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.

• Noor Agha vs The State & another2025 SCP 249 · Supreme Court of Pakistan · 2025-04-15
  statutory delaypost-arrest bailthird provisofourth provisohardened desperate or dangerous criminalcontinuous detentionmurder trial delay
  Summary & questions settled

  Criminal appeal by leave against the High Court's judgment refusing post-arrest bail on the ground of statutory delay in a case involving murder and abduction under Sections 302, 365, and 34 of the Pakistan Penal Code 1860. The petitioner was continuously detained for over two years without conclusion of trial, and the delay was not attributable to him. The High Court had declined statutory bail under the 4th proviso to Section 497(1) of the Code of Criminal Procedure 1898, holding that the petitioner was a 'hardened, desperate or dangerous criminal' merely based on the gravity of the offence. The Supreme Court allowed the appeal and granted bail, ruling that the exception under the 4th proviso cannot be applied subjectively or based solely on the nature of the charged offence. The Court held that an opinion declaring an accused a hardened, desperate, or dangerous criminal requires sufficient, objective material placed by the prosecution demonstrating a substantial risk or high probability of serious harm to society upon release.

  Questions settled

  • Can a court classify an accused as a 'hardened, desperate or dangerous criminal' under the 4th proviso to Section 497(1) of the Code of Criminal Procedure 1898 based solely on the gravity and nature of the charged offence?
  • What evidentiary standard and material are required for a court to form an opinion that an accused poses a substantial risk to society under the 4th proviso to Section 497(1) of the Code of Criminal Procedure 1898?
  • Does previous rejection of bail on merits preclude an accused from claiming bail on the independent ground of statutory delay under the 3rd proviso to Section 497(1) of the Code of Criminal Procedure 1898?
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• Noman s/o Abdul Razzak vs The State2025 SHC KHI 1682, 2025 SHC KHI 1687 · Sindh High Court · 2025-05-29
  narcotics possessionprovincial vs federal jurisdictionsentencing discretionfirst-time offenderstatutory interpretationcriminal appealnarcotic drug
  Summary & questions settled

  This criminal appeal challenged a conviction under the Control of Narcotic Substances (Amendment) Act, 2022, for possessing 1150 grams of charas. The appellant, arrested by provincial police, contended that the trial court erred in applying the Federal Amendment Act, 2022, arguing that the Control of Narcotic Substances (Sindh Amendment) Act, 2021, was the applicable legislation for provincial police actions. The core legal question was whether the Federal Amendment Act, 2022, exclusively superseded the provincial amendment for all narcotics offences or if they operated concurrently based on the arresting agency. The Court held that the two statutes are not mutually exclusive; the Federal Amendment Act, 2022, empowers federal agencies, while the Sindh Amendment Act, 2021, governs provincial police actions. Consequently, the Court converted the conviction to the appropriate provincial provision. Furthermore, emphasizing the principle of reformation for first-time offenders, the Court reduced the appellant's sentence from nine years to four years, maintaining the fine and the benefit of section 382-B, Code of Criminal Procedure 1898.

  Questions settled

  • Does the Control of Narcotic Substances (Amendment) Act, 2022, repeal the Control of Narcotic Substances (Sindh Amendment) Act, 2021?
  • Which narcotics legislation applies when an arrest is made by provincial police rather than a federal agency?
  • Can a court reduce a sentence based on the lack of prior criminal record of the accused?
  • Do the Federal Amendment Act, 2022, and the Sindh Amendment Act, 2021, operate concurrently?
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• Noman Saleem vs Rehmat Elahee & others2025 SHC 378 · Sindh High Court · 2025-03-13Read full judgment →
• Noman Liaqat Proprietor of M.H. Traders vs Federation of Pakistan and others2025 SHC KHI 1969 · Sindh High CourtRead full judgment →
• Nizam ud Din vs Additional District Judge etc2025 LHC 2300 · Lahore High Court · 2025-04-07Read full judgment →
• Nisar Hussain Shaikh vs Province of Sindh and others2025 SHC 322 · Sindh High Court · 2025-03-07
  proforma promotionretrospective promotionvested right to promotioncivil servicesuperannuationprovincial selection boardwrit jurisdiction
  Summary & questions settled

  The petitioner, a retired Senior Chest Specialist (BS-19), filed a constitutional petition seeking a declaration that the Health Department's failure to consider him for promotion to Chief Chest Specialist (BS-20) was illegal, and prayed for proforma promotion from the date of occurrence of the vacancy with back benefits. The court examined whether a civil servant has a vested right to promotion and whether proforma promotion can be granted post-retirement in the absence of statutory provisions. The Sindh High Court held that promotion is not a vested right and that the petitioner's case had been duly considered by the Provincial Selection Board I but regretted due to lack of vacancies in his category (Diploma Holder Doctors). Furthermore, the court held that proforma promotion post-retirement is alien to the Sindh Civil Servants Act, 1973 and the Sindh Civil Servants (Appointment, Promotion and Transfer) Rules, 1974, and that the proviso to Fundamental Rule 17 allowing such benefit was omitted prior to petitioner's retirement. The petition was accordingly dismissed.

  Questions settled

  • Whether promotion is a vested right of a civil servant?
  • Can a retired civil servant claim proforma or retrospective promotion in the absence of express statutory provisions under the civil service laws?
  • Does the High Court have jurisdiction to grant proforma promotion when a civil servant's case was considered and regretted for want of vacancy?
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• Nisar Ahmed Managing Partner M/S Master Pipe vs Federation of Pakistan2025 SHC KHI 1905 · Sindh High CourtRead full judgment →
• Niaz Muhammad vs The State and another2025 PLD Balochistan 92 · Balochistan High Court · 2023-10-23
  criminal revisionSection 540 Cr.P.C.acquitted accusedprosecution witnessaccomplice testimonytender of pardonwithdrawal of prosecution
  Summary & questions settled

  This criminal revision petition challenged the Trial Court's order dismissing the petitioner's application under Section 540 of the Code of Criminal Procedure, 1898, which sought to summon an acquitted co-accused as a prosecution witness. The core legal question was whether an accused, already acquitted following a compromise, could be compelled or permitted to testify as a prosecution witness against a remaining co-accused under the court's general powers to summon witnesses. The High Court dismissed the petition, holding that the Trial Court correctly refused the application. The Court reasoned that the Code of Criminal Procedure, 1898 provides specific, exclusive mechanisms—namely Sections 337, 338, and 494—for utilizing an accused as a witness. The principle laid down is that the prosecution cannot bypass these statutory requirements by invoking the general discretionary power under Section 540 to summon an acquitted accused. Consequently, an accused acquitted via compromise cannot be compelled to appear as a prosecution witness against a co-accused, as the law mandates strict adherence to the prescribed procedural exceptions for accomplice testimony.

