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. 232594 judgments in total.

• Umar Gul vs Dr. Hafiza Akhtar and others2025 SCP 23, 2025 SCMR 544, 2025 PLJ SC 279 · Supreme Court of Pakistan · 2025-01-13
  eviction petitionlandlord-tenant relationshipdenial of titleownership disputeutility billsrent restriction
  Summary & questions settled

  This civil petition for leave to appeal arose from an eviction petition filed by the respondents against the petitioner under the West Pakistan Urban Rent Restriction Ordinance, 1959, alleging default in rent payment and personal bona fide need. The Rent Controller initially dismissed the petition, but the appellate court set aside this order, and the High Court subsequently upheld the appellate decision, confirming the landlord-tenant relationship. The core legal question was whether the petitioner could successfully challenge the eviction order by asserting ownership of the property based on an alleged sale agreement and utility bills, thereby denying the landlord-tenant relationship. The Supreme Court dismissed the petition, holding that the petitioner failed to prove ownership through the alleged sale agreement or utility bills, which only indicate possession. The Court affirmed that when a tenant disputes the landlord's title, the appropriate forum for resolving such ownership claims is a civil court, not rent proceedings. The principle laid down is that utility bills do not establish property ownership, and a tenant disputing the landlord's title must seek recourse through a separate civil suit.

  Questions settled

  • Do utility bills in the name of an occupant serve as proof of ownership of the property?
  • What is the appropriate legal recourse for a tenant who disputes the ownership of the landlord during eviction proceedings?
  • Can a tenant successfully challenge an eviction petition solely by asserting an unproven claim of ownership?
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• Umar Farooq vs The State & another2025 SHC KHI 1543 · Sindh High Court · 2025-05-26
  rape of a minorsole testimony of victimdelayed FIRcoercive controlmedical corroborationDNA evidencecustodial sexual violence
  Summary & questions settled

  This criminal appeal challenges the judgment of the trial court convicting the appellant under Section 376(3) of the Pakistan Penal Code, 1860, for the rape of a minor girl in his custody and sentencing him to rigorous life imprisonment. The core legal questions involved the sufficiency and credibility of the victim's sole uncorroborated testimony, the legal effect of a delayed FIR caused by coercion and threats, and the implications of a negative DNA report and normal ancillary medical findings in cases of sexual assault against minors. The Sindh High Court dismissed the appeal and held that the minor victim's testimony was sterling, consistent, and inspired confidence, and was sufficiently corroborated by medical evidence of hymnal injury. The court ruled that the absence of seminal fluid or DNA does not negate penetrative assault, particularly where there is a prolonged reporting delay and post-assault hygiene, and that delayed reporting under the psychological influence of continuous threats does not undermine credibility. The court laid down principles regarding the trauma-informed assessment of child testimonies and the evaluation of coercive control in sexual offenses.

  Questions settled

  • Whether the sole testimony of a minor victim is sufficient to sustain a conviction for rape without independent corroboration?
  • Does an unexplained or delayed FIR automatically vitiate the prosecution's case in sexual assault matters involving minors?
  • Whether the absence of seminal fluid or DNA on vaginal swabs disproves the commission of penetrative sexual assault?
  • Can continuous threats made by an abuser against a sibling constitute a valid and legally cognizable justification for delayed disclosure by a child victim?
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• Umar Farooq vs Arshad Malook, etc2025 PHC 254 · Peshawar High Court · 2025-09-09Read full judgment →
• Umar Badshah vs The State and others2025 PHC 74 · Peshawar High Court · 2025-03-20Read full judgment →
• Umar Akbar Ali Ghumman vs Mst. Maria Javed Cheema etc2025 IHC 338 · Islamabad High Court · 2025-04-25Read full judgment →
• Umair Altaf vs The State, etc2025 LHC 3495 · Lahore High Court · 2025-05-15
  post-arrest bailblasphemycognizance of offenceFIR registrationSection 196 CrPCcriminal investigationprohibitory clause
  Summary & questions settled

  This petition sought post-arrest bail for the petitioner, accused of offences under Sections 295-A and 298-A of the Pakistan Penal Code 1860 and Section 11 of the Prevention of Electronic Crimes Act 2016, involving the alleged uploading of blasphemous content. The petitioner challenged the legality of the FIR, arguing that the failure to obtain prior authorization from the government as mandated by Section 196 of the Code of Criminal Procedure 1898 rendered the proceedings void ab initio. The Court addressed whether Section 196 of the Code of Criminal Procedure 1898 requires government sanction for the registration of an FIR and investigation. Holding that Section 196 of the Code of Criminal Procedure 1898 governs the stage of taking judicial cognizance—which occurs only upon the submission of a report under Section 173 of the Code of Criminal Procedure 1898—the Court determined that prior sanction is not a condition precedent for FIR registration or investigation. Consequently, the legal objection was rejected. On merits, given the petitioner's specific naming in the FIR and the recovery of incriminating digital evidence, the bail application was dismissed.

  Questions settled

  • Does the requirement of government sanction under Section 196 of the Code of Criminal Procedure 1898 apply to the registration of an FIR and the conduct of an investigation?
  • At what stage of criminal proceedings must the sanction required by Section 196 of the Code of Criminal Procedure 1898 be obtained?
  • Does the absence of government sanction at the time of FIR registration vitiate the entire criminal proceedings?
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• Umaid Ali and another vs Province of Sindh and others2025 SHC 262 · Sindh High Court · 2025-02-27Read full judgment →
• UBL Fund Management Limited vs Ms. Momy Kamal and another2025 CLD 393 · Securities and Exchange Commission of Pakistan · 2024-07-04Read full judgment →
• Ubed - ur - Rhman vs Province of Sindh and others2025 SHC KHI1940 · Sindh High Court · 2025-07-22Read full judgment →
• U&I Garments (Pvt.) Ltd and Junaid Jamshed (Pvt.) Ltd vs Securities and Exchange Commission of Pakistan2025 SHC KHI 1335 · Sindh High Court · 2025-05-13Read full judgment →
• Transport Operator Union through Representatives and 2 others vs Chairman Transport Authority, Azad Jammu and Kashmir, Muzaffarabad and 13 others2025 PLD High Court (AJ&K) 35 · High Court of Azad Jammu and Kashmir · 2024-10-10Read full judgment →
• Trans World International Inc. (TWI) vs Customs, Federal Excise and Sales2025 PTD 579 · Sindh High Court · 2023-01-30Read full judgment →
• Toufeeque Ahmed vs Federation of Pakistan and others2025 SHC KHI 2111 · Sindh High Court · 2025-08-27Read full judgment →
• Tops Foods and Beverages through General Manager and another vs Rizwan Ali and others2025 PLC 100 · Islamabad High Court · 2024-10-31
  disciplinary proceedingsnatural justiceindustrial disputetermination of serviceworkmanindoor management principleNIRCmisconduct
  Summary & questions settled

  This petition challenges orders passed by the National Industrial Relations Commission (NIRC) which set aside the termination of respondent No. 1, an employee of the petitioner company. The core legal questions concern whether the disciplinary inquiry conducted by the private employer satisfied the requirements of natural justice and whether the NIRC correctly invalidated the dismissal order on grounds of procedural irregularity and lack of authorization. The High Court held that the NIRC’s findings were unsupported by the evidence, which demonstrated that the respondent was served with charge sheets, participated in inquiry proceedings, and was afforded an opportunity to cross-examine witnesses. The Court ruled that disciplinary proceedings by private employers are not criminal trials and do not require the strict procedural adherence of a court of law. The principle of natural justice is satisfied by providing notice and a fair opportunity to defend; there is no legal requirement for a second show-cause notice or personal hearing in private employment. Furthermore, the Court affirmed that the dismissal was duly authorized under the principle of indoor management, thereby setting aside the NIRC’s impugned orders.

  Questions settled

  • Does the principle of natural justice in private disciplinary proceedings require a second show-cause notice or a personal hearing?
  • Are the strict procedural requirements of a criminal trial applicable to disciplinary proceedings conducted by a private employer?
  • Does the principle of indoor management apply to the authorization of dismissal orders by a company?
  • Are the Government Servants (Efficiency and Discipline) Rules, 1973 applicable to private sector employees?
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• Tipu Sultan Cooperative Housing Society Ltd and others vs Province of Sindh & Others2025 SHC KHI 1915, 2025 SHC KHI 1917 · Sindh High Court · 2025-07-21Read full judgment →
• The United Insurance of Company of Pakistan Limited vs Province of Sindh2025 SHC 124 · Sindh High CourtRead full judgment →
• The State, Wasif Saeed, Jannat-ul-Firdous vs Wasif Saeed, The State, etc2025 LHC 773 · Lahore High Court
  criminal appealmurder referencebenefit of doubtocular evidencedelayed FIRrecovery of weaponQatl-e-Amadfalsus in uno falsus in omnibus
  Summary & questions settled

  This criminal appeal challenged the conviction and death sentence of the appellant for the murder of Shakeel Ashraf under Section 302(a) of the Pakistan Penal Code 1860, alongside a murder reference for sentence confirmation and a petition against the acquittal of co-accused. The core legal question was whether the prosecution proved the appellant's guilt beyond reasonable doubt based on the ocular account, medical evidence, and recovery of the weapon. The Lahore High Court held that the prosecution case was riddled with fatal flaws, including an unexplained delay in lodging the FIR and conducting the post-mortem, which indicated a fabricated story. The Court found the ocular testimony of interested witnesses unreliable due to material contradictions and improvements. Furthermore, the recovery of the weapon violated Section 103 of the Code of Criminal Procedure 1898, rendering it inadmissible. The Court established that medical evidence is merely corroborative and cannot identify an assailant. Consequently, the Court acquitted the appellant, answering the murder reference in the negative, and dismissed the petition against the co-accused, emphasizing that a single reasonable doubt entitles an accused to acquittal.

