Pakistan Case LawLatest 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. 232,813 judgments in total.
- Jaffar Shah and another vs Mian Yahya Shah and another1999 SCMR 20 · Supreme Court of Pakistan · 1998-08-06Read full judgment →
Summary & questions settled
This petition for leave to appeal was filed by tenants against the order of the High Court affirming their eviction ordered by the Rent Controller under the Cantonments Rent Restriction Act 1963. The eviction was sought by the landlord on grounds of default in monthly rent payment and unauthorized subletting. The primary legal issues were whether the landlord's failure to personally testify was fatal to the eviction petition, whether a practice of accepting accumulated rent in lump sum negated wilful default, and whether inducting co-occupants as alleged partners without landlord consent amounted to subletting. The Supreme Court held that personal appearance of a landlord in the witness box is not a sine qua non where the onus shifts to the tenant to prove timely payment and authorized occupancy. The Court further ruled that alleged practice or acceptance of accumulated rent does not condone statutory default, nor does associating a partner without written consent of the landlord validate co-occupancy. Finding no merit, the Supreme Court dismissed the petition.
Questions settled- Is the personal appearance of a landlord in the witness box mandatory to establish grounds of default and subletting?
- Does the practice of accepting accumulated rent in lump sum condone statutory default in payment of rent?
- Does inducting an alleged partner into demised premises without the consent of the landlord constitute unauthorized subletting?
- Jaafar and another vs The State1999 MLD 2223 · Lahore High Court · 1998-10-14Read full judgment →
- Izzat Khan vs The State1999 YLR 1953 · Peshawar High Court · 1999-05-07Read full judgment →
- Izzat Khan and others vs Province of Sindh and others1999 YLR 1180 · Sindh High Court · 1998-11-19Read full judgment →
Summary & questions settled
This matter concerns applications filed under Section 12(2), Code of Civil Procedure 1908, seeking to set aside a decree dated 29-4-1997 passed in Suit No. 785 of 1996 on grounds of fraud and misrepresentation. The applicants, tenants of the subject property, challenged the decree, asserting that the plaintiff, Izzat Khan, obtained the judgment through fraudulent means. The Court identified three essential ingredients for maintaining an application under Section 12(2): the judgment must be of the same court; it must be obtained through fraud, misrepresentation, or lack of jurisdiction; and the applicant must be an affected person. The Court held that while ordinary tenants lack locus standi to challenge title decrees, occupants holding property on 'Pagri' basis possess the requisite standing. However, upon examination, the Court found no evidence of fraud or procedural irregularity in the impugned proceedings. Furthermore, the Court clarified that the decree merely cancelled a conveyance deed and did not declare the plaintiff as the owner, thus not affecting the applicants' rights. Consequently, the applications were dismissed. The Court emphasized that Section 12(2) must be strictly construed to prevent the misuse of the provision for relitigation.
Questions settled- What are the three essential ingredients required to maintain an application under Section 12(2) of the Code of Civil Procedure 1908?
- Do tenants of a property have the locus standi to challenge a decree declaring the title or ownership of that property under Section 12(2) of the Code of Civil Procedure 1908?
- Does an occupant of a property on a 'Pagri' basis have the locus standi to file an application under Section 12(2) of the Code of Civil Procedure 1908?
- Should the allegation of fraud under Section 12(2) of the Code of Civil Procedure 1908 be strictly construed?
- Izhar Hussain Khoso vs Mir Faridullai3 'Amali1999 MLD 3052 · Election Tribunal · 1998-03-16Read full judgment →
- Izhar Ahmed Khan and anothers vs Punjab Labour Appellate Tribunal, Lahore and others1999 SCMR 2557 · Supreme Court of Pakistan · 1999-05-20Read full judgment →
Summary & questions settled
This appeal concerns the employment status of workers initially engaged as temporary staff by the Cotton Export Corporation of Pakistan. The appellants, hired as Delivery Assistants, contended that despite being labeled temporary, they were employed against permanent posts for periods exceeding nine months, thereby qualifying as 'permanent workmen' under the West Pakistan Industrial and Commercial Employment (Standing Orders) Ordinance, 1968. The core legal question was whether the nature of the work and the duration of employment, rather than the designation in the appointment letter, determined the appellants' status as permanent employees. The Supreme Court held that the definition of a permanent workman is determined by the nature of the work and its duration. Since the evidence established the appellants were working against permanent posts for over nine months, they satisfied the statutory criteria for permanent status. The Court emphasized that the nature of the work is the primary test, and employers cannot circumvent labor laws by artificially breaking service periods to maintain a 'temporary' designation for work that is inherently permanent in nature.
Questions settled- What criteria determine whether a worker is classified as a 'permanent workman' versus a 'temporary workman' under the West Pakistan Industrial and Commercial Employment (Standing Orders) Ordinance, 1968?
- Does the designation of 'temporary' in an appointment letter override the actual nature of the work performed when determining an employee's status?
- Can an employer circumvent the status of a permanent workman by terminating and re-employing staff with short breaks to keep the service period under nine months?
- Ivtikhar Ahmed vs State1999 YLR 1841 · Lahore High Court · 1999-03-15Read full judgment →
- Ismat Ullah vs The State1999 YLR 153 · Lahore High Court · 1999-04-01Read full judgment →
- Islamic Republic of Pakistan through Secretary, Ministry of Commerce, Islamabad and others vs Messrs Metropole Cinema Limited1999 MLD 3239 · Lahore High Court · 1998-05-11Read full judgment →
- Ishtiaq and others vs State1999 MLD 3035 · Peshawar High Court · 1998-09-10Read full judgment →
- Ishfaq Ahmad vs Minister for Education, Punjab, Lahore and 4 others1999 PLC (C.S.) 224 · Lahore High Court · 1998-03-03Read full judgment →
- Ishaat Ali Khan vs The Secretary, Home Department, Government of Sindh, Karachi1999 PLC (C.S.) 765 · Sindh Service Tribunal · 1995-06-05Read full judgment →
- Irshad vs The State1999 YLR 956 · Lahore High Court · 1998-11-02Read full judgment →
- Irshad vs Mst. Sajeela Begum and 6 others1999 YLR 459 · Sindh High Court · 1998-09-28Read full judgment →
- Irshad Ahmed Hashmi and anothers vs General Manager, Pakistan1999 SCMR 240 · Supreme Court of Pakistan · 1997-06-19Read full judgment →
Summary & questions settled
This matter concerns an appeal against the dismissal of service appeals by the Chairman of the Federal Service Tribunal. The appellants, employees of Pakistan Railways, were removed from service following an inquiry into a fatal accident. Two members of the Service Tribunal differed in their opinions regarding the appropriate penalty for one appellant, while concurring on the other. Consequently, the Chairman dismissed both appeals without hearing the parties, despite a lack of disagreement regarding one appellant. The core legal question was whether the Chairman acted within his jurisdiction under the Federal Service Tribunals Act, 1973, by dismissing both appeals in their entirety without hearing the parties, despite the concurrence of the initial bench members on one of the cases. The Supreme Court held that the Chairman acted illegally and without jurisdiction. The Court established that where members of a tribunal bench concur on a specific issue, that portion of the judgment becomes final, and the Chairman cannot reopen or dismiss matters upon which there was no difference of opinion. Furthermore, the Court emphasized the necessity of affording parties a hearing before the third member when a difference of opinion arises.