  Questions settled

  • Can an acquitted co-accused be summoned as a prosecution witness under Section 540 of the Code of Criminal Procedure 1898?
  • Does the general power to summon witnesses under Section 540 of the Code of Criminal Procedure 1898 override the specific statutory requirements for accomplice testimony?
  • Is an accused acquitted via compromise compellable as a witness against a co-accused?
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• Niaz Muhammad Jalbani and another vs The State through Chairman NAB2025 P Cr. L J 853 · Sindh High Court · 2022-10-27
  accountability appealacquittal appealrule of consistencyburden of proofbenefit of doubtmisappropriation of fundscorruption and corrupt practicesdouble presumption of innocence
  Summary & questions settled

  This matter involves two criminal accountability appeals arising from a single judgment of the Accountability Court, Sukkur. The first appeal challenges the conviction of Niaz Muhammad Jalbani for corruption and corrupt practices under the National Accountability Ordinance, 1999, while the second appeal, filed by the State, challenges the acquittal of co-accused Azizullah Panhwar. The core legal questions concern whether the prosecution proved its case beyond reasonable doubt, the applicability of the rule of consistency when co-accused are acquitted on the same evidence, and the burden of proof in accountability cases. The High Court held that the prosecution failed to produce unimpeachable evidence against the appellant, noting that key prosecution witnesses exonerated him or provided contradictory testimony. Furthermore, applying the rule of consistency, the Court found that the appellant was entitled to acquittal given that the trial court had disbelieved the same evidence regarding the co-accused. The Court reaffirmed that while the Ordinance allows for presumptions of guilt, the initial burden remains on the prosecution to establish a reasonable case before any burden shifts to the accused.

  Questions settled

  • Does the rule of consistency require the acquittal of a co-accused if the prosecution evidence against them has been disbelieved by the trial court?
  • Does the presumption of guilt under Section 14 of the National Accountability Ordinance 1999 absolve the prosecution of its initial burden to prove a reasonable case?
  • What is the scope of interference by an appellate court in an appeal against an acquittal judgment?
  • Can a conviction be sustained solely on secondary evidence when the primary evidence is found to be forged or fictitious?
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• Niaz Hussain S/o Fakir Muhammad Siyal vs The State2025 SHC LAR 1841 · Sindh High Court · 2025-07-01
  criminal appealabductionfair trialSection 342 CrPCSection 540 CrPCbenefit of doubtdue processexculpatory evidence
  Summary & questions settled

  This criminal appeal challenged the conviction of the appellant for abduction and related offenses under the Pakistan Penal Code 1860. The core legal questions concerned whether the trial court committed procedural irregularities by allowing additional prosecution witnesses under Section 540 of the Code of Criminal Procedure 1898 without notice, and whether the failure to record a fresh statement under Section 342 of the Code of Criminal Procedure 1898 after the introduction of new incriminating evidence violated the right to a fair trial. The High Court held that the trial court’s failure to provide the accused an opportunity to be heard regarding additional witnesses and its failure to confront the accused with all incriminating evidence rendered the conviction unsustainable. The court emphasized that Section 342 of the Code of Criminal Procedure 1898 mandates a direct examination of the accused regarding all incriminating material, and that adopting prior statements is legally insufficient. Furthermore, the court ruled that ignoring exculpatory evidence, such as a prior Constitutional Petition filed by the victim, created reasonable doubt, necessitating the appellant's acquittal.

  Questions settled

  • Does the failure to record a fresh statement under Section 342 of the Code of Criminal Procedure 1898 after the introduction of additional evidence vitiate a conviction?
  • Can a trial court allow an application under Section 540 of the Code of Criminal Procedure 1898 without issuing notice to the accused?
  • Is the adoption of a previously recorded statement under Section 342 of the Code of Criminal Procedure 1898 through a written submission by defense counsel legally sufficient?
  • Does the failure to consider exculpatory evidence, such as a previously filed Constitutional Petition, entitle an accused to the benefit of doubt?
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• Niamat Ali Khan vs Provincial Housing Authority of Khyber Pakhtunkhwa2025 PHC 218 · Peshawar High CourtRead full judgment →
• New Jubilee Insurance Company Ltd. vs Active Apparels Intl. (Pvt.) Ltd.2025 SHC 538 · Sindh High Court · 2025-04-24Read full judgment →
• Nek Muhammad Baloch vs Province of Sindh & Others2025 SHC 652 · Sindh High Court · 2025-04-09Read full judgment →
• Nazir Ahmad etc vs The learned Additional District Judge, Kasur etc2025 LHC 2015 · Lahore High Court · 2025-02-20Read full judgment →
• Nazim Ahmed vs The Commissioner I.R. (Appeals-VII) CTO, Kar.& anr2025 SHC 276 · Sindh High Court · 2025-03-04Read full judgment →
• Nazia Saddique vs Additional District Judge, etc2025 LHC 2078 · Lahore High Court · 2025-03-06Read full judgment →
• Nazeer Ahmed Bhaan vs Administrator, T.M.O. Dokri2025 SHC LAR 2099 · Sindh High Court · 2025-08-21Read full judgment →
• Nazeer Ahmed Baloch vs The State & others2025 SHC 168 · Sindh High Court · 2025-02-24
  criminal miscellaneous applicationdirect complaintwithdrawal of applicationalternative remedycriminal procedure
  Summary & questions settled

  This criminal miscellaneous application was brought before the Sindh High Court by the applicant, Nazeer Ahmed Baloch, seeking legal redress. The core legal question concerned the appropriate forum and procedure for the ventilation of the applicant's grievances regarding the subject matter of the dispute. Upon hearing the matter at some length, the learned counsel for the applicant did not press the application. Instead, the counsel stated an intention to withdraw the petition in order to pursue an alternative statutory remedy before the competent court of law by filing a criminal direct complaint. The court accepted this stance and disposed of the application accordingly. The key principle laid down is that a party may seek to withdraw a miscellaneous application to avail alternative statutory remedies such as filing a direct complaint under the relevant provisions of the procedural law.

  Questions settled

  • Can an applicant withdraw a criminal miscellaneous application to pursue a direct complaint?
  • Whether an aggrieved person can exhaust remedies before a competent court under Section 200 of the Code of Criminal Procedure 1898 after withdrawing a misc application?
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• Nazar Muhammad Jokhio vs he State and Seven (7) Others2025 SHC KHI 1500 · Sindh High Court · 2025-05-20
  FIR registrationEx-Officio Justice of Peacecognizable offenceproperty disputecriminal procedurepolice powers
  Summary & questions settled

  This criminal miscellaneous application challenged an order passed by the Ex-Officio Justice of Peace, which directed the police to register an FIR based on a complaint regarding a property dispute. The core legal question was whether the Ex-Officio Justice of Peace, when exercising powers under Section 22-A and 22-B of the Code of Criminal Procedure 1898, is required to articulate a reasoning process—similar to that of the police—to determine if the information discloses a cognizable offence before mandating the registration of an FIR. The Court held that the impugned order was unsustainable because it lacked a reasoned evaluation of whether the complaint revealed a cognizable offence and failed to consider the police's role in the initial assessment of such information. The Court set aside the order, confirming that the Justice of Peace must perform a judicial evaluation of the complaint rather than issuing a summary direction. The key principle laid down is that the Ex-Officio Justice of Peace must articulate the specific thought process and legal basis for concluding that a cognizable offence is made out before directing the police to register an FIR.