  Questions settled

  • Does an unexplained delay in lodging an FIR and conducting a post-mortem examination create a reasonable doubt regarding the prosecution's story?
  • Can a conviction for murder be sustained solely on medical evidence when the ocular testimony is found to be unreliable?
  • Is the recovery of a crime weapon valid if the investigating officer fails to associate independent witnesses of the locality as required by Section 103 of the Code of Criminal Procedure 1898?
  • Does the acquittal of co-accused on the same set of evidence necessitate the acquittal of the remaining accused under the principle of falsus in uno falsus in omnibus?
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• The State, Waqar Ali vs Waqar Ali, The State2025 LHC 1544 · Lahore High Court · 2025-01-21
  benefit of doubtinjured witnessmedical evidence contradictionocular accountappreciation of evidencerecovery of weaponcriminal appealmurder reference
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence of the appellant for the murder of his relative. The prosecution relied on the ocular account of an injured witness and the recovery of a weapon. The Lahore High Court, upon review, found the prosecution's case fundamentally flawed. Key issues included the reliability of the injured witness, the consistency of the ocular account with medical evidence, and the validity of the recovery proceedings. The Court held that injuries on a witness do not automatically guarantee truthfulness; the testimony must still be scrutinized. Crucially, the Court identified irreconcilable contradictions between the ocular account (alleging a sharp-edged weapon) and the medical evidence (showing lacerated wounds). Furthermore, the failure to secure the alleged source of light (an electric bulb) and the unnatural conduct of the witnesses—who allegedly watched the murder without intervening—rendered their presence doubtful. The Court concluded that the prosecution failed to prove the case beyond a reasonable doubt, set aside the conviction, and acquitted the appellant, emphasizing that even a single reasonable doubt entitles an accused to acquittal as a matter of right.

  Questions settled

  • Does the presence of injuries on a prosecution witness automatically establish the truthfulness of their testimony?
  • Can a conviction be sustained when the ocular account is in direct contradiction with the medical evidence regarding the nature of the weapon used?
  • Is the failure to produce a source of light mentioned in the FIR fatal to the prosecution's case when the occurrence took place at night?
  • Does the failure to comply with Section 103 of the Code of Criminal Procedure 1898 regarding the recovery of a weapon render the recovery evidence inadmissible or unreliable?
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• The State, vs Muhammad Waqas alias Vicky2025 LHC 2972 · Lahore High Court · 2025-04-16
  murder appealbenefit of doubtantedated FIRinquest report discrepanciesunnatural conduct of witnessesweapon recovery reportdeath sentence confirmation
  Summary & questions settled

  This criminal appeal challenges the judgment of the trial court convicting the appellant under Section 302(b) of the Pakistan Penal Code 1860 and sentencing him to death for Qatl-e-Amd, alongside a murder reference for confirmation of the sentence. The core legal questions involved the credibility of the ocular account, delays in reporting the incident, the evidentiary value of antedated police documents and inquest reports, and the reliability of weapon recoveries. The Lahore High Court held that the prosecution miserably failed to prove its case beyond a reasonable doubt due to multiple major contradictions, unnatural conduct of eyewitnesses, tampering with FIR numbers and dates on police records, and compromised safe custody of crime weapons. Consequently, the court laid down that when material infirmities, antedated FIRs, and doubtful circumstances pervade the prosecution narrative, the benefit of the doubt must be extended to the accused as a matter of right. The appeal was accepted, the conviction and death sentence were set aside, and the appellant was acquitted.

  Questions settled

  • Whether material contradictions and unnatural conduct of eyewitnesses are sufficient to create a reasonable doubt in the prosecution's case?
  • Does the tampering of dates and FIR numbers on police documents like inquest reports vitiate the authenticity of the prosecution case?
  • Can a conviction for murder be sustained when the safe custody of recovered crime weapons and forensic parcels is compromised?
  • Is an accused entitled to the benefit of doubt as a matter of right when multiple suspicious circumstances surround the registration of the FIR?
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• The State, Tahir Mahmood alias Tahiri and another,Ikram ul Haq vs Tahir2025 LHC 1434 · Lahore High CourtRead full judgment →
• The State, Shamshad Sanni alias Lallou and three others, Asif Masih, Dawood Masih vs Shamshad Sanni alias Lallou, Sajjad alias Chajju, The State and other2025 LHC 1811 · Lahore High CourtRead full judgment →
• The State, Sajid Ali vs Sajid Ali, The State & another2025 LHC 1689 · Lahore High Court
  blasphemycriminal appealbenefit of doubtcapital sentencedelayed FIRstandard of proofwitness credibilityacquittal
  Summary & questions settled

  This criminal appeal challenged the conviction and death sentence imposed by the trial court under sections 295-C and 298-A of the Pakistan Penal Code 1860 for alleged blasphemy. The core legal question was whether the prosecution had established the appellant's guilt beyond a reasonable doubt, given the evidence presented. The Lahore High Court held that the prosecution's case was fundamentally flawed due to significant, unexplained delays in reporting the incident to the police and recording witness statements under section 161 of the Code of Criminal Procedure 1898. Furthermore, the court noted material contradictions in the testimony of prosecution witnesses and the absence of their names in the site plan, rendering their presence at the scene doubtful. The court emphasized that the prosecution failed to produce trustworthy, consistent evidence, and that suspicion cannot substitute for proof. Consequently, the court acquitted the appellant, applying the principle that if a single circumstance creates reasonable doubt in a prudent mind, the accused is entitled to acquittal as a matter of right, not grace.

  Questions settled

  • Does a significant, unexplained delay in reporting an incident to the police cast doubt on the prosecution's case?
  • What is the legal effect of recording witness statements under section 161 of the Code of Criminal Procedure 1898 with substantial delay?
  • Can a trial court exhibit statements recorded under section 161 of the Code of Criminal Procedure 1898 as evidence during trial?
  • Is an accused entitled to the benefit of the doubt if only a single circumstance creates reasonable doubt in a prudent mind?
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• The State, Saddam Hussain vs Shahid alias Shahidi, The State, etc2025 LHC 864 · Lahore High Court
  murder referenceocular accountchance witnessbenefit of doubtdelayed FIRmedical evidencecapital punishmentcriminal appeal
  Summary & questions settled

  This criminal appeal challenged the conviction and death sentence awarded under Section 302(b) of the Pakistan Penal Code 1860, alongside a murder reference and a revision petition for enhancement of compensation. The core legal questions concerned whether the prosecution established the appellant's guilt beyond reasonable doubt, given the credibility of the ocular account, the impact of significant delays in FIR registration and post-mortem, and the sufficiency of recovery evidence. The Lahore High Court set aside the conviction and death sentence, acquitting the appellant. The court held that the prosecution failed to prove its case due to several critical factors: unexplained delays in reporting the crime and conducting the post-mortem, the status of eyewitnesses as chance witnesses with contradictory testimonies, and a direct conflict between the ocular account and medical evidence regarding the firing distance. The court reaffirmed the principle that a single circumstance creating reasonable doubt entitles an accused to the benefit of the doubt, and that capital punishment cannot be based on the uncorroborated testimony of interested witnesses.

  Questions settled

  • Does a significant delay in lodging an FIR and conducting a post-mortem examination create reasonable doubt regarding the prosecution's case?
  • Can a conviction for a capital offense be sustained solely on the testimony of interested witnesses without independent corroboration?
  • Is the recovery of a crime weapon sufficient to sustain a conviction when the primary ocular evidence is disbelieved?
  • Does a conflict between medical evidence and ocular testimony regarding the distance of firing invalidate the prosecution's version of events?
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• The State, Saadat Hussain vs Saadat Hussain, The State2025 LHC 1892 · Lahore High Court · 2025-03-13
  murder referencecriminal appealbenefit of the doubtocular accountmedical evidenceappraisal of evidenceacquittal
  Summary & questions settled

  This criminal appeal and murder reference arise from a judgment of the trial court convicting the appellant, Saadat Hussain, under sections 302(b), 325, and 109 of the Pakistan Penal Code 1860, and section 13 of the Arms Ordinance 1965, resulting in a death sentence and imprisonment terms. The core legal question before the Lahore High Court was whether the prosecution successfully established the guilt of the accused beyond a reasonable doubt through credible ocular testimony, medical evidence, and corroborative material. The Court held that the testimonies of the alleged eyewitnesses were unnatural, full of major contradictions, and disproved by the physical realities of the crime scene. Furthermore, the prosecution failed to prove recoveries and motive. The High Court established the key principles that the presence of related witnesses must be strictly scrutinized based on natural human conduct, that medical evidence alone cannot identify a culprit, and that a single reasonable doubt entitles the accused to acquittal as a matter of right. Consequently, the appeal was allowed, the conviction was set aside, and the murder reference was answered in the negative.

  Questions settled

  • Whether the conduct of closely related eyewitnesses in failing to intervene during an assault runs contrary to natural human conduct?
  • Can medical evidence alone establish the identity of an accused person in a criminal trial?
  • Does the non-production of natural and material witnesses by the prosecution lead to an adverse inference under the law?
  • What is the legal effect on the prosecution's case when mandatory provisions regarding recoveries under the Code of Criminal Procedure 1898 are violated?
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• The State, Nusrat etc vs Nusrat etc, The State2025 LHC 404 · Lahore High Court
  narcotics controlchain of custodyreverse burden of proofcriminal appealdeath sentencereasonable doubtforensic analysisMalkhana
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence imposed by the Trial Court under Section 9(c) of the Control of Narcotic Substances Act, 1997, for the possession of narcotics. The core legal question concerns whether the prosecution successfully established the chain of custody for the recovered contraband and proved the guilt of the appellants beyond a reasonable doubt. The Lahore High Court held that the prosecution failed to discharge its initial burden of proof. Specifically, the court identified significant gaps in the chain of custody, including the failure to produce the Malkhana Moharrar and contradictions regarding the timing of the sealing of parcels and the arrival of the Investigating Officer. Consequently, the court acquitted the appellants, setting aside the death sentence. The judgment reaffirms that the principle of reverse burden of proof under the Control of Narcotic Substances Act, 1997, only triggers after the prosecution establishes a prima facie case. Furthermore, it emphasizes that any break in the chain of custody renders forensic reports unreliable, and a single reasonable doubt entitles an accused to acquittal as a matter of right.

