitutional petition against an order of the single Bench of the NIRC when an adequate statutory remedy of appeal before the Full Bench of the NIRC was available, and whether direct invocation of writ jurisdiction was permissible without exhausting alternative remedies or challenging the underlying termination order appropriately. The Sindh High Court held that the constitutional petition was not maintainable as the petitioner bypassed the statutory remedy of filing an appeal before the Full Bench of the NIRC. The key principle laid down is that the High Court will not entertain a constitutional petition under Article 199 against an order passed by a single Bench of the NIRC when the aggrieved party has not exhausted the statutory remedy of appeal available before the Full Bench.

  Questions settled

  • Is a constitutional petition maintainable against an order passed by a single Bench of the National Industrial Relation Commission without first exhausting the statutory remedy of appeal before the Full Bench?
  • Can the High Court interfere under Article 199 of the Constitution of the Islamic Republic of Pakistan, 1973 when the petitioner has an adequate alternative remedy available under the law?
  Read full judgment →
• Salahuddin Anjum Versus National Industrial Relations Commission, (Full Bench) Governor House, Gate No.4, Karachi , Faisal Mehmood Ghani2025 PLC 210 · Sindh High Court · 2024-04-17
  workman statusburden of prooflabor court jurisdictionbank officermanagerial capacitygrievance petitionindustrial dispute
  Summary & questions settled

  The petitioner, an Officer Grade-III in a nationalized bank, challenged an order by the Full Bench of the National Industrial Relations Commission (NIRC) which set aside a Labor Court judgment in his favor. The core legal question was whether the petitioner qualified as a "workman" under the relevant labor laws, thereby conferring jurisdiction upon the Labor Court to adjudicate his grievance. The High Court upheld the NIRC’s decision, holding that the petitioner failed to discharge the initial burden of proof required to establish his status as a workman. The Court affirmed that designation alone is not conclusive; rather, the nature of duties—manual or clerical versus managerial or supervisory—determines one's status. Since the petitioner’s duties involved supervisory functions and he failed to provide evidence of manual or clerical work, he did not qualify as a workman. The key principle laid down is that the burden of proof lies squarely on the claimant to demonstrate, through evidence, that their actual duties are manual or clerical, and that bank officers performing supervisory tasks do not fall within the definition of a workman.

  Questions settled

  • Does the burden of proof lie on the person claiming to be a workman to establish their status before a Labor Court?
  • Can an Officer Grade-III in a bank be classified as a workman under the Industrial Relations Act, 2012?
  • Is the designation of an employee the determining factor for establishing their status as a workman?
  • Does the performance of routine tasks involving the use of computers or pay orders necessarily qualify an employee as a workman?
  Read full judgment →
• Muhammad Amin Brothers (Pvt.) Ltd. Versus Syed Raheem2025 PLC 186 · Sindh High Court · 2025-02-13
  permanent workerbeneficial interpretationgroup insurancemine accidentconstitutional petitionlabour lawworkmen's compensation
  Summary & questions settled

  This constitutional petition challenged an order passed by the Commissioner Workmen's Compensation and Authority under Payment of Wages Act, which granted insurance benefits to mine workers or their heirs following an accident. The petitioner contended that the deceased and injured individuals did not meet the definition of 'permanent worker' under the Sindh Terms of Employment (Standing Orders) Act, 2015, as they had not completed the requisite probationary period. The core legal question was whether the restrictive definition of 'permanent worker' precludes insurance benefits for workers who suffer death or injury before completing the statutory service period. The Court held that the Sindh Terms of Employment (Standing Orders) Act, 2015 is a beneficial statute. Consequently, the restrictive period for 'permanent worker' status should not be interpreted to deny benefits in cases of death, as the statute does not explicitly impose such a restriction. The petition was dismissed regarding the deceased workers, though the Court declined to extend this interpretation to the injured worker and set aside the penalty imposed by the authority.