  Questions settled

  • Is the Ex-Officio Justice of Peace required to articulate a reasoning process before directing the registration of an FIR?
  • Does the Ex-Officio Justice of Peace have the authority to bypass the police's initial assessment of whether a complaint discloses a cognizable offence?
  • Can an order directing the registration of an FIR be sustained if it fails to specify the penal provision under which the offence is cognizable?
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• Nazar Muhammad and others vs The State through NAB and others2025 YLR 342 · Sindh High Court · 2024-05-23
  National Accountability Ordinanceamenity plotslayout plan revisioncooperative housing societysecondary evidencebenefit of the doubtcorrupt practicesbona fide purchasers
  Summary & questions settled

  This criminal appeal challenges the judgment of the Accountability Court at Hyderabad convicting the appellants under Section 10 of the National Accountability Ordinance, 1999 for alleged illegal revision of a housing society's layout plan, conversion of amenity plots to commercial plots, and subsequent irregular allotments and sales causing loss to the public exchequer. The core legal questions involved whether secondary evidence of layout plans was admissible, whether the National Accountability Bureau had jurisdiction over a private cooperative housing society without loss to the government exchequer, and whether criminal intent and pecuniary advantage were established against the administrators, regulators, and beneficiary purchasers. The Sindh High Court held that the prosecution failed to prove its case beyond a reasonable doubt, as the original and revised layout plans were unproven and inadmissible secondary evidence under Articles 72 to 74 of the Qanun-e-Shahadat Order 1984, no financial loss to the government was proved, and essential elements of mens rea and personal pecuniary advantage were lacking. The court laid down the principle that criminal convictions under accountability laws require strict proof of financial benefit, proven criminal intent (mens rea), and admissible primary or secondary documentary evidence rather than mere procedural irregularities or unproven photocopies.

  Questions settled

  • Whether uncertified photocopies of layout plans are admissible as secondary evidence under Articles 72 to 74 of the Qanun-e-Shahadat Order 1984 to prove the illegal conversion of amenity plots?
  • Does the National Accountability Bureau have jurisdiction to prosecute administrative irregularities in a self-financed private cooperative housing society where no loss to the government exchequer is established?
  • Can a conviction for corruption and corrupt practices be sustained under the National Accountability Ordinance, 1999 in the absence of proof regarding personal pecuniary advantage and criminal intent (mens rea)?
  • Are bona fide purchasers of plots through open auction entitled to acquittal when co-accused beneficiaries facing identical allegations have been acquitted?
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• Nazar alias Chand and another vs The State and others2025 YLR 596 · Lahore High Court · 2024-01-25
  criminal appealbenefit of doubtocular accountindependent corroborationacquittal of co-accusedmurderSection 161 CrPCappreciation of evidence
  Summary & questions settled

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

  Questions settled

  • Can eye-witnesses who are disbelieved regarding some accused persons be relied upon to convict other co-accused without independent corroboration?
  • Does the acquittal of co-accused based on the same ocular evidence necessitate the acquittal of remaining accused in the absence of independent corroboration?
  • What is the legal effect of a delay in recording statements under Section 161 of the Code of Criminal Procedure 1898 without a plausible explanation?
  • Can the prosecution rely on the weaknesses of the defence to prove its case?
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• Nazakat Ali vs Raja Shoukat Ali and others2025 CLC 933 · High Court of Azad Jammu and Kashmir · 2024-11-29Read full judgment →
• Nawabzada Muhammad Khisro Khan and another vs Mst. Aneesa Bibi and others2025 PHC 148 · Peshawar High CourtRead full judgment →
• Nawabzada Muhammad Fateh Khan vs Mumtaz Ahmad and others2025 SCP 101, 2025 SCMR 912 · Supreme Court of Pakistan · 2024-12-02
  pre-emptionlimitationTalb-i-Muwathibatattestation of mutationdate of knowledgedeclaratory suit
  Summary & questions settled

  This civil petition for leave to appeal arose from a pre-emption suit filed by the petitioner and a proforma respondent against a sale mutation. The trial court decreed the suit, but the appellate court and the High Court reversed this decision, dismissing the suit on the grounds of limitation and non-performance of the requisite talbs. The Supreme Court of Pakistan examined whether the limitation period of 120 days under Section 31 of the Khyber Pakhtunkhwa Pre-emption Act, 1987, commenced from the date of attestation of the mutation or from the date of the pre-emptor's prior knowledge of the sale. The Court held that the sale was legally completed when the vendor's statement was recorded prior to the attestation, and because the petitioner had filed an earlier declaratory suit challenging the transaction, they possessed prior knowledge of the sale. Consequently, the limitation period commenced under Section 31(d) from the date of knowledge, and subsequent attestation did not create a fresh cause of action. The Court also found the performance of Talb-i-Muwathibat to be concocted, thereby affirming the dismissal of the suit.

  Questions settled

  • Does a subsequent attestation of a mutation give rise to a fresh cause of action for a pre-emption suit if the pre-emptor already had prior knowledge of the sale?
  • How is the limitation period calculated under Section 31 of the Khyber Pakhtunkhwa Pre-emption Act 1987 when multiple eventualities are present?
  • What is the legal effect on a pre-emption claim if the pre-emptor fails to perform the immediate jumping demand of Talb-i-Muwathibat upon acquiring knowledge of the sale?
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• Nawab vs Ihsan Ali Khan and 3 others2025 MLD 633 · Sindh High Court · 2024-12-31
  illegal dispossessionlawful occupiersale agreementpart performancecriminal revisionconcurrent civil and criminal proceedingsdue process of law
  Summary & questions settled

  This criminal revision application impugns the order of the Additional Sessions Judge dismissing a complaint filed under the Illegal Dispossession Act, 2005. The applicant alleged he purchased landed property through a sale agreement, was handed possession upon part payment, and was subsequently forcibly dispossessed by the respondent. The trial court had dismissed the complaint on the grounds that the dispute was of a civil nature and the respondent was not a land grabber. The Sindh High Court held that a person in possession pursuant to a valid sale agreement is a lawful occupier protected by law, that forceful eviction without due process of law is illegal, that the provisions of the Illegal Dispossession Act apply universally and are not restricted solely to professional land grabbers, and that the pendency of civil litigation is no bar to criminal proceedings under the Act. The impugned order was set aside and the trial court was directed to proceed with the matter.

  Questions settled

  • Whether a person in possession of immovable property under an agreement to sell qualifies as a lawful occupier under the Illegal Dispossession Act, 2005?
  • Do the provisions of the Illegal Dispossession Act, 2005 apply exclusively to professional land grabbers and land mafias?
  • Does the pendency of civil litigation between the parties bar the initiation or maintenance of criminal proceedings under the Illegal Dispossession Act, 2005?
  • Can a vendor forcibly retake possession of property from a vendee on the pretext of default in payment without resorting to a court of law?
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• Nawab Khan vs The State and 6 others2025 YLR 715 · Sindh High Court · 2024-10-04Read full judgment →
• Nawab Khan Kalhoro and 3 others vs The State2025 YLR 981 · Sindh High Court · 2024-12-30
  pre-arrest bailfurther inquiryprohibitory clauseunexplained delaynon-vital partsmala fideprevious enmity
  Summary & questions settled

  This common order disposes of two pre-arrest bail applications arising from a single crime registered under Sections 337-F(v), 337-F(iii), 337-F(i), 114, 148, 149, and 504 of the Pakistan Penal Code 1860. The prosecution alleged that the applicants, armed with iron bars and lathies, intercepted and injured the complainant's brother. The applicants argued that the First Information Report was delayed by twelve days without explanation, the roles assigned were general, the injuries were on non-vital body parts, and the offences did not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898. The High Court observed that the injuries were on non-vital parts, the maximum punishment did not exceed five years, and the inordinate delay in lodging the FIR remained unexplained. Furthermore, the existence of a prior dispute indicated potential ulterior motives and mala fides. Applying established precedents, the Court held that the case required further inquiry and confirmed the interim pre-arrest bail.