Questions settled- Can the Chairman of the Federal Service Tribunal dismiss an appeal in its entirety when members of the bench have already reached a unanimous decision on part of the case?
- Is the Chairman of the Federal Service Tribunal required to hear the parties before deciding a case referred to him due to a difference of opinion between bench members?
- Does a difference of opinion between tribunal members regarding one appellant justify the reopening of a matter where the members had already concurred on another appellant?
- Irfan Mahdi vs The StateK.L.R. 1999 Criminal Cases 289 · Lahore High Court · 1998-04-30Read full judgment →
- Irfan Jamil Khan vs University of Engineering, Etc.K.L.R. 1999 Civil Cases 375 · Lahore High Court · 1998-04-18Read full judgment →
- Irfan Industries (Pvt.) Ltd. through Director vs Deputy Superintendent1999 MLD 1158 · Lahore High Court · 1998-08-13Read full judgment →
- Irfan Gul Magsi vs Haji Abdul Khaliq Soomro and others1999 PTD 1302 · Election Tribunal · 1998-10-29Read full judgment →
Summary & questions settled
This election petition under Sections 52, 62, and 67 of the Representation of the People Act 1976 challenged the election of Respondent No. 1 as a Member of the Provincial Assembly of Sindh. The petitioner alleged that the respondent was disqualified under Section 99(1)(f) read with Section 12(2) of the Act for making a false declaration of assets in his nomination papers to conceal a default in paying wealth tax under the Wealth Tax Act 1963. The Election Tribunal dismissed the petition, holding that discrepancies in asset valuations given in good faith or without mens rea do not constitute a willful default or false declaration. The Tribunal ruled that assessing asset valuations and determining tax liability falls strictly within the exclusive domain of the tax authorities. In the absence of a formal demand and assessment by tax authorities finding the candidate liable, the Tribunal cannot usurp that authority to declare him a defaulter.
Questions settled- Does an inadvertent discrepancy in asset valuation in a nomination paper constitute a disqualification under Section 99(1)(f) of the Representation of the People Act 1976?
- Can an Election Tribunal assess tax liability and declare a candidate a tax defaulter in the absence of a formal assessment by taxation authorities?
- What constitutes a default in the payment of taxes for the purposes of election disqualification?
- Irfan Ghouri vs Station House Officer, Police Station Chehyalak, Multan and anothers1999 P Cr. L J 1846 · Lahore High Court · 1998-07-20Read full judgment →
- Irfan Ghouri vs S.H.O., Police Station, Chehyalak, Multan and anothers1999 MLD 1353 · Lahore High Court · 1998-07-20Read full judgment →
- Iram Ghee Mills Ltd. vs Income Tax Appellate Tribunal Etc.1999 P.C.T.L.R. 1 · Lahore High Court · 1998-05-29Read full judgment →
- Iqrar Ahmed and another vs The State and another1999 YLR 1117 · Sindh High Court · 1999-03-16Read full judgment →
- Iqbal Yousif vs The State1999 MLD 921 · Sindh High Court · 1998-04-06Read full judgment →
- Iqbal Yousaf vs The StateK.L.R. 1999 Shariat Cases 22 · Sindh High Court · 1998-04-06Read full judgment →
- Iqbal Razzaq Butt vs Abdus Salam Butt and 6 others1999 MLD 634 · Supreme Court of Azad Jammu and Kashmir · 1998-08-03Read full judgment →
- Iqbal Razzaq Butt vs Abdus Salam Butt and 3 others1999 MLD 261 · Supreme Court of Azad Jammu and Kashmir · 1998-08-13Read full judgment →
Summary & questions settled
This review petition was filed against the Supreme Court of Azad Jammu and Kashmir's judgment dismissing an appeal regarding the petitioner's eligibility to contest elections for the Azad Jammu and Kashmir Legislative Assembly. The petitioner sought review based on the discovery of new evidence—pedigree-tables allegedly proving his grandfather was a State Subject—and argued that the writ petition before the High Court was incompetent due to the availability of an alternate remedy. The Court held that review jurisdiction under Order XLVI of the Azad Jammu and Kashmir Supreme Court Rules and Order XLVII, Rule 1 of the Code of Civil Procedure 1908 requires that the newly discovered evidence could not have been produced at the time of the original decree despite the exercise of due diligence. The Court found the petitioner failed to demonstrate this, noting the evidence was within his knowledge during the initial proceedings. Furthermore, the Court affirmed that the alternate remedy was not adequate or efficacious given the time-consuming nature of administrative appeals, and dismissed the petition in limine, emphasizing that review is not a mechanism to fill evidentiary gaps.
Questions settled- What are the mandatory conditions for exercising review jurisdiction regarding the discovery of new evidence under Order XLVII, Rule 1 of the Code of Civil Procedure 1908?
- Can a review petition be entertained if the petitioner fails to prove that the newly discovered evidence could not have been produced earlier with due diligence?
- Is a writ petition maintainable when an alternative administrative remedy exists but is not considered adequate or efficacious?
- Does the mere existence of an alternate remedy automatically bar the filing of a writ petition?