  Questions settled

  • Does the principle of reverse burden of proof under the Control of Narcotic Substances Act, 1997, apply automatically without the prosecution establishing a prima facie case?
  • What is the legal consequence of a break in the chain of custody of narcotic samples on the reliability of a forensic report?
  • Is the failure to produce the Malkhana Moharrar as a witness fatal to the prosecution's case regarding the safe custody of recovered contraband?
  • Can a single reasonable doubt in the prosecution's evidence entitle an accused to acquittal?
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• The State, Muhammad Saleem vs Muhammad Saleem, The State &2025 LHC 1099 · Lahore High CourtRead full judgment →
• The State, Muhammad Jehangir vs Muhammad Jehangir, The State and anothe2025 LHC 1512 · Lahore High CourtRead full judgment →
• The State, Muhammad Dilawar and another vs Muhammad Dilawar and another, The State2025 LHC 1194 · Lahore High CourtRead full judgment →
• The State, Muhammad Amjad, Muhammad Zahid vs Muhammad Amjad, The State and another, Muhammad Usman etc2025 LHC 317, 2025 MLD 899 · Lahore High Court · 2025-02-17
  murderbenefit of doubteyewitness reliabilitymedical evidenceweapon recoverycriminal appealdeath sentence
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence of the appellant under Section 302(b) of the Pakistan Penal Code 1860, alongside a murder reference and an appeal against the acquittal of a co-accused. The core legal questions involve the reliability of interested eyewitnesses during a night-time occurrence without a source of light, the corroborative value of medical evidence, and the legal effect of non-compliance with Section 103 of the Code of Criminal Procedure 1898 regarding weapon recovery. The Lahore High Court held that the prosecution failed to establish the presence of eyewitnesses, the motive was unproven, and the recovery of the weapon violated mandatory statutory provisions, creating multiple serious doubts in the prosecution case. The court laid down the principles that the prosecution must prove its case beyond a reasonable doubt on its own legs, that medical evidence cannot identify an assailant, and that a single circumstance creating reasonable doubt entitles the accused to the benefit of the doubt, resulting in the acquittal of the appellant and the dismissal of the appeal against the co-accused's acquittal.

  Questions settled

  • Whether medical evidence alone can be used to identify the real assailant in a criminal trial?
  • Does the failure to associate independent witnesses during the recovery of a weapon violate the mandatory provisions of Section 103 of the Code of Criminal Procedure 1898?
  • Can an accused be convicted based on interested eyewitness testimony when the occurrence takes place at night without a specified source of light?
  • What is the effect on the prosecution case when the prime target of an alleged assault is left unhurt by the assailant?
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• The State, Muhammad Abid vs Muhammad Abid, The State2025 LHC 1923 · Lahore High Court · 2025-03-19
  qatl-i-amdchance witnessesmedical contradictionbenefit of the doubtdelayed post-mortemmurder referencecriminal appealrecovery of weapon
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence of the appellant for committing qatl-i-amd under Section 302(b) of the Pakistan Penal Code 1860, along with a murder reference for confirmation. The core legal questions involved the credibility of chance witnesses, the consistency between ocular testimony and medical evidence, and the reliability of supporting recoveries and motive. The Lahore High Court held that the prosecution failed to prove its case beyond a reasonable doubt due to major discrepancies, including the witnesses being unconvincing chance witnesses, irreconcilable conflicts between the number and nature of injuries in the post-mortem report and the oral testimony, unexplained delays in conducting the post-mortem examination, and violation of mandatory procedural provisions regarding weapon recovery. The key legal principle laid down is that where the ocular account is in conflict with medical evidence and witnesses fail to establish their natural presence at the crime scene, the prosecution case collapses, and the accused is entitled to the benefit of the doubt as a matter of right.

  Questions settled

  • Whether the testimony of chance witnesses can be relied upon without convincing and consistent proof of their presence at the place of occurrence?
  • Does a material conflict between ocular testimony and medical evidence regarding the number and nature of firearm injuries vitiate the prosecution's case?
  • What is the evidentiary value of a weapon recovery when mandatory provisions regarding association of independent inhabitants of the locality are violated?
  • Can an unexplained delay in conducting the post-mortem examination raise an adverse inference against the presence of eyewitnesses and prompt lodging of the FIR?
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• The State, Mubashir, Shafqat Abbas vs Mubashir, The State, Zahoor, etc2025 LHC 3004 · Lahore High Court
  benefit of doubtdelayed FIRmurder trialappellate review of acquittalpost-mortem delayreappraisal of evidenceprivate complaint
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence of the appellant recorded by the trial court under Section 302(b) of the Pakistan Penal Code 1860 in a private complaint, alongside connected murder reference and petitions for leave to appeal against acquittals. The core legal questions involved the credibility of eyewitness accounts, the reliability of the prosecution's motive, the implications of delayed First Information Report registration and post-mortem examination, and whether the prosecution proved its case beyond a reasonable doubt. The Lahore High Court held that material contradictions regarding the recording of the First Information Report, unexplained delays in conducting the autopsy, and doubts surrounding the genesis of the occurrence rendered the prosecution's case doubtful. Consequently, the court accepted the appeal, set aside the conviction and sentence, extended the benefit of the doubt to the appellant, and dismissed the petitions against the acquittals. The key principle laid down is that where the prosecution fails to establish a consistent narrative and serious doubts arise concerning the timing of the First Information Report and the authenticity of the motive, the accused is entitled to the benefit of the doubt as a matter of right.

  Questions settled

  • Does an unexplained delay in recording the First Information Report and conducting the post-mortem examination cast sufficient doubt on the authenticity of the prosecution's case?
  • Whether an accused is entitled to the benefit of the doubt as a matter of right when material contradictions exist in the investigative record and medical evidence?
  • Can an appellate court interfere with an order of acquittal when the trial court has provided valid reasons and the judgment does not suffer from perversity or misreading of evidence?
  • Is the uncorroborated testimony regarding motive sufficient to sustain a conviction for murder when the prosecution fails to establish the true genesis of the occurrence?
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• The State, Liaquat Ali, Saeed Ahmed vs Liaquat Ali The State and another2025 LHC 1715 · Lahore High Court
  free fightsudden quarrelculpable homicide not amounting to murdermurder referencedeath sentence conversionsuppression of factsfirearm injuries
  Summary & questions settled

  This criminal appeal and murder reference addressed cross-convictions and death sentences arising from a double murder and firearm assault resulting from prior civil litigation between the parties. The core legal questions revolved around whether the prosecution proved its case beyond a reasonable doubt, whether the incident constituted premeditated murder or a sudden free fight, and whether the appellants were entitled to mitigating circumstances under the law. The Lahore High Court held that both sides withheld material facts, suppressed injuries sustained by the accused, and exaggerated the incident, establishing that the occurrence transpired during a sudden, unpremeditated free fight where both parties anticipated conflict. Consequently, the court converted the convictions under Section 302(b) of the Pakistan Penal Code 1860 to Section 302(c), setting aside the death sentences and sentencing the appellants to fourteen years of rigorous imprisonment, while laying down that cases of sudden mutual affray lacking premeditation and undue advantage attract Exception 4 of the erstwhile Section 300.

  Questions settled

  • Whether a sudden, unpremeditated armed clash where both parties are prepared for conflict constitutes a free fight attracting Exception 4 of Section 300 of the Pakistan Penal Code 1860?
  • Can a conviction under Section 302(b) of the Pakistan Penal Code 1860 be converted to Section 302(c) when the homicide occurs during a sudden quarrel without premeditation?
  • Does the suppression of injuries sustained by the accused and the exaggeration of the prosecution narrative create sufficient doubt to alter the nature of the conviction from premeditated murder to sudden affray?
  • Whether the failure of injured witnesses to attribute specific hurt to particular accused persons warrants acquittal under ancillary assault charges such as Section 324 of the Pakistan Penal Code 1860?
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• The State, Liaquat Ali, Mazhar and another vs Liaquat Ali, The State, The State and another2025 LHC 1597 · Lahore High CourtRead full judgment →
• The State, Atif Pervaiz vs Atif Pervaiz, The State, etc2025 LHC 639 · Lahore High Court · 2025-02-19
  murder referencebenefit of doubtchance witnessescriminal appealsupplementary statementocular evidencepost-mortem delayacquittal
  Summary & questions settled

  This matter concerns a criminal appeal against the conviction and death sentence of the appellant, Atif Pervaiz, for the murder of Muhammad Nawaz, alongside a murder reference for confirmation of the sentence. The trial court had convicted the appellant under Section 302(b) of the Pakistan Penal Code 1860, while acquitting his co-accused. The core legal questions were whether the prosecution had proven the appellant's guilt beyond a reasonable doubt, given the significant delays in reporting the incident and conducting the post-mortem, and whether the ocular evidence was reliable. The Lahore High Court held that the prosecution failed to prove its case. The court identified critical flaws: unexplained delays in the FIR and post-mortem, the status of the eye-witnesses as 'chance witnesses' who failed to justify their presence, and a lack of corroborative evidence. Furthermore, the court noted that the prosecution failed to prove the alleged motive. Consequently, the court acquitted the appellant, extending the benefit of the doubt. The judgment reaffirms the principle that the prosecution must prove its case on its own merits, and any single reasonable doubt entitles the accused to acquittal.

  Questions settled

  • Does a significant delay in the registration of an FIR and the conduct of a post-mortem examination create reasonable doubt in a murder case?
  • Can a conviction be sustained when the prosecution's eye-witnesses are classified as 'chance witnesses' and fail to justify their presence at the scene?
  • Is a supplementary statement recorded after the FIR, which introduces new accused persons, sufficient to sustain a conviction without independent corroboration?
  • Does the failure of the prosecution to prove an alleged motive in a murder case entitle the accused to the benefit of the doubt?
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• The State, Ameer Sultan vs Ameer Sultan, The State and another2025 LHC 1474 · Lahore High Court · 2025-01-16
  Qatl-i-AmdTest identification paradeBenefit of doubtOcular accountCriminal appealAppreciation of evidenceRecoveryMedical evidence
  Summary & questions settled

  This criminal appeal challenged the conviction and death sentence of the appellant for committing Qatl-i-Amd and house trespass under sections 302 and 449 of the Pakistan Penal Code 1860. The core legal questions concerned the reliability of the ocular account, the validity of the test identification parade, and the sufficiency of evidence to sustain a conviction. The Lahore High Court held that the prosecution failed to prove its case beyond a reasonable doubt. The court found the eyewitnesses’ presence doubtful due to their unnatural conduct and lack of corroboration, and the test identification parade was deemed flawed for failing to match the accused's features with the FIR description and lacking procedural compliance. Furthermore, the recovery of the weapon violated section 103 of the Code of Criminal Procedure 1898. Consequently, the court acquitted the appellant, extending him the benefit of the doubt. The judgment reaffirms that medical evidence is merely confirmatory, not corroborative for identity, and that benefit of the doubt is a fundamental right of the accused, not a concession.