  Questions settled

  • Whether an unexplained delay of twelve days in lodging a First Information Report can support a case for further inquiry in a bail application?
  • Can pre-arrest bail be confirmed where the alleged injuries are on non-vital body parts and the offences do not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Does the existence of a prior dispute between parties satisfy the requirement of showing potential mala fides or ulterior motives for granting pre-arrest bail?
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• Nawab @ Naboo Chandio, Mohammed Ali Chandio vs The State2025 SHC LAR 1610, 2025 SHC LAR 1611 · Sindh High Court · 2025-05-30Read full judgment →
• Naveed Anjum vs The Secretary, Revenue Division, Islamabad2025 PTD 272 · Federal Tax Ombudsman · 2022-07-28Read full judgment →
• Naveed Ahmed vs The State2025 IHC 238 · Islamabad High Court · 2025-04-14
  narcotics possessionheroin recoveryofficial witnesseschemical analysis samplesafe custody of malkhanaprevious conviction
  Summary & questions settled

  This common judgment disposes of a criminal appeal and a jail appeal filed against the trial court's judgment whereby the appellant was convicted under Section 9(1)(6)(c) of the Control of Narcotic Substances Act, 1997 and sentenced to ten years rigorous imprisonment along with a fine for the possession of 1455 grams of heroin. The core legal questions involved the credibility of official witnesses without independent corroboration, the sufficiency of a one-gram representative sample for chemical analysis, the mandatory versus directory nature of the timeframe for dispatching samples, and the establishment of safe custody and transmission of the contraband. The Islamabad High Court held that testimonies of police officials are as good as those of private witnesses, a one-gram sample is legally sufficient if accepted by the laboratory, and the timeline rules for sending samples are directory rather than mandatory. The court dismissed the appeals, ruling that the prosecution proved its case beyond a reasonable doubt, and maintained the conviction and sentence.

  Questions settled

  • Whether the testimony of police officials can be relied upon without independent corroboration in narcotics cases?
  • Is a one-gram representative sample sufficient for chemical analysis under the Control of Narcotic Substances Act, 1997?
  • Whether the time limit prescribed under Rule 4 of the Control of Narcotic Substances (Government Analysts) Rules, 2001 for sending samples to the laboratory is mandatory or directory?
  • Does the failure to associate private witnesses at the time of arrest render the prosecution's case doubtful?
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• Nauman Qasim Paracha & Others vs Sindh Building Control Authority &2025 SHC 2 · Sindh High Court · 2025-01-15Read full judgment →
• National Police Foundation vs Capital Development Authority and others2025 IHC 530 · Islamabad High Court · 2025-07-17Read full judgment →
• National Highways Authority vs Petrosin Services Harro River (Pvt) Ltd2025 IHC 550 · Islamabad High Court · 2025-06-30Read full judgment →
• National Highway Authority vs M/S Kingcrete Builders & Another2025 IHC 148 · Islamabad High Court · 2025-03-18Read full judgment →
• National Highway Authority vs M/S Hussain Cotex Limited & Another2025 IHC 88, 2025 CLD 598 · Islamabad High Court · 2025-02-25Read full judgment →
• National Highway Authority etc vs Ghulam Ali (deceased) through legal2025 LHC 1376, 2025 PLJ Lahore 587 · Lahore High CourtRead full judgment →
• National Highway Authority and others vs Syed Altaf Hussain Shah2025 YLR 129 · Lahore High Court · 2024-05-16Read full judgment →
• National Food Limited vs Collector of Customs in all SCRAs Model Customs2025 SHC 734 · Sindh High CourtRead full judgment →
• National Commission for Human Rights of Pakistan vs United Bank Limited2025 IHC 66 · Islamabad High Court · 2025-02-11
  National Commission for Human Rightsstatutory jurisdictionpension disputehuman rights violationintra-court appealservice rightsadministrative overreach
  Summary & questions settled

  This Intra-Court Appeal challenged a judgment that set aside an order issued by the National Commission for Human Rights (NCHR). The core legal question was whether the NCHR possesses the statutory jurisdiction to adjudicate or issue directives regarding pension disputes involving private sector employees of a commercial bank. The Court held that the NCHR is a statutory body established to investigate human rights violations, particularly those involving public servants. It determined that pension disputes, being contractual and statutory in nature, fall outside the NCHR's mandate and must be adjudicated by specialized forums or courts. The Court affirmed that while the right to a dignified life is a fundamental right, the NCHR cannot overreach its authority to resolve private employment disputes. Consequently, the Court dismissed the appeal, ruling that the NCHR's directive to enhance the pension amount was beyond its statutory jurisdiction and legally unsustainable, while preserving the employee's right to seek redress in an appropriate legal forum.

  Questions settled

  • Does the National Commission for Human Rights have the jurisdiction to adjudicate pension disputes involving private sector employees?
  • Is the National Commission for Human Rights empowered to issue directives regarding the enhancement of pension amounts?
  • Can the National Commission for Human Rights intervene in matters governed by private sector labour laws and employment contracts?
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• National Bank of Pakistan vs Federation of Pakistan & Others2025 SHC 698 · Sindh High Court · 2025-02-20Read full judgment →
• National Bank of Pakistan through its President, Karachi and others vs Muhammad Shafiq, Muhammad Tahir2025 SCP 155 · Supreme Court of Pakistan · 2025-01-09
  Master and servant ruleTermination of serviceReinstatementLeave to appealJudicial precedentContract of serviceEquityCorporate employment
  Summary & questions settled

  The Supreme Court considered two leave petitions filed by the National Bank of Pakistan against its former employees, whose services had been terminated. The employees had successfully challenged their termination in civil courts, securing reinstatement, with the Bank's subsequent appeals and revision petitions being dismissed. The core legal question before the Supreme Court was whether the long-standing 'master and servant' rule, as established in Malik and Haq and another v Muhammad Shamsul Islam Chowdhury PLD 1961 SC 531, which generally precludes reinstatement in contractual employment relationships, remains fit for purpose. The Court observed that the economic and corporate landscape has drastically changed since 1961, rendering the traditional rule potentially outmoded and rigid. It emphasized that equity requires flexibility for the law to evolve with time. Consequently, the Supreme Court granted leave to appeal to fundamentally reappraise this rule and determine if it requires modification, replacement, or substitution by a larger bench.

  Questions settled

  • Whether the 'master and servant' rule, precluding reinstatement in contractual employment, remains fit for purpose in modern times?
  • Whether the principle laid down in Malik and Haq and another v Muhammad Shamsul Islam Chowdhury PLD 1961 SC 531 requires modification or replacement?
  • Can a court order reinstatement of an employee in a master-servant relationship?
  • Should the law governing employment relationships in large corporations be re-evaluated in light of economic changes?
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• Natasha Danish vs The State2025 P Cr. L J 919 · Sindh High Court · 2024-09-30
  post-arrest bailfurther inquirynarcoticsProhibition (Enforcement of Hadd) Orderbail as punishmentcriminal procedure
  Summary & questions settled

  This matter concerns a post-arrest bail application filed by the applicant, Natasha Danish, who was charged under Section 11 of the Prohibition (Enforcement of Hadd) Order, 1979, following an incident involving alleged intoxication with Methamphetamine (Ice). The applicant had previously been acquitted in a related case involving reckless driving due to a compromise. The core legal question was whether the applicant was entitled to bail given the nature of the charges, the conflicting medical reports, and the statutory sentencing limits. The Court held that the case warranted further inquiry, noting a contradiction between the blood report, which showed no narcotics, and the urine report, which detected Methamphetamine. Furthermore, the Court observed that the maximum sentence for the charged offence is three years, and bail should not be withheld as punishment. Emphasizing the applicant's status as a mother of three and the fact that the investigation was complete, the Court granted post-arrest bail. The key principle laid down is that where evidence is contradictory and the maximum sentence is relatively low, bail should be granted unless exceptional circumstances exist, as bail cannot be used as a punitive measure.