  Questions settled

  • Does the definition of 'permanent worker' under the Sindh Terms of Employment (Standing Orders) Act, 2015, preclude insurance benefits for workers who die before completing the statutory probationary period?
  • Is the Sindh Terms of Employment (Standing Orders) Act, 2015, considered a beneficial statute requiring liberal interpretation in cases of worker death?
  • Can an employer be held liable for insurance payments under the Sindh Terms of Employment (Standing Orders) Act, 2015, if the worker has not completed the full probationary period?
  Read full judgment →
• Changyi Kangji Sanitation Engineering Pakistan (East) Versus Amirullah2025 PLC 173 · Sindh High Court · 2025-03-07
  grievance noticeservice of noticeworkmanlabour courtreinstatementback benefits
  Summary & questions settled

  The petitioner establishment challenged an appellate judgment that had reinstated respondent No.1 to service with back benefits after setting aside an order of the Labour Court. The core legal question was whether the grievance application was competently filed without proper service of a grievance notice upon the employer establishment as mandated by law. The Sindh High Court held that the service of the grievance notice at the premises of the Chief Executive Officer rather than at the official address of the establishment was fatal to the proceedings, rendering the grievance petition incompetently filed. The court laid down the principle that failure to serve a proper grievance notice to the correct authority or address makes the subsequent labour proceedings incompetent.

  Questions settled

  • Does service of a grievance notice at the premises of the Chief Executive Officer rather than the establishment's address render a labour petition incompetent?
  • Whether failure to serve a proper grievance notice under the Sindh Industrial Relations Act, 2013 vitiates subsequent proceedings?
  Read full judgment →
• Pakistan National Shipping Corporation Versus Muhammad Reyaz2025 PLC 129 · Sindh High Court · 2025-04-18
  second appealcontractual employeeworkman statuscivil court jurisdictionmaster and servantterminal benefitsmanagerial duties
  Summary & questions settled

  This second appeal arises from concurrent judgments and decrees passed by the lower courts which decreed the respondent's civil suit for salary arrears, bonuses, gratuity, leave compensation, club membership, notice period salary, and damages. The core legal questions involved whether the respondent fell within the definition of 'workman' under the Sindh Payment of Wages Act, 2015, thus ousting the jurisdiction of the civil court, and whether a contractual employee whose contract had expired was entitled to benefits beyond the terms of his contract. The Sindh High Court held that the nature of the respondent's duties was managerial and supervisory rather than manual or clerical, meaning he was not a workman and the civil suit was competently filed. The court further held that the lower courts erred in granting claims without proof or justification contrary to the express terms of the employment contract which barred additional allowances, and that temporary or contractual employees cannot claim rights beyond their contract terms. Consequently, the appeal was allowed, and the impugned judgments and decrees were set aside, dismissing the suit.

  Questions settled

  • Whether an employee performing managerial and supervisory duties falls within the definition of a 'workman' under the Sindh Payment of Wages Act, 2015?
  • Can a contractual employee claim terminal benefits and allowances over and above the express terms of their employment contract?
  • Whether the High Court can interfere with concurrent findings of fact in a second appeal under Section 100 of the Code of Civil Procedure, 1908, when the lower courts have misread or failed to appreciate the evidence?
  • Does a contractual employee acquire a right to permanent status or extension of service merely by the passage of time upon the expiry of their contract?
  Read full judgment →
• Karachi Shipyard and Engineering Works Ltd. Versus Sindh Labour Appellate Tribunal2024 PLC 100 · Sindh High Court · 2022-11-22
  writ jurisdictionlabour disputegrievance noticegrievance petitionlaw of limitationpay scaleSindh Labour Appellate Tribunal
  Summary & questions settled

  The High Court of Sindh considered a constitutional petition challenging the judgment of the Sindh Labour Appellate Tribunal, which had reversed the Labour Court's dismissal of an employee's grievance petition seeking a higher pay scale after sixteen years of service. The core legal questions involved whether the Labour Appellate Tribunal could lawfully disregard statutory limitation on grounds of morality or equity and whether its findings granting the higher pay scale were supported by evidence. The High Court held that statutory limitation cannot be brushed aside as a mere technicality or overridden by subjective notions of morality, reaffirming that courts are mandated to determine whether proceedings are within time and that each day of delay must be explained. The Court further held that the Tribunal's decision was based on surmises, superseded circulars, and misappreciation of evidence, given that the employee accepted his pay scale in 1995 without objection until 2011. Consequently, the High Court allowed the petition and set aside the impugned judgment.