- Iqbal Ahmed vs The State1999 MLD 3248 · Sindh High Court · 1999-01-07Read full judgment →
- Investment Corporation of Pakistan (I.C.P.) vs Messrs Sindh Tech.1999 MLD 2609 · Sindh High Court · 1997-08-12Read full judgment →
- Intizar Ali vs The StateK.L.R. 1999 Criminal Cases 71 · Lahore High Court · 1997-10-08Read full judgment →
- International Operating Services Ltd. vs Commissioner of Income-Tax1999 PTD 2746 · karnataka High Court · 1997-06-09Read full judgment →
- Institution of Engineers vs Director-General, Excise and Taxation and 2 others1999 PLD Lahore 337 · Lahore High Court · 1999-03-26Read full judgment →
- Institute of Chartered Accountants of, Pakistan, Karachi And Others1999 P.C.T.L.R. 47 · Supreme Court of PakistanRead full judgment →
Summary & questions settled
This judgment disposes of ten civil appeals arising from a common judgment of the High Court of Sindh regarding the validity of a notification issued by the Council of the Institute of Chartered Accountants of Pakistan restricting the number of attempts a student could make to clear the Intermediate and Final Chartered Accountancy examinations. The core legal questions involved whether the Council was competent to restrict examination attempts through an administrative notification under Bye-Law 118 of the Chartered Accountants Bye-Laws, 1983, without resorting to the formal rule-making procedure under Section 27 of the Chartered Accountants Ordinance, 1961, and whether such restrictions applied retrospectively to existing students. The Supreme Court held that the restriction of examination attempts relates to the standard of training and education and can only be validly imposed by framing a bye-law in accordance with Section 27 of the Ordinance, which requires previous publication and the approval of the Federal Government. Consequently, the Court held that the impugned notification issued without following these statutory requirements was invalid as an unauthorized executive act, while affirming that students do not possess a vested right to be exempt from prospective academic standard modifications.
Questions settled- Whether the Council of the Institute of Chartered Accountants can restrict the number of examination attempts for students through an administrative notification under Bye-Law 118 rather than by framing a formal bye-law under Section 27 of the Chartered Accountants Ordinance, 1961?
- Do students enrolled in a professional course have a vested right to be governed by the examination rules and unlimited attempts that existed at the time of their initial registration?
- To what extent can the High Court interfere with academic policy decisions of the Council of the Institute of Chartered Accountants in exercise of its constitutional jurisdiction under Article 199 of the Constitution of Pakistan, 1973?
- Institute (Institution) of Engineers Pakistan through Honorary1999 YLR 436 · Sindh High Court · 1998-12-07Read full judgment →
- Jamil Akhtar vs Secretary, Ministry of Food and Agriculture, Islamabad and 2 others1999 PLC (C.S.) 719 · Federal Service Tribunal · 1997-04-08Read full judgment →
- Inspectorgeneral of Police, Punjab, Lahore vs Ghulam Muhammad1999 SCMR 2509 · Supreme Court of Pakistan · 1999-06-21Read full judgment →
Summary & questions settled
This appeal arose from a challenge by the Inspector General of Police, Punjab, against an order of the Punjab Service Tribunal, which had directed the promotion of the respondent to various ranks based on the promotion dates of his juniors. The core legal question was whether the Service Tribunal possessed the jurisdiction to issue direct orders for the promotion of a civil servant and whether seniority constitutes a vested right for civil servants in Punjab. The Supreme Court, upon reviewing its prior jurisprudence, particularly the cases of Muhammad Iqbal Khokhar and Dr. Sabir Zameer Siddiqui, held that unlike other provincial and federal civil service laws, the Punjab Civil Servants Act, 1974, does not expressly subordinate seniority to rules, thereby establishing that seniority remains a vested right for civil servants in Punjab. Consequently, the Court dismissed the appeal and restored the Tribunal's order, affirming that the Tribunal acted within the scope of the law applicable to Punjab civil servants regarding the protection of their service rights.
Questions settled- Is seniority a vested right for civil servants in the Punjab province?
- Does the Punjab Civil Servants Act 1974 subordinate the right of seniority to rules prescribed for determining seniority?
- Can the Service Tribunal issue directions regarding the promotion of a civil servant in Punjab?
- Inspectorgeneral of Police, Lahore vs Qayyum Nawaz Khan1999 SCMR 1594 · Supreme Court of Pakistan · 1998-06-10Read full judgment →
Summary & questions settled
This petition for leave to appeal challenged a judgment of the Punjab Service Tribunal, which had granted the respondent, a police officer, confirmation as an Inspector effective from 1-7-1986. The core legal question was whether the Tribunal erred in granting this relief, particularly regarding the interpretation of Police Rule 13.20 and the allegation of discrimination against the respondent compared to other officers who received ante-dated confirmations. The Supreme Court upheld the Tribunal's decision, finding that the respondent had a satisfactory service record and that the denial of his confirmation was discriminatory, as other officers had received similar benefits despite the amendment to Police Rule 13.20. The Court held that the Tribunal’s decision was consistent with the law and that no question of public importance warranted interference under Article 212(2) of the Constitution. Furthermore, the Court noted that the petition was time-barred. The key principle established is that administrative authorities cannot discriminate against an employee by denying benefits, such as ante-dated confirmation, when such benefits are consistently granted to similarly situated employees under comparable circumstances.
Questions settled- Can an administrative authority deny a service benefit to an employee when similar benefits have been granted to other employees in comparable circumstances?
- Does the amendment of Police Rule 13.20 act as an absolute bar to ante-dated confirmation for police officers?
- Is a petition for leave to appeal under Article 212(2) of the Constitution maintainable if it is time-barred and lacks a question of public importance?
- Inspector-General of Police, Lahore vs Qayyum Nawaz Khan1999 PLC (C.S.) 1381 · Supreme Court of Pakistan · 1998-07-10Read full judgment →
Summary & questions settled
This petition for leave to appeal challenged a judgment of the Punjab Service Tribunal, which had directed the Inspector-General of Police to confirm the respondent as an Inspector with effect from 1-7-1986. The core legal question was whether the Tribunal erred in granting this relief, specifically regarding the applicability of Police Rule 13.20 and the issue of discrimination against the respondent compared to other officers who received ante-dated confirmations. The Supreme Court upheld the Tribunal's decision, finding that the respondent had a satisfactory service record and that the denial of his confirmation constituted discrimination, as other officers had received similar benefits despite the existence of the same rules. The Court held that the Tribunal's decision was consistent with the law and that no question of public importance warranted interference under Article 212(2) of the Constitution. The key principle laid down is that administrative authorities cannot discriminate against an employee by denying benefits such as ante-dated confirmation when such benefits have been granted to similarly situated employees, provided the request falls within the parameters of the applicable service rules.