  Questions settled

  • Does a contradiction between blood and urine reports regarding the presence of narcotics constitute a case of further inquiry for the purpose of bail?
  • Can bail be withheld as a form of punishment before the conclusion of a trial?
  • Is a person entitled to bail when the maximum sentence for the charged offence is three years and no exceptional circumstances exist?
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• Nasrullah alias Nasru vs The State, etc2025 LHC 822, PLJ 2025 Cr.C. 418 · Lahore High Court · 2025-03-13
  post-arrest bailattempt to commit qatl-i-amdprohibitory clausefemoral artery injuryabscondence of accusedfirearm injuryforensic science laboratory
  Summary & questions settled

  This order arises from a post-arrest bail petition filed by the petitioner/accused in a case registered under Sections 324 and 34 of the Pakistan Penal Code 1860, with Section 337-F(iii) subsequently added. The prosecution alleged that the petitioner fired two successive shots with a .44-bore rifle hitting both thighs of the complainant's brother. The primary legal questions were whether the petitioner was entitled to post-arrest bail considering his abscondence and whether Section 324 PPC was prima facie attracted where firearm injuries were inflicted on the thighs. The Lahore High Court dismissed the bail petition, holding that reasonable grounds connected the petitioner to the alleged offence, corroborated by the victim's statement, medical certification, weapon recovery, and matching forensic analysis. The Court laid down that while firearm injuries below the knee may warrant further inquiry under Section 497(2) Cr.P.C. regarding intent to kill, injuries inflicted above the knee at the thigh prima facie attract Section 324 PPC due to the life-threatening risk associated with damage to the femoral artery.

  Questions settled

  • Whether Section 324 of the Pakistan Penal Code 1860 is prima facie attracted when a firearm injury is caused to the thigh above the knee?
  • Does an injury caused below the knee necessitate further inquiry under Section 497(2) of the Code of Criminal Procedure 1898 regarding the applicability of Section 324 PPC?
  • Can an accused's abscondence and declaration as a proclaimed offender be weighed against them to deny post-arrest bail when reasonable grounds connect them to the commission of the offence?
  Read full judgment →
• Nasira Ashfaq vs Director General Safe Cities Authority, Punjab and 62025 PCRLJ 233 · Lahore High Court · 2024-04-30
  right to informationcriminal investigationPunjab Safe Cities Authorityelectronic datafair trialwrit jurisdictionpolice accountabilitySection 94 CrPC
  Summary & questions settled

  This constitutional petition challenged the refusal of the Punjab Safe Cities Authority (PSCA) to provide CCTV footage and call data records to the petitioner, whose husband was accused in a narcotics case. The core legal question was whether a private citizen has an absolute right to access electronic data held by the PSCA and what remedies exist when police fail to incorporate crucial evidence into a criminal investigation. The Court held that the PSCA is a regulated body whose data is accessible only through prescribed procedures by authorized entities like investigating officers or courts, not directly by private individuals. Consequently, the petitioner’s direct request was correctly declined. However, the Court clarified that when police fail to investigate fairly or incorporate relevant evidence, aggrieved parties have efficacious remedies under the Police Order 2002 and the Code of Criminal Procedure 1898, including approaching supervisory officers or seeking judicial intervention. The key principle is that while Article 19A guarantees the right to information, it is subject to reasonable restrictions; in criminal matters, the investigative process must be fair, and courts may intervene via writ jurisdiction if an investigation is conducted in bad faith.

  Questions settled

  • Can a private citizen directly obtain electronic data from the Punjab Safe Cities Authority for use in a criminal case?
  • What are the available legal remedies for an aggrieved person when the police fail to conduct a fair investigation or incorporate relevant evidence?
  • Does the Punjab Safe Cities Authority Act 2016 override the general provisions of the Punjab Transparency and Right to Information Act 2013 regarding data access?
  • Under what circumstances can the High Court exercise constitutional jurisdiction to intervene in an ongoing criminal investigation?
  Read full judgment →
• Nasir Zakir vs The State & another2025 LHC 5549 · Lahore High Court · 2025-09-15
  criminal appealmurderextrajudicial confessioncircumstantial evidencebenefit of the doubthostile witnessCCTV footagepointation
  Summary & questions settled

  This criminal appeal challenges the judgment of the trial court convicting the appellant under Section 364-A of the Pakistan Penal Code 1860 for the abduction and murder of a minor child. The core legal question concerns whether the prosecution's circumstantial evidence, including unverified CCTV footage, a retracted extrajudicial confession, hostile testimony from the complainant, and inadmissible pointation evidence, was sufficient to sustain a capital-related conviction beyond a reasonable doubt. The Lahore High Court held that the prosecution miserably failed to establish a direct link between the appellant and the crime due to glaring discrepancies, lack of forensic verification of the electronic evidence, weak and uncorroborated extrajudicial statements, and the turning hostile of key witnesses. Consequently, the appellate court set aside the conviction and sentence, acquitting the appellant on the basis of benefit of the doubt. The key principle laid down is that extrajudicial confessions and circumstantial links, such as unverified CCTV footage and police pointation statements, must be strictly corroborated and free from doubt to form the basis of a criminal conviction, especially in capital cases, and any reasonable doubt arising from the evidence must be resolved in favor of the accused.

  Questions settled

  • Whether unverified CCTV footage can be solely relied upon to uphold a conviction in a capital case without forensic authentication?
  • What is the evidentiary value of an extrajudicial confession made before police officers during interrogation?
  • Does a statement leading to discovery made while in police custody become inadmissible if the fact discovered was already in the knowledge of the police?
  • When is an accused entitled to the benefit of reasonable doubt resulting from material contradictions in the prosecution's evidence?
  Read full judgment →
• Nasir Jabbar vs Khalid Mahmood Akhtar (deceased) through his real2025 LHC 4228 · Lahore High CourtRead full judgment →
• Nasir and others vs The State and others2025 PCRLJ 168 · Peshawar High Court · 2022-12-30
  criminal appealmurderocular accountmedical evidencecontradictionbenefit of the doubtmotiveacquittal
  Summary & questions settled

  This criminal appeal challenges the judgment of the trial court convicting and sentencing the appellants under sections 302(b)/34 and 324/34 of the Pakistan Penal Code 1860 arising out of a double murder case. The core legal questions involved whether the prosecution successfully established the presence of the eye-witnesses at the spot, whether the incident occurred in the manner alleged, and whether the motive and ocular account were supported by trustworthy evidence and medical reports. The Peshawar High Court held that the prosecution's case suffered from major inherent defects, including unproven motive, glaring contradictions between the ocular testimony and medical evidence regarding the number and dimensions of injuries, unnatural conduct of the witnesses, and exaggerated implication of accused persons. The court laid down the principle that when the ocular account is inconsistent with medical evidence and the prosecution fails to establish its foundational story and motive beyond a reasonable doubt, the resulting benefit of the doubt must be extended to the accused as a matter of right, leading to the setting aside of the conviction and acquittal of the appellants.