  Questions settled

  • Can a court or tribunal disregard the statutory period of limitation on grounds of morality or fairness?
  • Is it mandatory for a court to examine whether proceedings before it are within the prescribed limitation period even if no objection has been raised?
  • Can a claim for a higher pay scale be granted based on superseded circulars and conjectures contrary to the terms of engagement accepted by an employee?
  • Does an unexplained delay of sixteen years in serving a grievance notice bar a worker's claim under labour laws?
  Read full judgment →
• Habib Bank Ltd. Versus Safeer Ahmed2019 PLC 83 · Sindh High Court · 2018-03-02
  Industrial Relations Commissioninterlocutory stay orderunfair labor practiceretirement of employeesjurisdictional challengewrit jurisdictionservice rules
  Summary & questions settled

  This constitutional petition challenged an interlocutory stay order issued by a Member of the National Industrial Relations Commission (NIRC) suspending the retirement of several bank employees. The core legal question concerned whether the NIRC had jurisdiction to entertain a grievance petition regarding retirement under the Industrial Relations Act, 2012, and whether the interim suspension of the retirement order was legally justified. The High Court declined to adjudicate the merits of the jurisdictional challenge or the underlying retirement dispute at the interlocutory stage. Instead, it disposed of the petition by directing the NIRC to decide the pending cases within a strict timeframe of 30 days. The court established that when a jurisdictional challenge is pending before a specialized tribunal, the High Court may prioritize the expeditious disposal of the main case by the tribunal rather than interfering with interlocutory orders, provided that interim protections are balanced to prevent prejudice to the parties involved.

  Questions settled

  • Does the National Industrial Relations Commission have jurisdiction to entertain a grievance petition challenging the retirement of bank employees?
  • Can a High Court direct a specialized tribunal to decide a pending case within a specific timeframe to avoid prolonged litigation?
  • Is an interlocutory stay order issued by the National Industrial Relations Commission subject to interference by the High Court before the main case is decided?
  Read full judgment →
• Syed Faisal Aziz Versus Sindh Labour Appellate Tribunal2019 PLC 72 · Sindh High Court · 2018-05-21
  workman definitionwrongful terminationlabour lawstanding ordersdisciplinary inquiryshow-cause noticeindustrial relations
  Summary & questions settled

  This constitutional petition challenged an order of the Sindh Labour Appellate Tribunal which had set aside the reinstatement of the petitioner. The core legal questions were whether the petitioner, designated as a Sales Coordinator, qualified as a 'workman' under the relevant labour laws, and whether his termination was lawful despite the employer's failure to conduct an inquiry or issue a show-cause notice. The Court held that the petitioner was indeed a 'workman' because the nature of his duties—involving clerical and manual tasks like maintaining bin cards and data entry—was determinative, rather than his designation. Furthermore, the Court ruled that the termination was illegal because the employer failed to comply with the mandatory procedural requirements prescribed under Standing Orders 12 and 15 of the Industrial and Commercial Employment (Standing Orders) Ordinance, 1968. The Court established the principle that statutory procedures for termination, including the conduct of independent inquiries, are mandatory and cannot be bypassed. Consequently, the petition was allowed, and the termination order was vacated, with liberty granted to the employer to initiate fresh disciplinary proceedings in accordance with the law.

  Questions settled

  • Does the designation of an employee determine their status as a 'workman' under the Industrial and Commercial Employment (Standing Orders) Ordinance 1968?
  • Is the requirement to hold an inquiry and issue a show-cause notice mandatory before terminating a permanent workman?
  • Can an employer terminate a workman without following the procedures prescribed in Standing Orders 12 and 15 of the Industrial and Commercial Employment (Standing Orders) Ordinance 1968?
  Read full judgment →
• Gerry's Dnata (Pvt.) Ltd. Versus National Industrial Relations Commission2019 PLC 63 · Sindh High Court · 2018-02-09
  Constitutional petitionNational Industrial Relations CommissionStatus quo orderContempt applicationIndustrial disputeInterim reliefService matter
  Summary & questions settled

  This constitutional petition challenged an order passed by the Full Bench of the National Industrial Relations Commission (NIRC), which granted a status quo order in a contempt/complaint proceeding. The petitioners contended that the NIRC acted on a misrepresentation regarding the suspension of a prior order and that the underlying appeal had become infructuous following a Supreme Court directive. The core legal question concerned the propriety of the NIRC’s status quo order amidst pending litigation and the necessity of judicial intervention to prevent adverse action against the petitioners. The High Court, without determining the merits of the industrial dispute, held that the factual controversy regarding the status of the previous order must be resolved by the NIRC itself. Consequently, the Court directed the NIRC to decide the pending complaint and contempt applications, along with any recall applications, within a reasonable timeframe. To preserve the status quo and prevent irreparable harm, the Court suspended the operation of the impugned order dated 03.01.2018 until the NIRC adjudicates the matter in accordance with the law.