Questions settled- Can an administrative authority deny a service benefit to an employee if similar benefits have been granted to other similarly situated employees?
- Does the amendment of Police Rule 13.20 absolutely bar ante-dated confirmation for police officers?
- Is a petition for leave to appeal maintainable under Article 212(2) of the Constitution if no question of public importance is involved?
- Inshaf Hussain Shah and 6 others vs Custodian, Evacuee Property, Azad Jammu and Kashmir and 40 others1999 MLD 531 · High Court of Azad Jammu and Kashmir · 1998-06-04Read full judgment →
- Inshaf Hussain Shah and 5 others vs Custodian of Evacuee Property, Aj&K, Muzaffarabad and 40 others1999 YLR 1676 · Supreme Court of Azad Jammu and Kashmir · 1999-05-12Read full judgment →
- Industrial Development Bank of Pakistan vs Messrs Azeem Food1999 YLR 1112 · Sindh High Court · 1998-04-06Read full judgment →
- Industrial Development Bank of Pakistan Through Its Deputy ChiefK.L.R. 1999 Revenue Cases 100 · Supreme Court of Pakistan · 1999-03-22Read full judgment →
Summary & questions settled
This appeal arose from a High Court judgment concerning the applicability of Section 41 of the Transfer of Property Act 1882 to a mortgaged property. The appellant, Industrial Development Bank of Pakistan, challenged a decision that protected a purchaser of mortgaged land under the doctrine of the ostensible owner. The core legal questions were whether a mortgagor remains an ostensible owner and whether a transfer made during pending litigation is valid. The Supreme Court held that Section 41 is inapplicable because a mortgagor, having deposited title deeds, is not an ostensible owner, and the mortgagee provided no consent. Furthermore, the Court held that the transaction was voidable under the doctrine of lis pendens pursuant to Section 52 of the Transfer of Property Act 1882, as the property was under attachment during pending recovery proceedings. The Court established that a purchaser pendente lite is bound by the litigation's outcome, and the failure to verify title deeds precludes a claim of good faith. Consequently, the High Court’s judgment was set aside, and the appeal was allowed.
Questions settled- Can a mortgagor who has deposited title deeds be considered an ostensible owner under Section 41 of the Transfer of Property Act 1882?
- Does the doctrine of lis pendens under Section 52 of the Transfer of Property Act 1882 apply to a bona fide purchaser of property during pending litigation?
- Is a transferee entitled to protection under Section 41 of the Transfer of Property Act 1882 if they failed to verify the original title deeds?
- Industrial Development Bank of Pakistan through Deputy Chief1999 SCMR 2874 · Supreme Court of Pakistan · 1999-03-22Read full judgment →
Summary & questions settled
This civil appeal by leave of the Supreme Court arises from a judgment of the Lahore High Court regarding the applicability of Section 41 of the Transfer of Property Act to a mortgaged property. The core legal question was whether a subsequent purchaser of a mortgaged property can claim the benefit of Section 41 relating to transfers by ostensible owners without the consent of the mortgagee bank and during the pendency of recovery proceedings. The Supreme Court held that the High Court erred in applying Section 41 because the mortgagor was not an ostensible owner with the express or implied consent of the mortgagee, the title deeds were deposited with the bank, and the purchaser failed to act in good faith by not verifying the title documents. Furthermore, the transaction was hit by the doctrine of lis pendens under Section 52 of the Transfer of Property Act as recovery proceedings and attachment were already pending. The appeal was accordingly allowed and the High Court's judgment set aside.
Questions settled- Whether the benefit of Section 41 of the Transfer of Property Act can be claimed in the case of a mortgaged property where title deeds are deposited with the mortgagee?
- Can a transferee be considered to have acted in good faith under Section 41 of the Transfer of Property Act without verifying the original title documents?
- Does the doctrine of lis pendens under Section 52 of the Transfer of Property Act apply to a transfer of property made while recovery proceedings and court attachment are pending?
- Is a purchase made during the pendency of litigation subject to the final result of the proceedings regardless of whether the purchaser is acting in good faith?
- Indus Pencil Industries (Pvt.) Ltd. vs Vikar Industries (Pvt.) Ltd.1999 P.C.T.L.R. 739 · Sindh High Court · 1998-11-17Read full judgment →
- Indus Pencil Industries (Private) Limited vs Vikar Industries (Private)1999 PLD Karachi 281 · Sindh High Court · 1998-12-24Read full judgment →
Summary & questions settled
The petition under Section 46 of the Trade Marks Act, 1940 sought the rectification of the trade mark register by removing the mark "Impala" registered by the respondent. The petitioner, an established manufacturer of stationery, contended that "Impala" caused confusion with its prior registered marks like "Deer" and "Stag." The core issues concerned the maintainability of the petition before the High Court, the definition of an "aggrieved person," and whether the registration violated Sections 8 and 10 of the Act. The Court held that the High Court and the Registrar possess concurrent jurisdiction under Section 46, and the petitioner, as a trade rival, qualified as an "aggrieved person." Finding that "Impala" was likely to cause deception among consumers, the Court ordered its removal from the register. It established that the term "person aggrieved" must be liberally construed, and that delay does not bar rectification unless it causes substantial injury or constitutes proven acquiescence. Furthermore, the likelihood of deception is assessed based on the potential confusion of the ultimate consumer.
Questions settled- Does the High Court have concurrent jurisdiction with the Registrar of Trade Marks for petitions filed under Section 46 of the Trade Marks Act, 1940?
- Who qualifies as an "aggrieved person" entitled to file a petition for the rectification of the trade mark register?
- Does a delay in filing a petition for rectification of a trade mark constitute a bar to relief in the absence of proven acquiescence?
- Is the Registrar of Trade Marks required to issue notice to owners of existing registered marks when considering a new application for a similar mark?