  Questions settled

  • Does the failure of eyewitnesses to intervene during a violent crime render their testimony unreliable?
  • Can a conviction be sustained solely on medical evidence when the ocular account is found to be unreliable?
  • What are the legal consequences of failing to comply with Section 103 of the Code of Criminal Procedure 1898 during a recovery?
  • Is a test identification parade valid if the accused's physical description was not recorded in the First Information Report?
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• The State, Ali Raza, Mst. Parveen Rahat vs Ali Raza, The State etc2025 LHC 3913 · Lahore High Court
  criminal appealmurder referencebenefit of doubtchance witnessocular evidencemedical evidenceabscondenceacquittal
  Summary & questions settled

  This criminal appeal and murder reference arose from the conviction and death sentence of the appellant for murder under Section 302(b) of the Pakistan Penal Code 1860. The core legal questions concerned the reliability of the prosecution's ocular account, the evidentiary value of abscondence, and the impact of disbelieving witnesses regarding co-accused persons. The Lahore High Court held that the prosecution failed to prove its case beyond reasonable doubt. The court determined that the alleged eye-witnesses were chance witnesses who failed to establish their presence at the scene, and their testimony was further undermined by medical evidence contradicting the sequence of events. The court ruled that abscondence alone is insufficient for conviction and that disbelieved witnesses cannot be relied upon against other co-accused without independent corroboration. Consequently, the court acquitted the appellant, extending him the benefit of doubt as a matter of right. The principle laid down is that criminal convictions must rest firmly on evidence rather than conjecture, and where reasonable doubt exists, the accused is entitled to acquittal.

  Questions settled

  • Can a conviction be sustained solely on the basis of abscondence when the ocular evidence is disbelieved?
  • Does the testimony of prosecution witnesses, once disbelieved regarding one co-accused, remain reliable against other co-accused without independent corroboration?
  • Is the evidence of a chance witness reliable if they fail to provide a cogent reason for their presence at the crime scene?
  • Can a court rely on high probabilities to convict an accused in a criminal case?
  Read full judgment →
• The State, Aftab and five others vs Aftab, The State and another2025 LHC 1963 · Lahore High Court · 2025-03-11
  free fightsudden quarrelculpable homicide not amounting to murdermitigation of sentencedaman and arshmurder referencebenefit of doubt
  Summary & questions settled

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

  Questions settled

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

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

  Questions settled

  • Can eyewitness testimony be relied upon if the witnesses are 'chance witnesses' who fail to credibly explain their presence at the scene of occurrence?
  • Does the absence of a proven light source at a night-time occurrence render eyewitness identification unreliable?
  • What is the impact of a significant and unexplained delay in lodging the First Information Report (FIR) and conducting the post-mortem examination on the prosecution's case?
  • Are recoveries made in violation of Section 103, Code of Criminal Procedure, admissible as incriminating evidence?
  • Does the burden of proof shift to the accused to explain an unnatural death occurring in their house, even if the prosecution's initial case is weak?
  Read full judgment →
• The State vs Shahzad Ghulam Hussain2025 SHC 680 · Sindh High Court · 2025-05-07
  acquittal appealwildlife protectionfloral resourcesillegal extractionsubordinate legislationburden of proofwild flora and fauna trade
  Summary & questions settled

  The present appeal was directed against the acquittal order passed by the Additional Sessions Judge-XI, Karachi South, in respect of charges under the Sindh Wildlife Protection, Preservation, Conservation and Management Act, 2020 and the Pakistan Trade Control of Wild Fauna and Flora Act, 2012, involving the alleged illegal export and extraction of Gughar Gum / Gughloo resin from protected Commiphora wightii plants. The core legal questions concerned whether the trial court correctly evaluated the statutory prohibitions on floral resource extraction, possession, and trade, and whether subordinate legislation could expand the scope of parent enactments regarding non-listed species. The Sindh High Court held that the prosecution failed to establish the origin of the resin from protected areas or illegal extraction methods, and concurred that subordinate rules cannot enlarge the scope of parent statutes. The appellate court concluded that the acquittal order suffered from no legal infirmity and dismissed the appeal, upholding the acquittal.

  Questions settled

  • Whether subordinate legislation or rules can enlarge the scope of the parent statute?
  • Does the passive collection or natural exudation of resin constitute unlawful extraction of protected floral resources under the Sindh Wildlife Protection, Preservation, Conservation and Management Act, 2020?
  • When does the burden of proof shift onto the accused under Section 38 of the Sindh Wildlife Protection, Preservation, Conservation and Management Act, 2020?
  • Whether penal statutory provisions must be strictly construed in favor of the accused?
  Read full judgment →
• The State vs Nikson Malik s/o Malik Masih2025 SHC 602 · Sindh High Court · 2025-03-27Read full judgment →
• The State vs Muhammad Shafee2025 PHC 38 · Peshawar High Court · 2025-03-06Read full judgment →
• The State vs Imran Ahmad Khan Niazi S/o Ikramullah Khan Niazi, (Ex-Prime2025 Accountability Court 1 · Accountability CourtRead full judgment →
• The State vs ASJ, etc2025 LHC 3544 · Lahore High Court · 2025-04-09
  inter-provincial tradeessential commoditiesconstitutional lawpresidential assentsupardariseizure of goodsPunjab Prevention of Speculation in Essential Commodities Act 2021
  Summary & questions settled

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

  Questions settled

  • Does the Punjab Prevention of Speculation in Essential Commodities Act, 2021 apply to the inter-provincial transportation of essential commodities?
  • Is Presidential assent required for a provincial law that imposes restrictions on inter-provincial trade under Article 151 of the Constitution of Pakistan 1973?
  • Can a provincial authority seize goods in transit between provinces under a statute that lacks the mandatory Presidential assent required by the Constitution?
  Read full judgment →
• The State vs Asif Akhter Hashmi and others2025 IHC 326 · Islamabad High Court · 2025-04-29
  Section 265-K CrPCacquittalmisappropriation of fundsEvacuee Trust Property Boardfair trialprosecution negligenceselective prosecution
  Summary & questions settled

  This appeal challenges an order passed by the Special Judge Central-II, Islamabad, which acquitted the respondents under Section 265-K of the Code of Criminal Procedure 1898 regarding allegations of misappropriating Evacuee Trust Property Board funds. The core legal question was whether the acquittal was sustainable when the prosecution had failed to challenge the prior acquittal of co-accused individuals who held identical roles in the same transaction. The High Court dismissed the appeal, holding that the acquittal was legally sound. The court established that the prosecution cannot selectively target specific board members for a unanimous, joint decision when other participants in the same transaction have already been acquitted without challenge. Furthermore, the court affirmed that Section 265-K, Code of Criminal Procedure 1898 empowers a trial court to acquit an accused at any stage if there is no probability of conviction, regardless of whether a formal charge has been framed. The court emphasized that the right to a fair and timely trial precludes the state from subjecting individuals to indefinite criminal proceedings due to its own negligence and inaction.

  Questions settled

  • Can a trial court acquit an accused under Section 265-K of the Code of Criminal Procedure 1898 before a formal charge has been framed?
  • Is the state precluded from prosecuting specific individuals for a joint decision when co-accused with identical roles have been acquitted without challenge?
  • Does the lack of a formal charge after a significant delay justify the acquittal of an accused under Section 265-K of the Code of Criminal Procedure 1898?
  Read full judgment →
• The State vs Administrative Judge, Anti-Terrorism Courts, Karachi and others2025 SHC 188 · Sindh High Court · 2025-02-18Read full judgment →
• The State through PG Punjab, Lahore vs Judge ATC No.1, Rawalpindi etc2025 SCP 111 · Supreme Court of Pakistan · 2025-04-07
  administrative authoritysuperintendence of courtsjudicial independencetransfer of casesAnti-Terrorism Courtjudicial proprietyconstitutional mandate
  Summary & questions settled

  This matter concerns petitions challenging an order passed by the Chief Justice of the Lahore High Court regarding the transfer of cases from an Anti-Terrorism Court. The State sought the transfer of cases, alleging bias against the Presiding Judge, which the Chief Justice declined, while also recording critical observations regarding the conduct of state functionaries. The Supreme Court addressed whether the Chief Justice acted within his authority and whether the impugned observations were appropriate. The Court held that the Chief Justice, acting under Article 203 of the Constitution, possesses the administrative authority to supervise and regulate subordinate courts, including the responsibility to protect judges from undue executive influence. The Court affirmed that the Chief Justice’s administrative decisions in this regard are not to be disturbed unless they are arbitrary or capricious. Furthermore, the Court clarified that while the Chief Justice’s observations regarding the conduct of state functionaries and judicial officers were made, they lack binding effect and should not prejudice future proceedings, emphasizing that judicial propriety requires circumspection when commenting on the conduct of functionaries without due inquiry.

  Questions settled

  • Does the Chief Justice of a High Court have the authority under Article 203 of the Constitution to supervise and regulate the proceedings of Anti-Terrorism Courts?
  • Are administrative orders passed by a Chief Justice of a High Court regarding the management of subordinate courts subject to interference if they are not shown to be arbitrary or capricious?
  • Do critical observations made by a High Court judge regarding the conduct of state functionaries in an administrative order have binding effect in future proceedings?
  Read full judgment →
• The State through Deputy Prosecutor General Punjab, Multan vs Senior Civil2025 LHC 4418 · Lahore High Court · 2025-06-04Read full judgment →
• The State through Advocate General, Azad Govt. of the State of Jammu2025 SC AJK 6 · Supreme Court of Azad Jammu and KashmirRead full judgment →
• The State through Advocate General Azad Jammu and Kashmir2025 PCRLJ 135 · Supreme Court of Azad Jammu and Kashmir · 2024-05-29
  State appealacquittallimitation periodcriminal procedurestatutory interpretationnarcotics control
  Summary & questions settled

  The appellant, the State, challenged a High Court judgment that dismissed its appeal against an acquittal order on the grounds of being time-barred. The trial court had previously acquitted the respondent in a narcotics case. The High Court had held that the appeal was filed beyond the statutory limitation period. The Supreme Court of Azad Jammu and Kashmir examined the limitation provisions under Section 417 of the Code of Criminal Procedure, 1898. The Court held that the High Court erred in its interpretation. It clarified that Section 417(2-A) of the Code of Criminal Procedure, 1898, which imposes a thirty-day limitation, applies only to "aggrieved persons," while Section 417(2) applies to complainants. Crucially, the Court affirmed that appeals filed by the State under Section 417(1) of the Code of Criminal Procedure, 1898, are not subject to the thirty or sixty-day limits but are governed by Article 157 of the Limitation Act, 1908, which prescribes a six-month limitation period. Consequently, the Court set aside the impugned judgment and remanded the matter to the High Court for decision on the merits.