  Questions settled

  • Can a High Court suspend an interim order passed by the National Industrial Relations Commission pending the resolution of a contempt application?
  • Is a status quo order passed by the National Industrial Relations Commission maintainable when the underlying appeal is sub judice?
  • Does the High Court have the jurisdiction to direct the National Industrial Relations Commission to decide pending applications within a specified timeframe?
  Read full judgment →
• Rana Muhammad Rasheed Versus Labour Appellate Tribunal Sindh2019 PLC 115 · Sindh High Court · 2018-02-13
  service record correctiondate of birth alterationsuperannuationcivil service ruleslimitation periodlabour lawjurisdiction of civil courts
  Summary & questions settled

  The petitioner, a former employee of the Karachi Dock Labour Board, challenged the judgment of the Sindh Labour Appellate Tribunal, which rejected his grievance application seeking a correction of his date of birth in his service record. The petitioner, having joined service in 1974, sought to change his recorded date of birth from 1952 to 1954 in 2011, shortly before his retirement. The core legal question was whether an employee is entitled to seek a correction of their date of birth in service records after an inordinate delay and whether such relief can be granted through a civil suit or outside the statutory limitation period. The Court dismissed the petition, holding that the date of birth cannot be altered at the verge of retirement. The Court emphasized that under Civil Service Regulation 171 and Rule 12-A of the Civil Servants (Appointment, Promotion and Transfer) Rules, 1973, any application for correction must be made within two years of the commencement of service. Furthermore, the Court affirmed that civil courts lack jurisdiction to adjudicate service matters regarding the alteration of service records.

  Questions settled

  • Can a public servant seek the correction of their date of birth in their service record at the verge of retirement?
  • Is a civil suit a maintainable remedy for a public servant seeking to alter their date of birth in their service record?
  • What is the statutory limitation period for an employee to apply for the correction of their date of birth in their service record?
  Read full judgment →
• Syed Raza Haider Rizvi Versus Gordon Shipping Company Ltd.2019 PLC 101 · Sindh High Court · 2018-07-02
  seaman injuryemployment contract breachdisability compensationlimitation actmedical treatment negligenceadmiralty and shipping
  Summary & questions settled

  The Plaintiff, a Second Officer on board a vessel, filed a suit for damages and compensation against the Defendants on account of physical disability and loss of earning capacity resulting from an injury sustained during his employment, allegedly aggravated by the Defendants' failure to provide complete medical treatment. The core legal questions involved whether the claim was barred by limitation, whether the injury was caused by the negligence of the Defendants, and whether the Defendants were liable for failing to complete the medical treatment and compensate the Plaintiff. The Court held that while the injury itself was not caused by the Defendants' negligence, the Defendants were negligent in abruptly discontinuing the Plaintiff's medical treatment abroad, resulting in a permanent partial disability. The suit was decreed in favor of the Plaintiff for a compensation equivalent to the established degree of permanent partial disability, along with mark-up. The key principle laid down is that an employer is liable for breach of contract and damages where medical treatment provided under an employment contract is prematurely and unjustifiably discontinued, causing permanent partial disability to an employee.

  Questions settled

  • Whether a claim for compensation arising from a breach of an employment contract is governed by Article 22 or Article 115 of the Limitation Act, 1908?
  • Does an employer's abrupt discontinuation of medical treatment provided under a seaman's contract of employment constitute actionable negligence?
  • Whether an employee is entitled to damages for permanent partial disability when medical treatment is prematurely terminated by the employer?
  • How is the quantum of compensation determined for a seaman suffering from partial permanent disability under standard shipping and employment terms?
  Read full judgment →
• Muslim Commercial Bank Ltd Versus Abdul Waheed Abro2015 PLC 259 · Sindh High Court · 2015-05-26
  domestic inquiryright of cross-examinationnatural justicereinstatementmisconductconstitutional jurisdictiondue processlabour law
  Summary & questions settled

  The petitioner, a banking company, challenged concurrent orders from the Sindh Labour Court and the Sindh Labour Appellate Tribunal, which reinstated an employee dismissed for alleged misappropriation. The core legal question was whether the domestic inquiry, which formed the basis for dismissal, was conducted fairly and in accordance with the principles of natural justice. The High Court held that the inquiry was fundamentally defective because the management failed to provide the employee with an opportunity to cross-examine all witnesses, despite the Inquiry Officer admitting this procedural lapse. The Court emphasized that cross-examination is a vital tool for discovering truth and ensuring a fair trial, a right now constitutionally protected under Article 10-A of the Constitution of Pakistan 1973. Consequently, the Court found no grounds to interfere with the concurrent findings of the lower courts regarding reinstatement. The judgment affirms that while employers retain the right to discipline employees, domestic inquiries must strictly adhere to due process, and the denial of the right to cross-examine renders evidence inadmissible, thereby vitiating the inquiry proceedings.