- Indrajit Singh vs Commissioner of Income-Tax1999 PTD 1939 · Madhya Pradesh High Court · 1996-03-15Read full judgment →
- Income-Tax Officer vs Kalyan Das Madan Mohan , .1999 PTD 3403 · Allahabad High Court · 1997-05-14Read full judgment →
- Income-Tax Officer vs Income-Tax Appellate Tribunal and another1999 PTD 3182 · Patna High Court · 1996-08-23Read full judgment →
- Income-Tax Officer and others vs All India Vijaya Bank Officers'1999 PTD 107 · Calcutta High Court · 1997-01-29Read full judgment →
- Income Tax Appellate Tribunal vs V. K. Agarwal and another1999 PTD 2218 · Supreme Court of India · 1998-11-17Read full judgment →
- Inayatullah vs The StateK.L.R. 1999 Criminal Cases 402 · Lahore High Court · 1998-12-03Read full judgment →
- Inayatullah and 4 others vs The State and anothers1999 P Cr. L J 731 · Sindh High Court · 1998-09-18Read full judgment →
Summary & questions settled
This criminal revision petition challenged an order of the III Additional Sessions Judge, Hyderabad, which had impleaded five persons as co-accused in a pending Sessions case based on an application filed by the complainant under Section 173, Code of Criminal Procedure 1898. These individuals had previously been placed in Column No. 2 of the police challan as persons not sent up for trial due to insufficient evidence. The core legal question was whether a complainant can invoke Section 173, Code of Criminal Procedure 1898 to compel the trial court to summon persons excluded by the police, and under what circumstances a trial court may summon such persons. The Sindh High Court held that Section 173, Code of Criminal Procedure 1898 is a provision for the Investigating Officer to submit a report, not a mechanism for complainants to implead accused persons. The Court set aside the impugned order, ruling that while a trial court possesses the inherent power to summon additional accused, it must do so based on sufficient incriminating material appearing on the record during the trial, rather than extraneous allegations.
Questions settled- Can a complainant file an application under Section 173 of the Code of Criminal Procedure 1898 to implead persons as co-accused who were not sent up for trial by the police?
- Is a trial court authorized to summon persons as co-accused who were placed in Column No. 2 of the police challan?
- What constitutes sufficient material for a trial court to summon an additional accused during the course of a trial?
- Is the opinion of the police regarding the innocence of persons placed in Column No. 2 of the challan binding upon the trial court?
- Inayat Begum And Another vs Muhammad Latif And Another1999 CLC 1160 · Supreme Court of Azad Jammu and Kashmir · 1998-12-04Read full judgment →
- In re: Pak Asian Fund Limited vs N/A1999 CLC 1603 · Sindh High Court · 1997-11-26Read full judgment →
Summary & questions settled
This matter involves a petition filed under Section 97 of the Companies Ordinance, 1984, seeking confirmation of the reduction of the authorized share capital of the petitioner company by 50%. The core legal question concerns whether the court should sanction the proposed reduction of share capital, and whether the scheme is fair, equitable, and protects the interests of shareholders and the public. The Sindh High Court held that the proposed reduction is just, fair, reasonable, and does not adversely affect shareholder interests or involve impediments such as loss of capital without representation. The court confirmed the reduction of the share capital as envisaged by Section 97 of the Ordinance. The key principle laid down is that reduction of share capital requires judicial confirmation, evaluated on the basis of fairness, equity among shareholders, protection of public interest, and the absence of prejudice to creditors or members.
Questions settled- Whether the court should refuse sanction to the reduction of share capital out of regard for the interests of the public?
- Is the proposed reduction of share capital fair and equitable as between different classes of shareholders?
- Does the proposed reduction involve diminution of liability in respect of unpaid capital or payment of paid-up capital?
- Imtiaz vs The StateK.L.R. 1999 Shariat Cases 19 · Lahore High Court · 1998-04-24Read full judgment →
- Imtiaz Hussain vs The State and 2 others1999 MLD 2987 · Lahore High Court · 1998-07-02Read full judgment →
- Imtiaz Ahmed Sheikh vs Secretary, Establishment Division and another1999 PLC (C.S.) 655 · Federal Service Tribunal · 1997-06-30Read full judgment →
Summary & questions settled
This service appeal challenged the dismissal of a civil servant from the Federal Government. The appellant, originally a Federal Government employee, was permanently absorbed into the Government of Sindh while retaining a lien in the Federal Government. Following his termination by the provincial government, the Federal Government ordered him to report for duty and subsequently dismissed him for unauthorized absence. The core legal question was whether the Federal Government could initiate disciplinary proceedings for unauthorized absence against a civil servant who had been absorbed into a provincial government but retained a lien, prior to the civil servant exercising their right of reversion. The Tribunal held that the dismissal was without legal authority. It established that a retained lien does not grant the parent department the right to recall a civil servant; rather, it provides the civil servant the option to revert upon specific contingencies. Consequently, the parent department lacks the authority to charge such a civil servant with unauthorized absence or initiate disciplinary proceedings for failing to report for duty before the civil servant has exercised their right of reversion.
Questions settled- Can a parent department initiate disciplinary proceedings for unauthorized absence against a civil servant who has been permanently absorbed into another department but retains a lien?
- Does a retained lien grant a parent department the authority to unilaterally recall a civil servant?
- Is a transfer under Section 10 of the Civil Servants Act, 1973, distinct from a permanent appointment in another department involving a retained lien?
- Imtiaz Ahmad Malik vs Secretary M/O Railway And OtherK.L.R. 1999 Labour & Service Cases 132 · Supreme Court of Pakistan · 1999-07-06Read full judgment →
Summary & questions settled
This matter arises from a petition filed by Imtiaz Ahmad Malik against the Secretary, Ministry of Railways and others, concerning the entitlement of an employee to the pay and allowances of a higher grade. The core legal question was whether an employee who served on a higher post (B-17) is entitled to the corresponding pay and allowances of that grade, even if promotion to that grade was restricted by quota. The Supreme Court of Pakistan held, based on precedent, that the petitioner is entitled to the pay and benefits of the B-17 post for the period he worked against it, subject to the deduction of any special pay already received. The Court converted the petition into an appeal and modified the judgment of the Federal Service Tribunal accordingly. The key principle laid down is that an employee performing duties on a higher post is entitled to the financial benefits of that post for the duration of such service.
Questions settled- Is an employee serving on a higher post entitled to the pay and allowances of that grade notwithstanding promotion restrictions?
- Whether an employee working against a higher post is entitled to financial benefits minus any special pay already received?