  Questions settled

  • What is the limitation period for the State to file an appeal against an acquittal order under Section 417(1) of the Code of Criminal Procedure, 1898?
  • Does the thirty-day limitation period prescribed in Section 417(2-A) of the Code of Criminal Procedure, 1898, apply to appeals filed by the State?
  • Are the provisions of the Limitation Act, 1908 applicable to proceedings under the Code of Criminal Procedure, 1898?
  Read full judgment →
• The State through Addl. Attorney General for Pakistan vs Zafar Khan alias2025 PCRLJ 548 · Sindh High Court · 2024-01-22
  criminal transfer applicationanti-terrorism courtfair trialjurisdictionterrorist financingprosecution delaysecurity threats
  Summary & questions settled

  This Criminal Transfer Application was filed by the State under Section 28(1A) of the Anti-Terrorism Act, 1997, seeking to transfer a terrorism case from an Anti-Terrorism Court in Karachi to an Anti-Terrorism Court in Islamabad. The core legal question was whether the prosecution established sufficient grounds, specifically regarding the safety of prosecutors or the interest of justice, to warrant the transfer of the trial. The Sindh High Court dismissed the application, holding that the prosecution failed to provide any material evidence to substantiate allegations of security threats against prosecutors, witnesses, or the presiding judge. The Court emphasized that a court’s jurisdiction must be jealously safeguarded and cannot be ousted based on the mere convenience of a party or unsubstantiated claims. The Court further observed that the application appeared to be a tactic to delay the trial, which would cause undue financial hardship and inconvenience to the accused, thereby violating their right to a fair trial. Consequently, the request for transfer was rejected as meritless.

  Questions settled

  • Can a case be transferred between Anti-Terrorism Courts solely on the ground of the prosecutor's convenience?
  • Is the mere allegation of security threats sufficient to warrant the transfer of a criminal trial without supporting material?
  • Does the transfer of a criminal trial to a distant jurisdiction constitute a denial of a fair trial to the accused?
  • What is the threshold for the High Court to exercise its discretion to transfer a case under Section 28 of the Anti-Terrorism Act, 1997?
  Read full judgment →
• The State through Additional Advocate General Gilgit Baltistan vs Ahmed2025 PCRLJ 120 · Gilgit Baltistan Chief Court · 2024-05-18
  pre-arrest bailcancellation of bailembezzlementequitable remedyjudicial discretiondocumentary evidencecriminal procedure
  Summary & questions settled

  This petition, filed by the State, challenged the order of the Special Judge Anti-corruption, which confirmed pre-arrest bail for the respondent, a former Medical Superintendent accused of massive embezzlement of hospital funds. The core legal question was whether the trial court correctly exercised its discretion in granting this extraordinary relief. The Gilgit Baltistan Chief Court held that the trial court failed to exercise its jurisdiction properly, as it granted bail without recording findings on the existence of a prima facie case, the necessity of arrest, or the potential for irreparable harm. The Court emphasized that pre-arrest bail is an equitable, extraordinary remedy reserved for cases where an innocent person is falsely implicated due to ulterior motives, rather than a routine relief. Finding that the charges were supported by documentary evidence and that the trial court relied on irrelevant grounds, the Court set aside the impugned order and withdrew the judicial protection, allowing the Investigating Officer to proceed with the arrest.

  Questions settled

  • Is pre-arrest bail a routine relief or an extraordinary equitable remedy?
  • What are the essential criteria a court must consider before granting pre-arrest bail?
  • Can pre-arrest bail be granted in cases where the charge is supported by documentary evidence?
  • Does the rule of consistency apply to pre-arrest bail when the co-accused was granted post-arrest bail?
  Read full judgment →
• The State and others vs Muhammad Rafi alias Muhammad Rafique and others2025 LHC 1627 · Lahore High CourtRead full judgment →
• The State and others vs Muhammad Irfan alias Pomi and others2025 LHC 3801 · Lahore High Court
  qatl-i-amdocular testimonymitigating circumstancescourt languageSection 103 CrPCdeath sentence commutationfair trialappreciation of evidence
  Summary & questions settled

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

  Questions settled

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

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

  Questions settled

  • Does the failure of an accused to produce jail records or independent evidence to substantiate a plea of alibi render the plea ineffective?
  • Can a conviction based on the doctrine of common object be sustained when the prosecution fails to prove the shared intent of the accused?
  • Is an accused required to enter the witness box to prove a plea of alibi under the Code of Criminal Procedure 1898?
  • Does the granting of post-arrest bail by the Supreme Court based on a plea of alibi preclude the trial court from evaluating the merits of that plea during the trial?
  Read full judgment →
• The State and another vs Sher Jahan and 3 others2025 MLD 328 · Gilgit Baltistan Chief Court · 2024-11-02
  bail cancellationpre-arrest bailfurther inquirycivil disputedelayed FIRmisuse of bailcriminal procedure
  Summary & questions settled

  This petition was filed under Section 497(5) of the Code of Criminal Procedure 1898 seeking the cancellation of pre-arrest bail granted to the respondents by the Sessions Judge, Gilgit, in a case registered under Section 395 of the Pakistan Penal Code 1860. The core legal question was whether the grounds for cancellation of bail were established. The court observed that the FIR was lodged with a four-month delay without explanation and that the underlying dispute appeared to be of a civil nature involving a vehicle sale transaction, necessitating further inquiry into the guilt of the accused under Section 497(2) of the Code of Criminal Procedure 1898. Furthermore, the court noted that the petitioner failed to demonstrate that the respondents had misused the bail concession, tampered with evidence, or threatened witnesses. Consequently, the court dismissed the petition, holding that the cancellation of bail requires strong, compelling grounds which were absent in this case. The principle laid down is that bail once granted cannot be cancelled absent evidence of misuse of the concession or interference with the administration of justice.

  Questions settled

  • Does a four-month delay in lodging an FIR without explanation justify the cancellation of pre-arrest bail?
  • When does a dispute regarding a vehicle transaction constitute a matter of civil nature requiring further inquiry under Section 497(2) of the Code of Criminal Procedure 1898?
  • What are the essential grounds required for the cancellation of bail once it has been granted by a court of competent jurisdiction?
  Read full judgment →
• The State (ANF) vs Syed Aitemad Hussain Zaidi2025 SHC KHI 1599 · Sindh High Court · 2025-05-30
  Prevention of Smuggling Actfreezing orderbona fide purchaserlimitation periodforfeiture of assetsnarcotics proceedsstatutory notice
  Summary & questions settled

  This Special Criminal Appeal challenged an order by the Special Judge, Customs and Anti-Smuggling, which directed the release of immovable property from a freezing order issued under the Prevention of Smuggling Act, 1977. The core legal questions concerned the maintainability of the appeal regarding statutory limitation and the validity of freezing assets belonging to a bona fide purchaser without prior notice under Section 31 of the Act. The Court held that the appeal was incurably time-barred under Section 43 of the Act, as it was filed beyond the thirty-day limitation period without an application for condonation. On merits, the Court affirmed the trial court's decision, ruling that the failure to serve notice under Section 31 to the registered title holder, whose acquisition predated the freezing order, rendered the forfeiture proceedings ineffective. Relying on the principle of stare decisis, the Court held that procedural safeguards, including notice to actual title holders, are mandatory, and suspicion cannot substitute for proof in forfeiture matters. Consequently, the appeal was dismissed, and the release order was upheld.

  Questions settled

  • Is an appeal filed beyond the thirty-day limitation period under the Prevention of Smuggling Act, 1977 maintainable without an application for condonation of delay?
  • Does the failure to serve a notice under Section 31 of the Prevention of Smuggling Act, 1977 upon a bona fide title holder render the freezing of their property ineffective?
  • Can property acquired by a bona fide purchaser prior to the issuance of a freezing order be forfeited without establishing a nexus between the purchaser and the narcotics trafficker?
  Read full judgment →
• The Province of Punjab through Secretary, Sports & Youth Affairs2025 LHC 794 · Lahore High Court · 2025-02-24
  condonation of delaylimitationland acquisitiongovernment litigationsufficient causetime-barred appealvested rights
  Summary & questions settled

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

  Questions settled

  • Can a government department claim preferential treatment or leniency regarding the law of limitation?
  • Does internal administrative correspondence or delay within a government department constitute sufficient cause for condoning a delay in filing an appeal?
  • Is the court required to condone a delay in filing an appeal if the appellant fails to explain each day of the delay?
  • Does the Limitation Act, 1908 apply to appeals filed under Section 54 of the Land Acquisition Act, 1894?
  Read full judgment →
• The Government of Balochistan through, Additional Chief Secretary2025 SCP 59, 2025 SCMR 656, 2025 PLC (C.S.) 746 · Supreme Court of Pakistan · 2024-12-03
  recruitment processvested rightlegitimate expectationselection committeecivil service appointmentprocedural irregularity
  Summary & questions settled

  The matter concerns a challenge to a High Court judgment that directed the appointment of respondents despite irregularities in the recruitment process. The core legal question is whether candidates possess a vested right to appointment upon recommendation by a selection committee when the process contains significant procedural defects. The Supreme Court held that the High Court erred in directing appointments, as no offer letters had been issued and the recruitment process was fundamentally flawed due to unauthorized changes in post allocation and committee composition. The Court set aside the impugned judgment and dismissed the respondents' petition. The key principles laid down are that a selection committee must strictly adhere to its mandate and the terms of the advertisement; it cannot unilaterally add or subtract posts. Furthermore, the mere recommendation of a candidate does not create a vested right to employment, and the doctrine of legitimate expectation cannot be invoked to sustain a recruitment process that violates statutory rules and established procedures.