  Questions settled

  • Does the denial of the right to cross-examine witnesses in a domestic inquiry violate the principles of natural justice?
  • Can a High Court interfere with concurrent findings of fact recorded by labour courts in its constitutional jurisdiction?
  • Is the testimony of a witness in a domestic inquiry admissible if the accused was not afforded the opportunity to cross-examine them?
  Read full judgment →
• Pizza Piper Versus Sindh Labour Appellate Tribunal2014 PLC 300 · Sindh High Court · 2014-04-15
  Workmen's Compensation ActLabour Appellate Tribunalpre-deposit of decretal amountex parte orderconstitutional jurisdictionadministrative dutyCommissioner for Workmen's Compensationright to certified copies
  Summary & questions settled

  This matter concerns constitutional petitions challenging an order of the Sindh Labour Appellate Tribunal, which conditioned the entertainment of an employer's procedural applications—specifically for certified copies and recalling an ex parte order—upon the pre-deposit of the decretal amount. The core legal question was whether the Labour Appellate Tribunal could lawfully impose this pre-deposit requirement under the Workmen's Compensation Act, 1923, when the underlying grievance did not challenge the merits of the compensation award. The Court held that the impugned condition was unsustainable. It reasoned that the statutory requirement for pre-deposit under Section 30(1)(a) of the Workmen's Compensation Act, 1923, applies exclusively to appeals against orders awarding compensation. Since the employer's appeal before the Tribunal concerned the Commissioner's refusal to perform administrative duties rather than the merits of the compensation, the pre-deposit provision was inapplicable. The Court set aside the condition, directing the Commissioner to process the applications without requiring the deposit, establishing that procedural grievances are distinct from substantive appeals requiring statutory pre-deposit.

  Questions settled

  • Is the pre-deposit of the decretal amount mandatory for all appeals filed under the Workmen's Compensation Act, 1923?
  • Does the requirement for pre-deposit under Section 30(1)(a) of the Workmen's Compensation Act, 1923, apply to appeals concerning procedural or administrative refusals by the Commissioner?
  • Can a Labour Appellate Tribunal impose a condition of pre-deposit on an application for recalling an ex parte order if the appeal itself did not challenge the merits of the compensation award?
  Read full judgment →
• Mst. Dadli Versus Federation of Pakistan through Divisional Superintendent Pakistan Railways, Sukkur2011 PLC 276 · Sindh High Court · 2011-03-01
  Payment of Wages ActService duesLegal heirsLabour Court jurisdictionGratuityProvident fundConstitutional petitionInheritance
  Summary & questions settled

  This constitutional petition challenged an appellate order of the Labour Court, which had dismissed the petitioner's claim for a share in the service dues of her deceased son, a former railway employee. The petitioner, the mother of the deceased, sought her share of gratuity, provident fund, and insurance, arguing that the Labour Court incorrectly held that such claims were outside the scope of the Payment of Wages Act, 1936. The High Court held that the Labour Court erred in its appellate capacity by failing to address the merits of the claim and improperly directing the petitioner to seek relief through a civil suit. The Court affirmed that under Section 15 of the Payment of Wages Act, 1936, legal heirs of a deceased employee possess the statutory right to apply for the recovery of unpaid dues, including gratuity and provident fund. Consequently, the High Court set aside the appellate order and remanded the matter to the Labour Court for a fresh decision, directing it to examine the actual payments made and the entitlement of the heirs in accordance with law.

  Questions settled

  • Does the Authority under the Payment of Wages Act, 1936 have jurisdiction to adjudicate claims for service dues filed by the legal heirs of a deceased employee?
  • Can a Labour Court, in an appeal under the Payment of Wages Act, 1936, dismiss a claim solely by directing the claimant to seek relief through a private civil suit?
  • Are legal heirs of a deceased employee entitled to file an application under Section 15 of the Payment of Wages Act, 1936 for the recovery of unpaid service dues?
  Read full judgment →
• Muhammad Usman Versus Federation of Pakistan through Secretary Ministry of Industries and Production2010 PLC 427 · Sindh High Court · 2010-04-05
  constitutional petitionmaintainabilitystatutory rulesservice matterswrit jurisdictionemployment contractPakistan Steel
  Summary & questions settled