  Questions settled

  • Whether the prosecution's case becomes doubtful when the medical evidence is in direct conflict with the ocular account regarding the number and nature of firearm injuries?
  • Does failure to prove the alleged motive react adversely against the prosecution when motive is set up as the primary basis for the crime?
  • Whether the exaggeration of the number of accused persons requires the court to apply a higher standard of care and circumspection in appraising evidence?
  • Is a single circumstance creating reasonable doubt in a prudent mind about the guilt of the accused sufficient to entitle him to an acquittal as a matter of right?
  Read full judgment →
• Nasibullah S/o Hameedullah vs The State2025 SHC KHI 1989 · Sindh High Court · 2025-07-08
  Call Data RecordSection 94 CrPCfair trialnarcotics casecross-examinationproduction of documentsdata retention
  Summary & questions settled

  This revision application challenges an order passed by the Special Court (CNS), Karachi, which declined the accused’s request for the production of Call Data Records (CDR) in a narcotics case. The core legal question was whether a trial court possesses the authority to summon such records during the pendency of a trial, particularly when telecommunication companies maintain data only for a limited duration. The High Court allowed the application, setting aside the impugned order. The court held that Section 94 of the Code of Criminal Procedure 1898 confers broad, discretionary power upon the court to summon any document or thing necessary for the purposes of an inquiry or trial at any stage. It reasoned that limiting this power would prejudice the accused’s right to a fair trial and the ability to confront prosecution witnesses. The court established that the potential deletion of CDRs due to routine retention policies necessitates timely judicial intervention to ensure that essential evidence is preserved for the purpose of cross-examination, thereby upholding the principles of a fair trial and impartial adjudication.

  Questions settled

  • Does a trial court have the authority under Section 94 of the Code of Criminal Procedure 1898 to summon Call Data Records during an ongoing trial?
  • Can a trial court reject a request for the production of documents solely on the ground that the prosecution's evidence is currently being recorded?
  • Is the right to summon documents under Section 94 of the Code of Criminal Procedure 1898 limited to the stage of the defence evidence?
  • Does the potential deletion of Call Data Records by telecommunication companies justify the early summoning of such records by the court?
  Read full judgment →
• Naseem Mai and another vs Malik Muhammad Shah Aalam and others2025 SCP 266 · Supreme Court of Pakistan · 2025-07-07
  family lawmaintenance allowancemarriage expensesfuture cause of actionpremature claimjudicial discretionFamily Courts Act
  Summary & questions settled

  This petition for leave to appeal challenged a Lahore High Court judgment that set aside a decree for future marriage expenses awarded to the petitioners against their father. The core legal question was whether a court can decree a claim for prospective marriage expenses where no marriage date is fixed and no preparations are underway. The Supreme Court held that such claims are premature and speculative. The Court reasoned that while a father has moral and religious duties toward his children, the Family Courts Act, 1964 does not empower courts to enforce indefinite, future financial obligations that lack a concrete cause of action. The Court emphasized that judicial relief requires an existing right and an actual infringement, not hypothetical or future needs. Consequently, the petition was dismissed, affirming that a suit for marriage expenses is only maintainable when such expenses are immediate, certain, and unjustly denied. The petitioners were granted liberty to approach the court afresh if a concrete cause of action arises in the future.

  Questions settled

  • Can a court decree a claim for future marriage expenses where no marriage date is fixed and no preparations are underway?
  • Is a claim for prospective marriage expenses maintainable under the Family Courts Act, 1964?
  • Does a father have a judicially enforceable legal obligation to pay for indeterminate future marriage expenses of his children?
  Read full judgment →
• Naseem Kousar vs The State & another2025 LHC 4744 · Lahore High Court · 2025-05-27
  narcoticschain of custodysafe custodymalkhanapolice rulescriminal appealacquittalburden of proof
  Summary & questions settled

  This criminal appeal arises from a judgment of the Additional Sessions Judge, Bahawalpur, convicting the appellant under Section 9(1)-6(d) of the Control of Narcotic Substances Act, 1997, and sentencing her to fourteen years' rigorous imprisonment. The core legal question before the Lahore High Court was whether the prosecution had established the safe custody and secure transmission of the alleged narcotics and sample parcels in the absence of mandatory police registers and road certificates, and whether the principles regarding chain of custody apply to pending cases. The court held that the prosecution failed to prove safe custody and secure transmission of the case property because it omitted to produce necessary documentary evidence such as Register Nos. II and XIX or the Road Certificate, thereby failing to establish the integrity of the chain of custody. The court laid down the principle that the prosecution must substantiate oral recovery evidence with documentary proof of safe custody and transmission in accordance with the Police Rules, 1934, and that Supreme Court judgments clarifying procedural mandates apply retrospectively to all pending cases.

  Questions settled

  • Does the failure of the prosecution to produce extracts from Register No. XIX and Road Certificates undermine the chain of custody in narcotics cases?
  • Whether the principles regarding safe custody and transmission of case property laid down by the Supreme Court apply to pending cases?
  • Can a positive chemical examiner's report alone sustain a narcotics conviction when the prosecution fails to prove safe transmission of the sample parcels?
  • When does the statutory presumption of guilt under Section 29 of the Control of Narcotic Substances Act, 1997, shift the burden of proof to the accused?
  Read full judgment →
• Nargis Subhan & Others vs Province Of Sindh & Others2025 SHC 290 · Sindh High Court · 2025-02-13Read full judgment →
• Naqeebullah Ehsas and others vs Khair Muhammad Arif, President Pashto2025 CLC 851 · Balochistan High Court · 2024-03-26Read full judgment →
• Nanik Ram Jethwani vs Lakhmichand Wadwani through legal2025 CLC 876 · Sindh High Court · 2024-11-20Read full judgment →
• Najeeb Ullah Durrani and another vs Securities and Exchange Commission2025 IHC 314, 2025 PLJ Islamabad 241 · Islamabad High CourtRead full judgment →
• Naimatullah vs The State2025 MLD 894 · Balochistan High Court · 2024-12-06
  Criminal RevisionRobberyTest of Identification ParadeJoint RecoveryEvidentiary ValueAcquittalMisreading of Evidence
  Summary & questions settled

  This Criminal Revision Petition challenged the conviction and sentence of the petitioner under Section 392 of the Pakistan Penal Code, 1860, for robbery. The core legal question was whether the conviction could be sustained based on a Test of Identification Parade (TIP) where witnesses failed to provide a prior description of the culprits, and whether the alleged recovery of stolen cash, which was joint and lacked specific identification, constituted sufficient evidence. The High Court held that the conviction was unsustainable, noting that the identification process was flawed because the witnesses had not provided a description of the accused before the TIP. Furthermore, the court ruled that the joint recovery of cash, without proof of specific denominations or serial numbers, failed to corroborate the prosecution's case. Consequently, the court set aside the judgments of the lower courts and acquitted the petitioner. The judgment reinforces the principle that identification parades are unreliable without prior descriptions, and joint recoveries lacking specific links to the stolen property cannot support a conviction.