  Questions settled

  • Does a candidate acquire a vested right to appointment merely upon being recommended by a selection committee?
  • Can a selection committee add or subtract posts during the recruitment process beyond what was advertised?
  • Is the doctrine of legitimate expectation applicable to validate a recruitment process that is fundamentally flawed?
  • Does the mere submission of an application for a recruitment process create a vested right to claim a job?
  Read full judgment →
• The Director, Directorate of Intelligence and Investigation Customs vs Ajab2025 PTD 226 · Sindh High Court · 2024-05-30Read full judgment →
• The Director, DG I&I-IR, Sales Tax House, Karachi vs The State & another2025 SHC 346 · Sindh High Court · 2025-03-13
  money launderingpredicate offenceconcealment of incomeincome taxSpecial Judge Customsjurisdictionproceeds of crime
  Summary & questions settled

  This appeal under section 23 of the Anti-Money Laundering Act, 2010 challenged an order of the Special Judge (Customs, Taxation & Anti-Smuggling) returning a complaint filed under section 21(2) of the Act for alleged money laundering and predicate offences under sections 192 and 192A of the Income Tax Ordinance, 2001. The core legal question was whether a money laundering complaint is maintainable under the Anti-Money Laundering Act, 2010 without the formal prosecution or existence of a validly established predicate offence, particularly when the respondent had not filed income tax returns or been subjected to proceedings under the Income Tax Ordinance, 2001. The Sindh High Court held that the commission of a predicate offence is a sine qua non for the offence of money laundering, and since the respondent had never filed returns or documents under the Income Tax Ordinance, 2001, no predicate offences under sections 192 and 192A of the said Ordinance were made out, rendering the money laundering complaint misconceived. The appeal was accordingly dismissed.

  Questions settled

  • Whether the commission of a predicate offence is a sine qua non for the prosecution of an offence of money laundering?
  • Does a Special Judge (Customs) have jurisdiction to try an offence of money laundering predicated on offences under the Income Tax Ordinance, 2001?
  • Can a complaint for money laundering under section 21(2) of the Anti-Money Laundering Act, 2010 be maintained when no proceedings or prosecution for the underlying predicate offences have been initiated?
  • Do sections 192 and 192A of the Income Tax Ordinance, 2001 apply to a person who has never filed an income tax return or furnished documents under the Ordinance?
  Read full judgment →
• The Commissioner-Inland Revenue, Corporate Zone, RTO, Peshawar vs M_s. Peshawar Electric Supply Company Ltd. (PESCO), WAPDA House, Shami Road, PeshawarPTCL 2025 CL. 546 · Appellate Tribunal Inland Revenue · 2024-11-07Read full judgment →
• The Commissioner of Inland Revenue, Peshawar vs M/s Sufi Tahir Nadeem2025 SCP 236 · Supreme Court of Pakistan · 2025-06-24
  Fast Moving Consumer Goodsminimum taxtax liabilitystatutory interpretationturnover taxconsumer goods definition
  Summary & questions settled

  This matter concerns tax references filed by the Commissioner of Inland Revenue against a taxpayer regarding the classification of goods for minimum tax purposes. The core legal question was whether the respondent's products—specifically Bopp Composite/Plain Film, Pet Film, CPP Metalized Film, and CPP Milky Film—qualified as 'Fast Moving Consumer Goods' (FMCG) under the Income Tax Ordinance, 2001, thereby entitling the taxpayer to a reduced minimum tax rate of 0.2% instead of 1%. The Supreme Court held that the goods in question are primarily industrial or commercial packaging materials used in the production of other goods, rather than items consumed directly by end consumers. Consequently, the Court ruled that these products do not meet the statutory definition of FMCG provided in Section 2(22A) read with Section 2(13AB) of the Ordinance. The Court established the principle that for goods to qualify as FMCG, they must be supplied in the retail market for daily consumer demand and be intended for direct consumption, rather than serving as components in the production of other finished goods.

  Questions settled

  • Do industrial packaging films qualify as 'Fast Moving Consumer Goods' under Section 2(22A) of the Income Tax Ordinance 2001?
  • Are goods used in the production of other products considered 'consumer goods' under Section 2(13AB) of the Income Tax Ordinance 2001?
  • Does the definition of 'Fast Moving Consumer Goods' exclude durable goods under the Income Tax Ordinance 2001?
  Read full judgment →
• The Commissioner Inland Revenue. RTO, Faisalabad vs Mr. Zohaib Ali2025 LHC 5557 · Lahore High Court · 2025-09-08Read full judgment →
• The Commissioner Inland Revenue, Lahore vs M_s Eagle Cables (Pvt) Ltd, Lahore2025 SCP 38, PTCL 2025 CL. 329, 2025 PTD 635, 2025 SCMR 728 · Supreme Court of Pakistan · 2025-01-16
  sales taxinput tax adjustmentfake invoicesblacklisted supplierbanking channelFBR portal verification
  Summary & questions settled

  This petition for leave to appeal arose from an order of the High Court passed under Section 47 of the Sales Tax Act 1990, concerning the adjustment of input tax claimed by a taxpayer. The core legal issue was whether a taxpayer can be held to have violated Section 8(1)(d) of the Sales Tax Act 1990 by claiming input tax adjustments based on alleged fake invoices issued by suppliers who were active at the time of purchase but subsequently blacklisted or suspended. The Supreme Court dismissed the Revenue's petition and refused leave to appeal. The Court held that where purchases are executed in good faith from active, registered suppliers whose status was verified on the Federal Board of Revenue portal, and payments are processed through legitimate banking channels in compliance with Section 73 of the Sales Tax Act 1990, the transactions are not invalidated by subsequent blacklisting. Pursuant to Section 21(3) of the Act, purchasers who procure goods prior to a supplier's suspension or blacklisting remain entitled to input tax adjustments.

  Questions settled

  • Can a taxpayer be denied input tax adjustment solely based on the subsequent blacklisting or suspension of its supplier?
  • Does compliance with Section 73 banking channel requirements protect a taxpayer's entitlement to input tax adjustment under the Sales Tax Act 1990?
  • Whether invoices issued by a duly registered supplier become automatically invalidated if the supplier is blacklisted at a later date?
  Read full judgment →
• The Commissioner Inland Revenue Zone-II, Regional Tax Office vs M/s.2025 SHC 606 · Sindh High Court · 2025-04-16Read full judgment →
• The Commissioner Inland Pakistan Ltd vs M/s. Byco Petroleum RevenuePTCL 2025 CL. 28 · Supreme Court of Pakistan · 2024-07-05
  default surchargesales taxstrict liabilitywillful defaulttax penaltyfinance act
  Summary & questions settled

  This case pertains to tax periods between February 2016 and December 2017, where penalties under Section 33 and additional default surcharge under Section 34 of the Sales Tax Act, 1990 were imposed due to late filing of income tax returns. The assessing authority, appellate tribunal, and the High Court previously held that the taxpayer was not liable because the default was not willful. The core legal question before the Supreme Court was whether the default surcharge under Section 34 of the Sales Tax Act, 1990 operates as a strict liability provision post-amendment by the Finance Act, 2005. The Supreme Court held that Section 34, containing the phrase 'whether willfully or otherwise', is a strict liability provision that applies regardless of whether the default was deliberate or inadvertent, thereby setting aside the High Court's judgment on this point. However, regarding penalties under Section 33, where the High Court failed to evaluate the impact of the statutory framework, the matter was remanded back to the High Court for fresh decision. The key principle laid down is that Section 34 of the Sales Tax Act, 1990 is a strict liability clause.

  Questions settled

  • Whether Section 34 of the Sales Tax Act, 1990 operates as a strict liability provision after the insertion of the phrase 'whether willfully or otherwise'?
  • Does the imposition of default surcharge under Section 34 of the Sales Tax Act, 1990 require proof of deliberate or willful default by the taxpayer?
  • Can the matter regarding the imposition of penalties under Section 33 of the Sales Tax Act, 1990 be remanded to the High Court for a fresh decision when left unaddressed?
  Read full judgment →
• The Collector of Customs vs Power Link Petroleum Services and another2025 PTD 377 · Sindh High Court · 2021-03-15Read full judgment →
• The Collector of Customs vs M/s. JW SEZ (Pvt.) Ltd., LahorePTCL 2025 CL. 506 · Sindh High Court · 2024-02-22Read full judgment →
• The Collector of Customs vs Abdul Nasir Shah and another2025 PTD 288 · Sindh High Court · 2024-02-18Read full judgment →
• The Collector of Customs (West) vs M/s. Seminar (Pvt) Limited2025 SHC 198, PTCL 2025 CL. 404 · Sindh High Court · 2025-01-23Read full judgment →
• The Chief Administrator of Auqaf, Punjab, Lahore and 02 others vs Muhammad Panah Nomani and 20 others2025 LHC 259 · Lahore High CourtRead full judgment →
• The Bank of Punjab vs M/s Hira Textile Mills Limited and 08 others2025 LHC 3488 · Lahore High Court · 2025-05-14Read full judgment →
• The Bank of Punjab vs M/s Agri International & 05 others2025 LHC 887 · Lahore High Court · 2025-03-18Read full judgment →
• The Bank of Azad Jammu and Kashmir through attorney holders vs Muhammad Ramzan Abbasi and 4 others2025 MLD 794 · Supreme Court of Azad Jammu and Kashmir · 2024-10-14Read full judgment →
• Thardeep Microfinance Foundation through its Authorize Person namely2025 SHC MPK 1732 · Sindh High Court · 2025-06-03
  dishonored chequeSection 22-A Cr.P.C.civil disputecriminal process misuseclean hands doctrineFIR registrationSection 489-F PPC
  Summary & questions settled

  This Criminal Miscellaneous Application, filed under Section 561-A of the Code of Criminal Procedure 1898, challenged an order by the Ex-Officio Justice of Peace dismissing a petition for the registration of an FIR under Section 489-F of the Pakistan Penal Code 1860. The core legal question was whether the High Court should compel police to register an FIR in a dispute involving a dishonored cheque issued as a loan guarantee, where the underlying debt had been partially repaid. The Court held that the application was devoid of merit and dismissed it. It reasoned that the dispute was essentially civil in nature, concerning loan recovery and accounting, rather than a criminal matter. Furthermore, the Court noted that the applicant had suppressed the material fact of partial loan repayment, failing to approach the Court with clean hands. The Court affirmed that the criminal justice system should not be misused to exert pressure for civil recoveries, emphasizing that courts must not mechanically direct FIR registration in disputes that are primarily contractual or monetary in nature.