  This constitutional petition challenged the non-extension of the petitioners' employment contracts with Pakistan Steel. The petitioners, previously employed on a retainer basis, sought relief after their earlier service tribunal appeal abated following Supreme Court precedents. The core legal question was whether a constitutional petition is maintainable against a corporation like Pakistan Steel regarding employment grievances when no statutory rules govern the terms and conditions of service. The Court, relying on the Supreme Court's judgment in Pakistan International Airline v. Tanveer ur-Rehman, held that in the absence of statutory rules governing employment, a constitutional petition is not maintainable. The Court rejected the petitioners' arguments, noting that the facts were indistinguishable from the Roopa Syed case, which established that corporations without statutory service rules are not amenable to writ jurisdiction in such employment disputes. Consequently, the petition was dismissed, affirming that the High Court lacks jurisdiction to entertain such matters under its constitutional mandate, while leaving the petitioners free to pursue other legal remedies available under the law.

  Questions settled

  • Is a constitutional petition maintainable against a corporation in the absence of statutory rules governing the terms and conditions of employment?
  • Does the lack of statutory rules governing employment in a corporation preclude the High Court from exercising writ jurisdiction?
  Read full judgment →
• Abdul Mateen Versus Muhammad Akhtar2008 PLC 60 · Sindh High Court · 2007-08-07
  ex parte orderPayment of Wageslimitationcondonation of delayservice of summonsdiscrimination
  Summary & questions settled

  This constitutional petition was filed against an order of the Commission for Workmen's Compensation and Authority for the Payment of Wages Act, which set aside an ex parte order and allowed the respondent to file a written statement. The petitioner contended that the respondent's application to set aside the ex parte order was time-barred, filed without a condonation of delay application, and that the Authority acted in a discriminatory manner by dismissing similar late applications in other cases. The High Court observed that the respondent claimed lack of service and only learned of the proceedings upon the initiation of coercive recovery. Distinguishing the facts from the other case cited, the Court held that each application must be decided on its own merits and no case of discrimination was made out. The petition was dismissed in limine, but the trial Court was directed to frame an issue on limitation to be decided on the basis of evidence along with other issues on the merits within three months.

  Questions settled

  • Whether an application to set aside an ex parte order can be entertained without a formal application for condonation of delay if the party claims they were never served with summons?
  • Does the dismissal of a restoration application in one case bind an authority to dismiss similar applications in other cases where the factual circumstances regarding appearance and service differ?
  • Can a question of limitation regarding an application to set aside an ex parte order be deferred to be framed as an issue and decided on merits along with other issues?
  Read full judgment →
• Khalid Naseem Versus Shaheen Airport Services2008 PLC 385 · Sindh High Court · 2006-06-01
  back-benefitsreinstatementindustrial relationslabour courtunlawful dismissalwages
  Summary & questions settled

  This appeal arises from an order of the Labour Court concerning an application under Section 51 of the Industrial Relations Ordinance, 1969, regarding the payment of back-benefits. The core legal question was whether an employee, previously directed to be reinstated with 30% back-benefits by the Labour Appellate Tribunal, is entitled to full wages for the subsequent period during which the employer unsuccessfully challenged the reinstatement order through constitutional petitions up to the Supreme Court, or if the 30% rate should continue to apply. The Sindh High Court held that the employer, having failed to implement the reinstatement order and having pursued prolonged litigation at its own risk, is liable to pay full wages to the employee from the date of the Tribunal's decision until the actual date of reinstatement. The key principle laid down is that an employer cannot evade compliance with a reinstatement order and subsequently restrict back-benefits to a previously adjudicated percentage for the period consumed by the employer's own unsuccessful appeals.

  Questions settled

  • Whether an employee is entitled to full wages for the period consumed by the employer's unsuccessful appeals against a reinstatement order?
  • Can an employer restrict back-benefits to a previously adjudicated percentage for the period of litigation initiated by the employer?
  • Is an employee required to plead and prove gainful employment for the period after a tribunal has already ordered reinstatement?
  Read full judgment →
• Sentinel (Pvt.) Ltd. through Resident Director Versus Mst. Gul Fareen Jana2008 PLC 304 · Sindh High Court · 2008-05-05
  compulsory group insuranceworkmen's compensationadverse inferencetermination of servicewrit jurisdictionburden of proofstanding orders
  Summary & questions settled