  Questions settled

  • Does a Test of Identification Parade hold evidentiary value if the witnesses failed to provide a description of the accused prior to the parade?
  • Can a joint recovery of cash, without specific identification of denominations or serial numbers, serve as corroborative evidence for a conviction?
  • Is a conviction sustainable when the prosecution fails to provide substantive evidence and relies solely on flawed identification and unverified recoveries?
  Read full judgment →
• Naimatullah and others vs The State and another2025 P Cr. L J 963 · Balochistan High Court · 2024-09-30
  murderocular accountsole eyewitnessrelated witnessmotivemitigating circumstanceslife imprisonmentsentence enhancement
  Summary & questions settled

  This consolidated criminal appeal and criminal revision petition arise from a judgment of the Trial Court convicting the appellant under Section 302(b) of the Pakistan Penal Code 1860 for the murder of the deceased and sentencing him to imprisonment for life with compensation under Section 544-A of the Code of Criminal Procedure 1898, while the revision petition sought sentence enhancement. The core legal questions involved the reliability of the sole eyewitness, the corroboration by medical and circumstantial evidence, and the existence of mitigating circumstances justifying life imprisonment instead of the death penalty. The Balochistan High Court held that the prosecution successfully established its case through a natural and confidence-inspiring ocular account corroborated by medical evidence and proven motive, and that sudden hot words constituted a mitigating circumstance. The court dismissed both the appeal and the revision petition, maintaining the conviction and sentence. The key principle laid down is that the testimony of a related eyewitness, if consistent, natural, and unshaken during cross-examination, is fully sufficient to sustain a murder conviction without requiring independent corroboration.

  Questions settled

  • Whether the testimony of a sole eyewitness who is related to the deceased can form the basis of a murder conviction without independent corroboration?
  • Does a sudden exchange of hot words between the accused and the deceased prior to a fatal attack constitute a mitigating circumstance warranting a lesser sentence of imprisonment for life instead of capital punishment?
  • Can a disclosure memo and pointation of the place of occurrence lead to a valid discovery of a fact when the police had already visited and known the crime scene?
  Read full judgment →
• Naheed Shoukat Malik (late) through her legal heirs vs Malik Mohsin Raza2025 IHC 266 · Islamabad High CourtRead full judgment →
• Naeem Ullah vs Chaudhary Zulifqar Ahmad, etc2025 LHC 5243 · Lahore High Court · 2025-08-06Read full judgment →
• Naeem Ismail vs Raja Waleed Ur Rehman, etc2025 IHC 340 · Islamabad High Court · 2025-04-30Read full judgment →
• Naeem Iqbal Khan vs Mst. Fateh Khatoon and others2025 YLR 385 · Lahore High Court · 2024-09-19Read full judgment →
• Naeem Hussain Awan others vs Government of Pakistan & others2025 SHC KHI 2156 · Sindh High Court · 2025-08-29Read full judgment →
• Naeem Hussain & others vs Province of Sindh and others2025 SHC KHI 2264 · Sindh High Court · 2025-09-11
  regularization of servicecontract appointmentsenioritycivil servicemerit-based recruitmentretrospective effectSindh Public Service Commission
  Summary & questions settled

  This petition challenged the contract-based appointment of Sub-Engineers in the Sindh Public Health Engineering & Rural Development Department, seeking a declaration that such appointments are illegal for permanent posts and requesting that their regularization be backdated to their initial 2018 hiring date. The core legal questions concerned whether contract appointments for permanent posts are permissible under service laws, whether the Sindh Public Service Commission (SPSC) has the authority to assess contract employees for BS-11 posts, and whether regularization can be granted retrospectively. The Court held that while the petitioners were regularized in 2025, such regularization constitutes a fresh appointment rather than a continuation of service. Relying on established Supreme Court precedents, the Court affirmed that regularization is a prospective act, not retrospective, and that service rendered on a contract basis cannot be counted towards seniority or backdated for the purpose of permanent status. The key principle laid down is that public appointments must be merit-based and transparent, and regularization of contract employees does not grant them seniority from their initial date of contract employment, as this would violate the rights of those recruited through proper competitive processes.

  Questions settled

  • Can a temporary or contract appointment be made against a permanent position in the civil service?
  • Does the regularization of a contract employee constitute a fresh appointment or a continuation of previous service?
  • Can the seniority of a regularized employee be counted from the date of their initial contract appointment?
  • Does the Sindh Public Service Commission have the authority to assess contract employees for regularization in BS-11 posts?
  Read full judgment →
• Naeem Asghar & another vs Provincial Govt.& others2025 PHC 210 · Peshawar High Court · 2025-07-14Read full judgment →
• Naeem Akhtar vs District Judge/Appellate Authority Rent Controller Mirpur,2025 PLJ AJ&K 4 · High Court of Azad Jammu and KashmirRead full judgment →
• Naeem Abbas etc vs Altaf Hussain etc2025 LHC 3823 · Lahore High Court · 2025-05-14Read full judgment →
• Nadir Mukhtiar vs The Directorate of Immigration and Passports, Islamabad, through its Director General & others2025 IHC 32 · Islamabad High CourtRead full judgment →
• Nadir Hussain Advocate vs The State & another2025 SHC KHI 1601 · Sindh High Court · 2025-05-30
  direct complaintSection 203 Cr.P.C.Section 202 Cr.P.C.anti-corruptioncognizance of offencecriminal revisioninquiry reportjudicial discretion
  Summary & questions settled

  This criminal revision application challenged an order by the Special Judge Anti-Corruption, which dismissed a direct complaint under Section 203 of the Code of Criminal Procedure 1898. The complainant had alleged corruption and illegal acts by government officials. Following a court-ordered inquiry under Section 202 of the Code of Criminal Procedure 1898, the inquiry officer submitted a positive report confirming the allegations. However, the Special Judge dismissed the complaint, citing perceived contradictions in witness statements and the complainant's attempt to withdraw allegations against one respondent. The High Court held that the dismissal was legally unsustainable. It ruled that while an inquiry report is not binding, a trial court must provide compelling, cogent reasons to dissent from a positive report. The court found that the Special Judge selectively appreciated the evidence, ignoring corroborative witness statements, and misapplied the principle of 'cognizance of the offence, not the person.' Consequently, the High Court set aside the impugned order and remanded the matter for a fresh, comprehensive determination on whether sufficient grounds exist to proceed against the accused.

  Questions settled

  • Does a positive inquiry report under Section 202 of the Code of Criminal Procedure 1898 require a trial court to provide robust reasons if it chooses to dismiss the complaint under Section 203 of the Code of Criminal Procedure 1898?
  • Can a trial court dismiss a direct complaint under Section 203 of the Code of Criminal Procedure 1898 based on a selective reading of witness statements while ignoring a positive inquiry report?
  • Does the principle of 'cognizance of the offence and not of the person' mandate that a complainant must prosecute all named accused, or can they choose to withdraw against one without the entire complaint being dismissed?
  Read full judgment →
• Nadir and another vs The State2025 YLR 517 · Sindh High Court · 2024-10-09Read full judgment →
• Nadeem Liaqat vs The State, etc2025 LHC 5200 · Lahore High Court · 2025-07-23
  illegal dispossessioncriminal appealbenefit of doubtexhibition of documentsburden of proofwitness credibilityprocedural lapse
  Summary & questions settled

  This criminal appeal challenges the conviction of the appellant under the Illegal Dispossession Act, 2005, for allegedly forcibly dispossessing the complainant from a property. The core legal questions concern whether the prosecution successfully established the charge of illegal dispossession beyond a reasonable doubt and whether procedural lapses, specifically the failure to formally exhibit the complaint, invalidated the trial court's judgment. The Lahore High Court held that the conviction was unsustainable, noting material contradictions in the testimony of prosecution witnesses, an inordinate delay in filing the complaint, and the lack of credible evidence regarding the alleged incident. Furthermore, the Court emphasized that a document not formally exhibited during trial cannot be read into evidence. Consequently, the Court allowed the appeal, set aside the conviction, and acquitted the appellant, extending the benefit of doubt. The judgment reaffirms that the burden of proof rests on the prosecution and that procedural requirements, such as the formal exhibition of documents, are essential for a valid conviction.