- Imtiaz Ahmad and 2 others vs The State1999 SCMR 2830 · Supreme Court of Pakistan · 1999-05-20Read full judgment →
Summary & questions settled
This criminal appeal arose from a conviction for murder and attempted murder. The appellants were convicted by the trial court for the murder of Inayatullah and causing injuries to others, with the High Court maintaining the convictions of the appellants while acquitting two co-accused. Before the Supreme Court, the appellants did not challenge their convictions, limiting the scope of the appeal to the quantum of sentence. The Supreme Court observed that the ocular testimony of the injured witnesses was reliable and fully supported the prosecution's case. However, regarding sentencing, the Court noted that the two acquitted co-accused had also inflicted fatal or near-fatal injuries on the deceased, indicating a collective act. Despite the acquittal of those co-accused—which the State did not challenge—the Court held that the primary appellant's death sentence was disproportionate given the collective nature of the violence. Consequently, the Supreme Court dismissed the appeal regarding conviction but modified the death sentence of the primary appellant to imprisonment for life.
Questions settled- Can the Supreme Court convert a death sentence to life imprisonment if the evidence shows the crime was a collective act involving acquitted co-accused?
- Is the testimony of an injured witness considered reliable in a murder trial?
- Does the failure of the State to challenge an acquittal prevent the Supreme Court from considering the role of acquitted persons when determining the sentence of the remaining convicts?
- Imran Shahzad vs The StateK.L.R. 1999 Criminal Cases 616 · Lahore High Court · 1999-04-14Read full judgment →
- Imran Butt vs The State1999 YLR 366 · Lahore High Court · 1998-10-19Read full judgment →
- Imperil Construction Company, Sahiwal and 30 others vs Chief1999 YLR 1153 · Lahore High CourtRead full judgment →
Summary & questions settled
These writ petitions challenged the cancellation of tender bids by the Chief Engineer, Punjab Health Engineering Division, for drainage schemes. The core legal question was whether the lowest bidder in a tender process acquires a vested right or locus standi to challenge the rejection of their bid when the tender terms explicitly reserve the right to reject bids without assigning reasons. The Court dismissed the petitions, holding that the petitioners failed to prove their bids were ever formally accepted by the competent authority. The Court determined that the tender conditions empowered the Engineer-in-charge to reject any or all tenders without assigning reasons, and that the rejection was supported by official records. The key principle laid down is that a mere bid in a tender process does not create a contractual right or a binding promise until formally accepted. Consequently, a bidder lacks locus standi to challenge the rejection of their bid where the tender terms allow for rejection without cause, and principles of natural justice do not apply to the rejection of unaccepted bids.
Questions settled- Does the submission of the lowest bid in a tender process create a vested right or contractual obligation?
- Can a bidder challenge the rejection of a tender bid where the tender conditions reserve the right to reject bids without assigning reasons?
- Does the principle of natural justice require notice and hearing before the rejection of an unaccepted tender bid?
- Does a lowest bidder have locus standi to file a writ petition against the cancellation of a tender process?
- Imdad Hussain vs The State1999 PLD Karachi 151 · Sindh High Court · 1998-10-22Read full judgment →
- Imdad Hussain And Others vs Member, Board of Revenue1999 CLC 1247 · Lahore High Court · 1998-11-30Read full judgment →
- Imdad Hussain and 9 others vs Deputy Inspectorgeneral of Police1999 YLR 1694 · Lahore High Court · 1997-11-24Read full judgment →
- Imdad Ali and 28 others vs The Secretary, Ministry of Health, Overnment of Pakistan, Islamabad and 35 others1999 PLC (C.S.) 779 · Federal Service Tribunal · 1996-09-12Read full judgment →
- Imam Bux vs The State1999 P Cr. L J 1696 · Sindh High Court · 1998-09-17Read full judgment →
- Imam Bakhsh vs The State1999 YLR 19 · Lahore High Court · 1998-11-24Read full judgment →
- Ilyas and 2 others vs The State1999 P Cr. L J 1879 · Lahore High Court · 1998-11-05Read full judgment →
- Ilamuddin through Legal Heirs vs Syed Sarfraz Hussain through Legal1999 CLC 312 · Sindh High Court · 1997-09-12Read full judgment →
Summary & questions settled
This civil revision application was filed by the legal heirs of the original applicant against the appellate judgment that had reversed the trial court's dismissal of the respondent's suit and decreed the mandatory and permanent injunctions concerning unauthorized construction on a lane. The core legal question was whether a party can agitate issues in revisional jurisdiction that were decided against them by the trial court but were not challenged via cross-objections or appeal before the first appellate forum. The Sindh High Court held that findings of a trial court not challenged before the lower appellate forum cannot be agitated in an upper appellate or revisional forum, and that concurrent or appellate findings based on site inspection and evidence, unless perverse, will be preferred in revisional jurisdiction. The key principles laid down are that a party failing to challenge adverse trial court findings before the first appellate court is estopped from raising those issues in revision, and that un-agitated mixed questions of law and fact like limitation cannot be reopened.
Questions settled- Can a party agitate findings of the trial court in a revisional forum if they failed to challenge the same before the lower appellate forum?
- Is a finding on limitation, being a mixed question of law and fact, open to challenge in revision when left un-agitated before the first appellate court?
- Which decision is to be preferred in revisional jurisdiction in case of a conflict between the trial court and the appellate court judgments?
- Whether a party is estopped from raising issues before the High Court that they acquiesced to before the lower appellate court?
- Ilam Din And 4 Others vs Yousaf Ali And 12 Other1999 CLC 140 · Lahore High Court · 1998-07-28Read full judgment →
- Ilam Din alias Jumma vs The State1999 YLR 929 · Lahore High Court · 1998-12-17Read full judgment →
- Ijaz Mehmood vs Board of Intermediate and1999 CLC 984 · Lahore High Court · 1998-12-17Read full judgment →
Summary & questions settled
The petitioner sought a writ of mandamus to compel the Board of Intermediate and Secondary Education to correct his date of birth based on a certificate from a Town Committee. The core legal question was whether such a municipal birth certificate is binding on the Board and whether the Board’s refusal to amend its records was lawful. The Court held that the Board acted within its legal authority and dismissed the petition. It established that entries in public registers maintained by Local Councils under the Punjab Local Government Ordinance, 1979, carry only a rebuttable presumption of correctness and are not automatically binding on statutory bodies like the Board. The Board retains the discretion to verify the authenticity of such documents to prevent fraud. Furthermore, the Court emphasized that applicants must strictly comply with the Board’s regulations, which require the correction of school records as a prerequisite for amending Board records. The Board’s refusal was deemed logical and consistent with its regulatory framework, as the petitioner failed to satisfy the mandatory conditions for such a correction.