  This petition challenged an order by the Commissioner for Workmen's Compensation directing the petitioner, a security firm, to pay compulsory group insurance compensation to the widow of a deceased security guard. The core legal questions concerned whether the deceased was an employee at the time of his death, whether the petitioner employed 50 or more persons—thereby triggering statutory insurance obligations—and whether the Commissioner erred in rejecting the petitioner's procedural requests to produce further evidence. The Court held that the petitioner failed to substantiate claims that the deceased had voluntarily resigned, noting that any termination without a written order violates Standing Order 12(3). Furthermore, the Court applied the principle of adverse inference under Article 129(g) of the Qanun-e-Shahadat, 1984, holding that the petitioner’s failure to produce employment records within their exclusive possession justified the presumption that the workforce exceeded the statutory threshold. Emphasizing that writ jurisdiction does not permit the reappraisal of factual findings supported by evidence, the Court dismissed the petition, affirming the employer's liability to compensate the legal heirs.

  Questions settled

  • Can an employer terminate a workman without a written order stating the reasons?
  • Does the failure of a party to produce records in their exclusive possession allow the court to draw an adverse inference?
  • Is a finding of fact by a Commissioner for Workmen's Compensation subject to reappraisal in writ jurisdiction?
  • What is the threshold of employees required to trigger the compulsory group insurance obligation under the Industrial and Commercial Employment (Standing Orders) Ordinance, 1968?
  Read full judgment →
• Echo West International (Pvt.) Ltd Versus Sindh Social Security Court No.1 and 2 others2008 PLC 274 · Sindh High Court · 2008-04-01
  condonation of delaylimitationvoid ordersufficient causesocial securitymiscellaneous appealtime-barred
  Summary & questions settled

  This miscellaneous appeal challenged an order passed by the Sindh Social Security Court No.1. The core legal question was whether a delay of 605 days in filing the appeal should be condoned under Section 5 of the Limitation Act, 1908, particularly where the appellant contended the impugned order was void and thus exempt from limitation. The High Court dismissed the appeal in limine, holding it hopelessly time-barred. The court rejected the appellant's argument that limitation does not run against void orders, affirming that even void orders must be challenged within a reasonable period from the date of knowledge. The court established that vague explanations for delay do not constitute sufficient cause for condonation. Furthermore, while arbitrary or mala fide actions by government functionaries may be challenged via constitutional jurisdiction, statutory limitation periods for appeals remain strictly applicable, and a party cannot remain in deep slumber regarding their rights, as the facility for extending time cannot be stretched to unreasonable lengths at the appellant's whim.

  Questions settled

  • Does the law of limitation apply to orders alleged to be void?
  • Can a delay of 605 days be condoned based on vague explanations?
  • What is the terminus a quo for challenging an order alleged to be a nullity?
  Read full judgment →
• Umer Khitab Versus Knitwear Industries2008 PLC 220 · Sindh High Court
  industrial relationsillegal terminationdepartmental inquirywilful absencegrievance noticelabour court appeal
  Summary & questions settled

  This appeal under section 47(3) of the Industrial Relations Ordinance, 2002 challenges the dismissal of the appellant's labour application by the Sindh Labour Court. The core legal questions involved whether the appellant was illegally terminated from service without a proper inquiry and whether a valid grievance notice was served under section 46 of the Industrial Relations Ordinance, 2002. The Sindh High Court held that the appellant's termination was lawful, following a proper departmental inquiry into his wilful absence from duty, and that he failed to establish the service of a valid grievance notice. The court affirmed the findings of the labour court, holding that unrefuted testimony of the inquiry officer and the resemblance of the appellant's signatures on the charge-sheet negated his claims of verbal and illegal termination, thereby dismissing the appeal.

  Questions settled

  • Whether an employee's services can be terminated for wilful absence after a departmental inquiry?
  • Does failure to cross-examine an inquiry officer amount to an admission of the inquiry's validity?
  • Whether an application under the Industrial Relations Ordinance, 2002 is maintainable without serving a valid grievance notice?
  • How are disputed signatures on departmental notices verified by the court?
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• Khaistan Khan Versus Indus Deying and Others2008 PLC 119 · Sindh High Court · 2004-09-22
  misconductwrongful dismissallabour lawres judicataindustrial relationsscope of jurisdictionconcurrent findings
  Summary & questions settled