  Questions settled

  • Can the High Court direct the registration of an FIR under Section 22-A and 22-B of the Code of Criminal Procedure 1898 when the underlying dispute is essentially a civil matter?
  • Does the suppression of material facts, such as partial loan repayment, disentitle an applicant from seeking relief under Section 561-A of the Code of Criminal Procedure 1898?
  • Is a dispute involving a dishonored cheque issued as a loan guarantee automatically a criminal matter under Section 489-F of the Pakistan Penal Code 1860, or can it be treated as a civil recovery matter?
  Read full judgment →
• TCS etc vs Muhammad Siddique Ghumman etc2025 LHC 3888 · Lahore High Court · 2025-06-03Read full judgment →
• Tasleem Hussain (decd) through L.R.s and others vs Allahdad Shah and others2025 SCMR 387 · Supreme Court of Pakistan · 2024-10-15
  heirship disputeidentity disputeburden of proofcivil revisionleave to appealfactual controversyparentageofficial record correction
  Summary & questions settled

  The Supreme Court heard civil petitions for leave to appeal arising from two rounds of litigation concerning a dispute over heirship and the identity of two individuals: Sharif Shah son of Mehar Shah and Sharif Ali Shah alias Sharif Shah son of Riasat Ali Shah. The core legal question was whether these two individuals were one and the same person. The High Court had previously held that they were two different persons, a finding upheld by the Additional District Judge and subsequently by the High Court in later proceedings. The Supreme Court affirmed the High Court's consolidated judgment, dismissing the petitions for leave to appeal. The Court held that the burden of proof for asserting a fact, such as identity or parentage, lies with the party making the assertion, and that mere assertions in official records, without documentary or oral evidence or a declaration from a competent court, lack credibility. The petitioners failed to discharge this burden.

  Questions settled

  • Does the burden of proof for asserting a factual identity (e.g., of a deceased person) lie with the party making the assertion?
  • Can a mere assertion regarding parentage in official records be given credibility without a declaration from a competent court or correction by authorities?
  • Can a party succeed in claiming an identity without producing documentary or oral evidence to prove such an assertion?
  • Whether a court can interfere with findings of fact by lower appellate courts if there is no misreading or non-reading of evidence or jurisdictional error?
  Read full judgment →
• Tarique Mubeen vs Province of Sindh through Secretary Government of Sindh and 3 others2025 PLC (C.S.) 136 · Sindh High Court · 2024-05-07
  age relaxationcombined competitive examinationspsccivil servantsconstitutional petitionjudicial review
  Summary & questions settled

  This constitutional petition arose from an advertisement issued by the Sindh Public Service Commission for recruitment to BPS-17 posts through a Combined Competitive Examination, which the petitioner challenged for failing to provide upper age relaxation. The core legal question was whether the petitioner was entitled to an upper age relaxation under Rule 12 of the Sindh Civil Servants (Appointment, Promotion and Transfer) Rules, 1974, despite a policy notification excluding posts filled through combined competitive examinations from such relaxation. The court held that the Government of Sindh validly excluded posts filled through combined competitive examinations from upper age relaxation via the notification, and delay in holding examinations does not warrant judicial interference in policy matters absent bad faith. The key principle laid down is that the High Court cannot substitute its view for executive policy decisions regarding age relaxation unless arbitrariness or ill-will is proven.

  Questions settled

  • Whether Rule 12 of the Sindh Civil Servants (Appointment, Promotion and Transfer) Rules, 1974 allows upper age relaxation for posts filled through Combined Competitive Examinations during the restricted period?
  • Can the High Court substitute its own view for a policy decision of the government regarding age relaxation?
  • Does inordinate delay in conducting competitive examinations form a sufficient legal basis to compel age relaxation without proof of ill-will?
  Read full judgment →
• Tarique Hussain and others vs Province of Sindh and others2025 SHC SUK 1706 · Sindh High Court · 2025-05-15Read full judgment →
• Tariq Rehman Chohan vs The State and another2025 LHC 5337 · Lahore High Court · 2025-08-18
  post-arrest bailcriminal breach of trustdishonest chequemistaken bank transferprohibitory clauseimplied entrustment
  Summary & questions settled

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

  Questions settled

  • Does the receipt of funds mistakenly transferred into a bank account constitute 'entrustment' under Section 405 of the Pakistan Penal Code 1860?
  • Can a joint charge for offenses under Section 489-F and Section 406 of the Pakistan Penal Code 1860 be brought against an accused?
  • Is bail a matter of right in cases not falling within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  Read full judgment →
• Tariq Mehmood, Shazia Munir, Zarai Taraqiati Bank Limited vs Shazia Munir2025 IHC 440 · Islamabad High Court
  sexual harassmentworkplace harassmentprobationary employeereinstatementjurisdictional overreachFederal Ombudsmandelay in reportingcorroborative evidence
  Summary & questions settled

  This judgment decides multiple interlinked writ petitions challenging the orders of the Federal Ombudsman for Protection Against Harassment of Women at the Workplace and the President's Secretariat. The respondent, a probationary officer at Zarai Taraqiati Bank Limited (ZTBL), was terminated from service during her probation. Following her termination, she filed a complaint under the Protection Against Harassment of Women at the Workplace Act, 2010, alleging sexual harassment by her immediate supervisor (the petitioner). The Ombudsman found the petitioner guilty, imposed a major penalty of removal from service, and ordered the respondent's reinstatement. The High Court set aside the Ombudsman's orders, holding that the complainant failed to provide any corroborative evidence, independent witnesses, or CCTV footage, and that her 14-day delay in reporting, coinciding with her termination, cast serious doubt on the complaint's veracity. Crucially, the Court ruled that the Federal Ombudsman lacks the statutory jurisdiction under the Act of 2010 to order the reinstatement of an employee or interfere with departmental disciplinary proceedings.

  Questions settled

  • Does the Federal Ombudsman for Protection Against Harassment of Women at the Workplace have the statutory jurisdiction to reinstate an aggrieved person back into service?
  • What is the legal effect of an unexplained delay in reporting workplace harassment when the complaint coincides with the employee's termination?
  • Can a probationary employee's services be terminated without assigning any reason under the Zarai Taraqiati Bank Limited Staff Regulations 2005?
  • Whether an order of the Ombudsman finding an employee guilty of harassment can be sustained solely on uncorroborated allegations without independent witnesses or available surveillance footage?
  Read full judgment →
• Tariq Mehmood vs The State2025 SCP 75, 2025 SCMR 780 · Supreme Court of Pakistan · 2025-02-24
  criminal appealdeath sentencejudicial confessionbenefit of doubtforensic evidencechain of custodyacquittalprocedural irregularity
  Summary & questions settled

  This criminal appeal challenged the High Court's judgment affirming the death sentence of the appellant for murder. The core legal questions concerned the validity of the appellant's judicial confession, the integrity of the forensic evidence, and the sufficiency of the prosecution's proof regarding motive. The Supreme Court found that the prosecution's case was fundamentally flawed due to procedural irregularities in recording the confession, such as failing to allow the accused time for reflection or conducting a physical examination for torture. Additionally, the Court noted significant lapses in the chain of custody, specifically the simultaneous submission of crime empties and the weapon to the Forensic Science Laboratory. The Court also highlighted the absence of a proven motive and the reliance on hearsay evidence. Holding that these lacunae rendered the prosecution's case doubtful, the Court set aside the lower courts' judgments and acquitted the appellant. The judgment reaffirms the principle that any material loophole in the prosecution's case necessitates extending the benefit of doubt to the accused, ensuring the safe administration of criminal justice.

  Questions settled

  • Does the simultaneous submission of crime empties and the alleged weapon to a forensic laboratory invalidate the forensic report?
  • What are the legal consequences of a Judicial Magistrate failing to allow an accused time for reflection before recording a confession?
  • Is a conviction sustainable when the prosecution fails to establish a motive for the alleged crime?
  • Does the failure to follow procedural formalities in recording a confession under Section 364 of the Code of Criminal Procedure 1898 render the confession inadmissible?
  Read full judgment →
• Tariq Mehmood vs Inspector General of Police and 4 others2025 PLJ Lahore 630 · Lahore High Court · 2025-03-13Read full judgment →
• Yasir Mehmood vs Jamshed Ahmed Subhani & Another2025 IHC 128 · Islamabad High Court · 2025-02-25
  dishonest issuance of chequecriminal liabilityburden of proofmens reaacquittal appealnegotiable instrumentdishonour of cheque
  Summary & questions settled

  This criminal appeal challenged the acquittal of the respondent by the trial court in a case registered under Section 489-F, Pakistan Penal Code 1860, concerning the dishonor of a cheque. The core legal question was whether the prosecution successfully established the essential ingredients of the offence, specifically the dishonest intent and the issuance of the cheque for the repayment of a loan or fulfillment of an obligation. The High Court dismissed the appeal, holding that the prosecution failed to prove these fundamental elements. The court observed that the complainant provided no written agreement or documentary evidence to substantiate the alleged financial obligation, and the respondent’s claim that the cheque was provided as security remained plausible. The court affirmed that mere dishonor of a cheque does not automatically create criminal liability under Section 489-F, Pakistan Penal Code 1860, without proof of the underlying obligation and dishonest intent. Consequently, the appellate court found no illegality in the trial court's acquittal, as the prosecution failed to prove its case beyond reasonable doubt.

  Questions settled

  • Does the mere dishonor of a cheque automatically create criminal liability under Section 489-F, Pakistan Penal Code 1860?
  • What are the essential ingredients required to prove an offence under Section 489-F, Pakistan Penal Code 1860?
  • Can a conviction under Section 489-F, Pakistan Penal Code 1860 be sustained in the absence of proof regarding the underlying obligation or loan?
  Read full judgment →
• Tariq Mehmood Aamir vs Government of the Punjab2025 LHC 3368 · Lahore High Court · 2025-05-15Read full judgment →
• Tariq Khan, Aman Ullah vs Additional Director General (North), Federal2025 SCP 48, 2025 SCMR 453, 2025 PLC (C.S.) 467 · Supreme Court of Pakistan · 2024-11-07
  compulsory retirementdepartmental inquirymisconductinefficiencynatural justicecross-examinationde novo inquirycivil servantfair trialprocedural lapse
  Summary & questions settled

  This judgment addresses civil petitions for leave to appeal against a Federal Service Tribunal decision upholding the compulsory retirement of two civil servants, Tariq Khan and Aman Ullah. The petitioners, an ASI and a Head Constable, were charged with misconduct and inefficiency for clearing passengers with fake Schengen Visas at Bacha Khan International Airport. The core legal question was whether the departmental inquiry, which led to their major penalty, violated principles of natural justice, specifically by denying them the right to cross-examine witnesses. The Supreme Court found that no opportunity was provided to the petitioners for cross-examination, which is a fundamental right and an unavoidable obligation of an inquiry officer. The Court also noted inconsistencies in punishment among five indicted officials. The Court held that such a procedural lapse sabotages the disciplinary proceedings. Consequently, the petitions were converted into appeals and allowed, the impugned judgment was set aside, and the matter was remanded for a de novo inquiry to be completed within three months, ensuring ample opportunity for defence.