Questions settled- Is a birth certificate issued by a Local Council binding on an educational board for the purpose of correcting a student's date of birth?
- Does the entry of a date of birth in a Local Council register carry a conclusive or a rebuttable presumption of correctness?
- Can an educational board refuse to correct a student's date of birth if the student fails to comply with the board's specific regulatory requirements?
- Is the Board of Intermediate and Secondary Education authorized to scrutinize the genuineness of a birth certificate provided by a student?
- Ijaz Masih alias Damo vs The State1999 P Cr. L J 343 · Lahore High Court · 1998-09-07Read full judgment →
Summary & questions settled
This criminal miscellaneous petition sought post-arrest bail for the petitioner, Ijaz Masih, who was charged in an F.I.R. under Sections 302/34 and 337-A(i)(ii) of the Pakistan Penal Code 1860 for his alleged involvement in the murder of Bashir Masih. The prosecution alleged that while the co-accused Shahzad Masih inflicted the fatal knife blow, the petitioner facilitated the crime by holding the deceased in a 'Japha' (bear hug) from behind. The petitioner argued for bail based on the principle of consistency, noting that other co-accused had been granted bail. The Court rejected this argument, distinguishing the petitioner's role from that of the co-accused who were only attributed a 'Lalkara' or minor injuries. The Court held that the act of holding the deceased in a 'Japha' was a pivotal role that facilitated the fatal attack, rendering the petitioner vicariously liable. Consequently, the Court dismissed the bail petition, affirming that such active participation in a murder case disentitles an accused to the concession of bail.
Questions settled- Does the principle of consistency apply when the role of the bail-seeking accused is distinguishable from the roles of co-accused already granted bail?
- Is an accused who holds the deceased in a 'Japha' while a co-accused inflicts a fatal blow vicariously liable for the murder?
- Does the act of holding a victim in a 'Japha' to facilitate a fatal attack constitute sufficient grounds to deny post-arrest bail?
- Ijaz Hussain vs The Election Tribunal/Senior Civil Judge, Jhang and 21999 MLD 2164 · Lahore High Court · 1998-11-02Read full judgment →
- Ijaz Hussain vs S.H.O., P.S. Katha Sagral, Tehsil and District Khushab1999 MLD 2721 · Lahore High Court · 1997-03-25Read full judgment →
- Ijaz Hussain vs Jawad Hussain and another1999 YLR 1394 · Peshawar High Court · 1999-04-28Read full judgment →
- Ijaz Hussain vs Election TribunalK.L.R. 1999 Civil Cases 288 · Lahore High Court · 1998-11-02Read full judgment →
- Ijaz Hussain Suleri vs The Registrar and another1999 SCMR 2381 · Supreme Court of Pakistan · 1999-01-21Read full judgment →
Summary & questions settled
This petition for leave to appeal was filed before the Supreme Court of Pakistan against an order of a Division Bench of the Lahore High Court dismissing an Intra-Court Appeal (I.C.A.) as non-maintainable. The core legal questions involved whether an I.C.A. was barred under the Law Reforms Ordinance, 1972, and whether University employees could maintain a Constitutional Petition regarding transfer, promotion, and implementation of service orders. The Supreme Court upheld the High Court's order and dismissed the petition on merits as well as limitation. The Court held that the I.C.A. was not maintainable under the proviso to section 3(2) of the Law Reforms Ordinance, 1972, because the original order was susceptible to revision under section 11-A of the Universities of Punjab Act, 1973. The Court further affirmed that University employees do not hold statutory posts governed by statutory rules to maintain a Constitutional Petition, civil servants/employees have no vested right to a particular post or location of transfer, and promotion based on seniority-cum-fitness is not a vested right.
Questions settled- Whether an Intra-Court Appeal is maintainable under section 3(2) of the Law Reforms Ordinance, 1972, where a revisional remedy is provided under section 11-A of the Universities of Punjab Act, 1973?
- Whether employees of Universities are holders of statutory posts whose terms and conditions are governed by statutory rules for maintaining a Constitutional Petition?
- Does an employee have a vested right to hold a post at a particular station or to be promoted to a post filled on the basis of seniority-cum-fitness?
- Ijaz Hussain and another vs S.H.O., Police Station Saddar, Bhakkar and others1999 P Cr. L J 954 · Lahore High Court · 1998-11-24Read full judgment →
- Ijaz and 2 others vs The State1999 YLR 468 · Lahore High Court · 1999-03-02Read full judgment →
- Ihsanullah vs Collector of Customs, Custom House, Lahore and 41999 PLD Lahore 96 · Lahore High Court · 1998-10-29Read full judgment →
- Ihsanullah Bhatti vs Pakistan Foundation1999 PLC (C.S.) 1075 · Lahore High Court · 1999-04-20Read full judgment →
- Iftikhar Ali vs The State and anothers1999 P Cr. L J 1239 · Lahore High Court · 1998-09-29Read full judgment →
Summary & questions settled
This petition was filed to quash criminal proceedings initiated against the petitioner regarding an alleged forgery of a No Objection Certificate (N.O.C.) used in rent litigation. The core legal question was whether the police could register a case and proceed with an investigation for forgery and cheating when the document in question was allegedly used in judicial proceedings, and whether the police could continue investigation after a Magistrate had already discharged the accused. The Court held that the proceedings were an abuse of the process of law. It found that the ingredients for cheating under the Pakistan Penal Code were not met, and that the police lacked authority to register the case without a written complaint from the concerned Court, as required by law for documents produced in judicial proceedings. Furthermore, the Court noted that the initial discharge order by the Magistrate had attained finality. Consequently, the Court quashed the F.I.R. and the subsequent criminal proceedings, establishing that police cannot bypass the statutory requirement for a judicial complaint when an alleged forgery occurs in relation to documents submitted in court.
Questions settled- Can the police register a criminal case for forgery of a document produced in judicial proceedings without a written complaint from the concerned Court?
- Does a Magistrate's order discharging an accused, if not challenged, attain finality preventing further police investigation?
- Are the offences of forgery under sections 468 and 471 of the Pakistan Penal Code 1860 cognizable by the police without a Magistrate's permission?