  This constitutional petition challenges the dismissal of the petitioner, an Auto Cone Operator, from service by his employer. The core legal question was whether the petitioner's refusal to perform the duties of an Auto Cone Operator, claiming he was a winder, constituted misconduct justifying dismissal, and whether the inquiry proceedings were vitiated by procedural unfairness. The Court held that the petitioner's refusal to perform the duties of an Auto Cone Operator, a position he had previously held and for which he was employed, constituted misconduct. The Court rejected the petitioner's procedural arguments regarding the inquiry, noting that the misconduct was established by admitted facts. Furthermore, the Court clarified that the jurisdiction of the National Industrial Relations Commission under Section 22-A(8)(g) and the Labour Courts under Section 25-A of the Industrial Relations Ordinance 1969 serve distinct purposes, and the dismissal of a preventive application before the Commission does not operate as res judicata against subsequent labour proceedings. Consequently, the Court upheld the concurrent findings of the lower tribunals and dismissed the petition.

  Questions settled

  • Does the jurisdiction of the National Industrial Relations Commission under Section 22-A(8)(g) of the Industrial Relations Ordinance 1969 overlap with the jurisdiction of Labour Courts under Section 25-A?
  • Can the dismissal of a preventive application before the National Industrial Relations Commission operate as res judicata in subsequent proceedings before a Labour Court?
  • Does an employee's refusal to perform duties associated with their designated job position constitute misconduct?
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• Abdul Qayyum Versus Sindh Labour Appellate Tribunal2001 PLC 115 · Sindh High Court · 2000-11-07
  right to fair hearingnatural justiceremand of caselabour lawconstitutional petitionadjournmentprejudice
  Summary & questions settled

  This constitutional petition challenges an order passed by the Sindh Labour Appellate Tribunal, which proceeded to decide an appeal despite the absence of the petitioners' counsel, who was engaged in proceedings before the High Court and had requested an adjournment. The core legal question was whether the Tribunal's refusal to adjourn, which effectively denied the petitioners the assistance of their legal counsel, resulted in a denial of the right to a fair hearing. The High Court held that the petitioners, being uneducated, were prejudiced by the Tribunal's decision to proceed in the absence of their counsel, as they were unable to present their case on its merits. Consequently, the Court set aside the impugned order and remanded the matter to the Tribunal for a fresh decision. The key principle laid down is that where a party is deprived of the right to be heard through their chosen counsel due to circumstances beyond their control, and prejudice is evident, the proceedings violate the principles of natural justice, necessitating a rehearing.

  Questions settled

  • Does proceeding with an appeal in the absence of a party's counsel, after an adjournment request is denied, constitute a denial of the right to a fair hearing?
  • Can a tribunal's order be set aside if the party was prejudiced by the inability to present their case through counsel?
  • Is a remand appropriate when a party is denied the opportunity to be heard through their chosen advocate?
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• Telephone Industries of Pakistan (Pvt.) Ltd. Versus Sindh Labour Appellate Tribunal1998 PLC 221 · Sindh High Court · 1997-03-13Read full judgment →
• Naseem Saigol Versus Altaf Hussain, Labour Officer and Inspector of Factories, Central Division, Sindh, Karachi1998 PLC 163 · Sindh High Court · 1997-11-01Read full judgment →
• United Workers Front of Pakistan Steel, Karachi Versus Chairman, National Industrial Relations Commission, Karachi , Ch. Rasheed Ahmad & Sulleman Habibullah1995 PLC 462 · Sindh High Court · 1995-01-15Read full judgment →
• Mahmood Khan Versus Sindh Labour Appellate Tribunal, Karachi1995 PLC 426 · Sindh High Court · 1995-03-08Read full judgment →
• Tobacco International Ltd., Karachi Versus Chairman, Sindh Labour Appellate Tribunal, Karachi1993 PLC 87 · Sindh High Court · 1992-05-28Read full judgment →
• Manzoor Hussain Versus General Manager, C.T.R., Lahore1993 PLC 85 · Sindh High Court · 1991-12-15Read full judgment →
• Abasin International Workers Union, Thatta Versus Manager, M/s. Abasin International Dhabeji, District Thatta1993 PLC 83 · Sindh High Court · 1992-08-27Read full judgment →
• Haider Abbas Rizvi Versus Chief Secretary, Government of Sindh, Karachi1993 PLC 687 · Sindh High Court · 1993-04-25Read full judgment →
• Muslim Commercial Bank Ltd., Karachi Versus Shah Nawaz Solangi1993 PLC 651 · Sindh High Court · 1992-10-31Read full judgment →
• Sitwat Hussain Versus National Bank of Pakistan, Karachi1993 PLC 650 · Sindh High Court · 1992-12-15Read full judgment →