  Questions settled

  • Is the right to cross-examine witnesses a fundamental aspect of natural justice in departmental inquiries?
  • Can a major penalty like compulsory retirement be imposed based on a departmental inquiry that denies the right of cross-examination?
  • What are the grounds for ordering a de novo inquiry in disciplinary proceedings?
  • Do procedural lapses and violations of natural justice in a departmental inquiry warrant setting aside the imposed penalty?
  • What powers are conferred upon an Inquiry Officer or Inquiry Committee under the Government Servants (Efficiency & Discipline) Rules, 1973?
  Read full judgment →
• Tariq Hussain Umrani vs The State2025 SHC 728 · Sindh High Court · 2025-04-30Read full judgment →
• Tariq Aziz vs Federation of Pakistan & others2025 SHC KHI 2145 · Sindh High Court · 2025-08-26Read full judgment →
• Tariq Ali vs Hilal Shah2025 CLC 348 · Peshawar High Court · 2022-04-21Read full judgment →
• Tariq Abbas Khan vs Federation of Pakistan, Pakistan Navy (PNS), etc2025 IHC 250 · Islamabad High Court · 2025-04-21Read full judgment →
• Tario alias Tara Chand vs The State2025 YLR 707 · Sindh High Court · 2024-02-15
  post-arrest bailprohibitory clauserule of consistencydelay in FIRItlaf-i-udwattributable rolecriminal jurisprudence
  Summary & questions settled

  This is a criminal bail application filed before the Sindh High Court by the applicant, Tario alias Tara Chand, seeking post-arrest bail in Crime/FIR No. 44/2023 registered at Police Station Khahi for offences under sections 324, 334, 114, and 34 of the Pakistan Penal Code. The core legal question concerns whether the applicant is entitled to post-arrest bail given the specific attribution of a hatchet blow resulting in the traumatic amputation of the victim's hand, falling under the prohibitory clause of section 497 of the Code of Criminal Procedure, and whether the rule of consistency applies when co-accused have been granted bail. The court held that the applicant was specifically nominated with a distinct and grievous role corroborated by medical evidence and eyewitness accounts, bringing his case within the prohibitory clause, and that the rule of consistency is inapplicable due to distinguishable roles. Consequently, the High Court dismissed the bail application, laying down that disparate roles among co-accused preclude the application of the rule of consistency and that delay in lodging an FIR does not warrant bail when satisfactorily explained and identity is established.

  Questions settled

  • Whether an accused charged with an offence falling within the prohibitory clause of section 497 of the Code of Criminal Procedure 1898 is entitled to post-arrest bail when specifically nominated with a role causing grievous injury?
  • Does the rule of consistency or parity apply to grant bail to an accused whose role is distinguishable from co-accused who have already been granted bail?
  • Is a delay in lodging the First Information Report automatically a ground for granting post-arrest bail when a plausible explanation is furnished and the culprit's identity is not in doubt?
  Read full judgment →
• Tanvir Hussain vs The State2025 SCP 62, 2025 SCMR 776 · Supreme Court of Pakistan · 2025-02-20
  leave to appealmurdercompromiseDiyatminor legal heirsDiyat Arsh and Daman Fund Rules 2007installments of Diyat
  Summary & questions settled

  This petition for leave to appeal arose from a conviction under Section 302(b) of the Pakistan Penal Code 1860, wherein the petitioner was sentenced to death for murder, which was later modified to life imprisonment by the Lahore High Court due to unproven motive. The petitioner challenged his conviction and sought acceptance of an out-of-court compromise. The Supreme Court of Pakistan evaluated whether a compromise could be accepted when the share of Diyat belonging to a minor legal heir had not been secured due to the convict's financial incapacity.

  The Supreme Court dismissed the petition, upholding the conviction and life imprisonment. The Court held that a compromise remains incomplete and legally unexecutable if the share of minor legal heirs in Diyat is not fully protected and secured. The Court emphasized that minor legal heirs' statutory rights cannot be compromised away. Regarding the petitioner's inability to pay Diyat, the Court clarified that he may apply under Section 331 of the Code of Criminal Procedure 1898 for payment in installments or seek financial recourse through the administrative committee constituted under the Diyat, Arsh and Daman Fund Rules, 2007.

  Questions settled

  • Can a compromise in a murder case be sanctioned if the share of Diyat due to a minor legal heir is not secured?
  • What remedies are available to a convict who is financially incapable of paying the full Diyat amount immediately?
  Read full judgment →
• Tanveer Ahmed vs The State2025 IHC 320 · Islamabad High Court · 2025-04-23
  narcotics smugglingconscious possessionchain of custodyrepresentative samplingjail appealchemical examiner reportcontrol of narcotic substances
  Summary & questions settled

  This jail appeal arises from a judgment passed by the Trial Court convicting the appellant under Section 9(c) of the Control of Narcotic Substances Act, 1997, and sentencing him to rigorous imprisonment for life along with a fine. The core legal question involved was whether the prosecution successfully established the recovery of a large quantity of narcotics, the safe chain of custody, and conscious possession beyond a reasonable doubt. The Islamabad High Court dismissed the appeal and upheld the conviction, holding that the testimonies of the prosecution witnesses, compliance with representative sampling principles, unbroken chain of custody, and positive FSL reports conclusively proved the charge. The key principles laid down include the application of the doctrine of conscious possession regarding illicit substances found within a vehicle under a defendant's control, the requirement for an unbroken chain of custody in narcotics cases, and the adherence to representative sampling procedures.

  Questions settled

  • Does the person in control of a vehicle bear the burden under the doctrine of conscious possession for illicit substances found therein?
  • Is an unbroken chain of custody from the place of recovery to the forensic laboratory essential in narcotics cases?
  • Can a mere denial in a statement under Section 342 of the Code of Criminal Procedure 1898 displace convincing prosecution evidence when the accused fails to examine himself under Section 340(2)?
  • What is the effect of complying with representative sampling procedures on the admissibility of chemical analysis reports?
  Read full judgment →
• Tamrez vs DPO Nowshera and others2025 P Cr. L J 905 · Peshawar High Court · 2024-11-29
  illegal detentionpolice high-handednessJustice of the Peaceregistration of FIRcognizable offenceinter-provincial arrestconstitutional safeguardscriminal writ petition
  Summary & questions settled

  This criminal writ petition addressed police high-handedness involving the alleged unlawful arrest and detention of the petitioner's brother by local police officials without following statutory procedures for inter-provincial arrests, followed by the District Police Officer's failure to act and the ex-officio Justice of the Peace's erroneous direction for an inquiry rather than ordering the registration of a criminal case. The core legal questions revolved around the legality of the arrest in violation of fundamental rights, the scope of powers of a Justice of the Peace under Section 22-A of the Code of Criminal Procedure, 1898, and the appropriate legal consequences for police misconduct. The Peshawar High Court held that the arrest and detention were illegal and in violation of constitutional safeguards, and that a Justice of the Peace cannot order an inquiry instead of directing the registration of an FIR when information discloses a cognizable offence. The court established that police officials must strictly adhere to statutory procedures like Section 86 of the Code of Criminal Procedure, 1898, when executing arrests, and that a Justice of the Peace must order FIR registration upon disclosure of a cognizable offence rather than ordering a police inquiry.

  Questions settled

  • Whether the arrest and detention of a person without following the mandatory procedure for inter-provincial arrests under the Code of Criminal Procedure, 1898, is illegal and violates fundamental constitutional rights?
  • Does an ex-officio Justice of the Peace have the power to order a police inquiry into a complaint instead of directing the registration of a criminal case when the information discloses the commission of a cognizable offence?
  • What are the legal duties of an officer in charge of a police station upon receiving information regarding the commission of a cognizable offence?
  • Whether police officials can be held criminally and administratively accountable for carrying out arbitrary arrests without a warrant or lawful justification?
  Read full judgment →
• Talib Hussain, etc vs Faiz Alam, etc2025 IHC 18, 2025 PLJ Islamabad 97, 2025 CLC 970 · Islamabad High Court · 2025-02-03Read full judgment →
• Talib Hussain vs Muhammad Akram2025 LHC 4613 · Lahore High Court · 2025-06-20Read full judgment →
• Taj Wali Khan vs Hukam Khan (decd) through LRs2025 SCMR 231, 2025 PLJ SC 94 · Supreme Court of Pakistan · 2024-11-06
  pre-emption suitlimitation periodfraud and concealmentpleadingscivil revisionconcurrent findings
  Summary & questions settled

  This civil appeal challenges the judgment and decree of the Peshawar High Court, which accepted a revision petition and dismissed the appellant's pre-emption suit after setting aside the concurrent decrees of the lower courts. The core legal question revolves around whether the pre-emption suit was barred by limitation and whether the benefit of extension of limitation under section 18 of the Limitation Act, 1908 on the grounds of fraud and concealment could be invoked without being initially pleaded. The Supreme Court dismissed the appeal, holding that a pre-emption suit filed after 122 days from the attestation of mutation is barred by time under Section 31 of the Khyber Pakhtunkhwa Pre-emption Act, 1987, which prescribes a 120-day limitation period. The Court laid down the principle that the plea of fraud and the consequential extension of limitation under Section 18 of the Limitation Act, 1908 must be specifically pleaded in the plaint from the very inception and established through evidence, and cannot be raised for the first time as a mixed question of fact and law without prior foundational pleadings.

  Questions settled

  • Whether a pre-emption suit filed after 120 days from the date of attestation of mutation is barred by limitation under Section 31 of the Khyber Pakhtunkhwa Pre-emption Act, 1987?
  • Can the benefit of Section 18 of the Limitation Act, 1908 regarding the computation of limitation from the date of knowledge due to fraud be claimed without being specifically pleaded in the plaint?
  • Whether a fresh plea involving a mixed question of law and fact, not raised before the trial court or appellate courts, can be entertained for the first time before the Supreme Court?
  Read full judgment →
• Taj Muhammad Detho vs Senior Civil Judge Rato Dero & others2025 SHC LAR 1499 · Sindh High Court · 2025-05-19Read full judgment →
• Taj Muhammad and 19 others vs Provincial Government through Chief2025 MLD 630 · Gilgit Baltistan Chief Court · 2024-10-31Read full judgment →
• Tahir Mehmood & 2 others vs The State & another2025 PHC 268 · Peshawar High Court · 2025-07-09Read full judgment →