- Iftikhar Ahmed Malik vs Sibquat Hayat Ghani and 3 others1999 CLC 1977 · Sindh High Court · 1998-06-30Read full judgment →
- Iftikhar Ahmad vs Station House Officer and others1999 P Cr. L J 1831 · Lahore High Court · 1998-09-18Read full judgment →
- Iftikhar Ahmad vs S.H.O, And OtherK.L.R. 1999 Criminal Cases 27 · Lahore High Court · 1998-09-18Read full judgment →
- Iftikhar Ahmad Khan vs Federation of Pakistan through Secretary, Establishment Division, Islamabad and 3 others1999 PLC (C.S.) 573 · Federal Service Tribunal · 1998-01-06Read full judgment →
- Iftikhar Ahmad alias Billu vs The State1999 P Cr. L J 976 · Lahore High Court · 1998-12-07Read full judgment →
- Iftekhar Ahmed Lari vs Messrs Federal Chemical & Ceramics1999 YLR 1094 · Sindh High Court · 1999-03-31Read full judgment →
- Idrees vs The State1999 P Cr. L J 1056 · Sindh High Court · 1998-10-21Read full judgment →
- Idrees Anwar And Another vs The StateK.L.R. 1999 Criminal Cases 504 · Lahore High Court · 1998-11-12Read full judgment →
- Idoo vs Additional District Judge and 2 others1999 YLR 367 · Lahore High Court · 1998-11-17Read full judgment →
- Ideal Glass (Pvt.) Ltd. vs Federation of Pakistan1999 PTD 1308 · Sindh High Court · 1998-11-27Read full judgment →
- ICI Pakistan Limited, Lahore vs Punjab Labour Court No. 3, Ferozewala, Sheikhupura and another1999 PLC 13 · Lahore High Court · 1998-03-03Read full judgment →
Summary & questions settled
This matter concerns two writ petitions filed by an industrial employer challenging an interim order of a Labour Court. The core legal question was whether a Labour Court possesses the jurisdiction to grant ad interim relief, specifically by suspending the termination of services, in proceedings initiated under section 25-A of the Industrial Relations Ordinance, 1969, given that Order XXXIX, Rule 1, Code of Civil Procedure 1908 is not strictly applicable. The Lahore High Court held that while the Civil Procedure Code may not strictly apply, the power to grant interim relief is an ancillary and incidental power necessary for the Labour Court to effectively adjudicate the main petition and prevent proceedings from becoming infructuous. However, the Court dismissed the petitions in limine on the ground that they were premature. The key principle laid down is that a Labour Court, as a tribunal, inherently possesses the incidental power to issue interim orders to maintain the status quo during the pendency of a grievance petition, and parties must exhaust available statutory remedies, such as those under the Industrial Relations Ordinance, 1969, before invoking the High Court's constitutional jurisdiction.
Questions settled- Does a Labour Court have the jurisdiction to grant interim relief in a grievance petition under the Industrial Relations Ordinance, 1969?
- Is the power to grant interim relief by a Labour Court considered an ancillary power to its main adjudicatory function?
- Can a petitioner invoke the constitutional jurisdiction of the High Court without first exhausting the remedy of appeal before the Labour Appellate Tribunal?
- ICI Pakistan Limited and another vs Crescent Investment Bank Ltd.1999 CLC 1037 · Sindh High Court · 1998-12-14Read full judgment →
- ICI Pakistan Limited And Another vs Crescent Investment Bank Limited1999 P.C.T.L.R. 415 · Sindh High Court · 1998-12-14Read full judgment →
- Icc Textiles Limited vs Federation of Pakistan through Secretary of Finance, Islamabad and 2 others1999 PLD Lahore 251 · Lahore High Court · 1998-11-30Read full judgment →
Summary & questions settled
These constitutional petitions challenged the vires of Section 12 of the Finance Act, 1991, which imposed a Corporate Assets Tax on the assets of incorporated companies. The petitioners contended that under Item 50 of the Fourth Schedule to the Constitution of Pakistan 1973, the legislature could only tax the net value of assets, not the gross value, and that the tax was discriminatory and confiscatory. The Lahore High Court dismissed the petitions, holding that the term capital value of assets in the Constitution does not restrict the legislature to taxing only net assets. The Court affirmed that entries in the Federal Legislative List must be interpreted broadly, and the legislature possesses the authority to determine the mechanism of taxation, including the valuation method. Furthermore, the Court ruled that the tax classification—targeting corporations with assets exceeding Rs. 50 million—was based on an intelligent differentia and was neither discriminatory nor confiscatory. The judgment emphasizes that courts should exercise judicial restraint regarding economic legislation, prioritizing the preservation of laws over their invalidation.
Questions settled- Does the phrase capital value of assets in Item 50 of the Fourth Schedule to the Constitution of Pakistan 1973 limit the legislature to taxing only the net value of assets?
- Can the legislature impose a tax on the gross value of corporate assets?
- Is the classification of corporations based on an asset threshold of Rs. 50 million for tax purposes discriminatory under the Constitution of Pakistan 1973?
- Should economic legislation be interpreted with greater latitude than laws affecting civil rights?
- Ibrar Hussain Rizvi, Subinspector Police, Qila Gujjar Singh, Lahore vs Ghazala Aziz and 4 others1999 PLD Lahore 521 · Lahore High Court · 1999-06-02Read full judgment →
Summary & questions settled
This Intra-Court Appeal challenged a Single Judge's order directing the police to record the complainant's statement and register a second First Information Report (F.I.R.) regarding the alleged custodial killing of her son, Tahir Nafees. The appellant, a police officer, contended that a prior F.I.R. regarding the incident had already been registered, precluding the registration of a second one. The core legal question was whether the High Court, in exercise of its constitutional jurisdiction, can order the registration of a second F.I.R. when a version of the incident is already on record. The Court held that while the general rule is to avoid multiple F.I.R.s for the same occurrence, this is not an absolute rule. Where the complainant's version is radically different from the initial police version—specifically alleging custodial assassination rather than a police encounter—and raises serious factual allegations, the Court is empowered to direct the registration of a second F.I.R. to secure the ends of justice. The Court affirmed that police agencies cannot engage in custodial killings, and such directions are consistent with the rule of law.
Questions settled- Can the High Court order the registration of a second First Information Report if a previous one has already been recorded?
- Is the duty of a Station House Officer to record a statement under Section 154 of the Code of Criminal Procedure 1898 mandatory?
- Under what circumstances can a court depart from the general rule against registering multiple First Information Reports for the same occurrence?
- Ibrahim vs The State1999 P Cr. L J 941 · Lahore High Court · 1998-05-12Read full judgment →