  Questions settled

  • Can a document that has not been formally exhibited during trial be read into evidence?
  • Does an inordinate, unexplained delay in filing a complaint under the Illegal Dispossession Act, 2005, undermine the credibility of the prosecution's case?
  • Is a conviction sustainable when prosecution witnesses provide contradictory testimony regarding the occurrence of the alleged offence?
  Read full judgment →
• Nadeem Aslam etc vs Shahid Mehmood etc2025 LHC 4965 · Lahore High Court · 2025-06-26Read full judgment →
• Nadeem Ahmed vs The State and others2025 IHC 328 · Islamabad High Court · 2025-05-09
  Criminal breach of trustSection 249-A Cr.P.C.AcquittalCivil disputeBusiness partnershipCriminal liabilityTrial Court powers
  Summary & questions settled

  This appeal challenges an order passed by the Trial Court acquitting respondents under Section 249-A of the Code of Criminal Procedure 1898 in a case registered under Section 406 of the Pakistan Penal Code 1860. The core legal question was whether a business partnership dispute involving the non-payment of funds constitutes criminal breach of trust or is merely a civil matter. The High Court held that the dispute was essentially civil in nature, arising from a breach of agreement rather than criminal conduct. The Court determined that the fundamental ingredients of Section 405 of the Pakistan Penal Code 1860, specifically entrustment and misappropriation, were absent. Furthermore, the Court affirmed that under Section 249-A of the Code of Criminal Procedure 1898, a Trial Court possesses the authority to acquit an accused at any stage if the charge is groundless, and this power may be exercised suo motu without a formal application. Consequently, the appeal was dismissed, upholding the acquittal as the prosecution had no realistic prospect of conviction.

  Questions settled

  • Does a business partnership dispute involving non-payment of money constitute criminal breach of trust under Section 405 of the Pakistan Penal Code 1860?
  • Can a Trial Court exercise powers under Section 249-A of the Code of Criminal Procedure 1898 suo motu without a formal application?
  • Is a dispute arising from a breach of a business agreement essentially a civil matter rather than a criminal one?
  • What are the essential ingredients required to establish the offense of criminal breach of trust?
  Read full judgment →
• Nabila Hakim Ali Khan vs Government of the Punjab, etc2025 LHC 3845 · Lahore High Court · 2025-04-09Read full judgment →
• Nabeela Shaukat vs Federation of Pakistan and others2025 IHC 322 · Islamabad High Court · 2025-04-25Read full judgment →
• Nabeel son of Doshambay vs The State2025 SHC KHI 1724 · Sindh High Court · 2025-06-02
  post-arrest bailprohibitory clausegutka mawa actfurther inquiryrecovery by police officials
  Summary & questions settled

  The applicant sought post-arrest bail in a case registered under Section 8(i) of the Gutka Mawa Act, after his bail plea was dismissed by the trial court. The core legal question was whether the applicant was entitled to post-arrest bail when the offense carried a maximum punishment not falling within the prohibitory clause of Section 497 of the Code of Criminal Procedure, and where recoveries were witnessed solely by police officials in a populated area without associating private mashirs under Section 103 of the Code of Criminal Procedure. The Sindh High Court held that since the maximum punishment for the offense is three years, it does not fall within the prohibitory clause of Section 497, Code of Criminal Procedure, making bail the rule and refusal the exception. Furthermore, investigation was complete, custody was no longer required, and non-association of private witnesses raised a case for further inquiry. The court laid down the principle that offenses carrying lesser sentences outside the prohibitory clause entitle the accused to bail as a matter of right unless exceptional grounds like abscondence, tampering, or repetition of the offense are established.

  Questions settled

  • Does an offense carrying a maximum punishment of three years fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Is bail granted as a matter of right when an offense does not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Does the failure to associate private witnesses under Section 103 of the Code of Criminal Procedure 1898 during a recovery in a populated area make out a case for further inquiry?
  Read full judgment →
• M/s. Wali Khan Trading Company, Karachi vs The CIR, Zone-II, RTO-1,PTCL 2025 CL. 470 · Appellate Tribunal Inland Revenue · 2024-12-13Read full judgment →
• M_s. WAK Limited Multan Road, Lahore and others vs Collector Central Excise & Sales Tax, Lahore (Now Commissioner Inland Revenue, LTU, Lahore) and others2025 SCP 184 · Supreme Court of Pakistan
  mandatory and directory provisionssales tax assessmentlimitation periodorder-in-originalshow cause noticetax recoverystatutory interpretationcondonation of time-limit
  Summary & questions settled

  This larger Bench was constituted to consider whether the judgment in Collector of Sales Tax, Gujranwala v Super Asia Mohammad Din (2017 SCMR 1427) correctly interpreted certain time-bound provisions for issuing an order-in-original under fiscal statutes as mandatory rather than directory. The core legal question was whether statutory timeframes for making assessment and recovery orders under the Sales Tax Act 1990 and allied tax laws are mandatory, rendering orders passed beyond those periods invalid. The Court held that both the initial time limit and the negative phrasing regarding extensions ('in no case exceed') are mandatory, and failure to pass orders within these stipulated periods invalidates the adjudication. The key principles affirmed are that multi-layered statutory time limitations on executive tax authorities protect taxpayers from indefinite liability and stale claims, and that procedural timelines coupled with strict negative language must be construed as mandatory to fulfill the legislative intent.

  Questions settled

  • Whether the time periods prescribed for passing an order-in-original under the Sales Tax Act 1990 are mandatory or directory?
  • Does the absence of explicitly stated penal consequences in a fiscal statute render a procedural time limit directory?
  • Whether the Federal Board of Revenue has an open-ended discretion under section 74 of the Sales Tax Act 1990 to grant time extensions without any outer limit?
  • What is the legal effect of an adjudication order passed beyond the statutory timeframe prescribed under the relevant assessment provisions?
  Read full judgment →
• M/s. Umar Textiles vs Federal Board of Revenue & othersPTCL 2025 CL. 220 · Sindh High Court · 2025-01-27Read full judgment →
• M/s. UIG (Pvt.) Ltd vs Member Inland Revenue (Sales Tax) and others, SindhPTCL 2025 CL. 50 · Sindh High CourtRead full judgment →
• M/s. Taj Vegetable Oil Processing Unit (Pvt.) and others. Ltd vs FederationPTCL 2025 CL. 261 · Peshawar High CourtRead full judgment →
• M/s. Sui Southern Gas Company Ltd. vs Large Taxpayers Unit (L.T.U.)2025 SHC 292, PTCL 2025 CL. 649 · Sindh High Court · 2025-03-04Read full judgment →
• M/s. Steel Complex (Pvt.) Limited vs Islamabad Electric Supply & Company2025 IHC 500 · Islamabad High CourtRead full judgment →
• M/s. Sidra International vs FOP and others2025 SHC KHI 2090 · Sindh High Court · 2025-08-18Read full judgment →
• M/s. Sidat Hyder Morshed Associates (Pvt) Ltd vs Trade Development2025 SHC KHI 1600 · Sindh High Court · 2025-05-30Read full judgment →
• M/s. Ruknuddin (Pvt.) Ltd vs Province of Sindh & others2025 SHC 286 · Sindh High Court · 2025-02-14Read full judgment →
• M/s. Regus Executive Center Karachi (Private) Limited vs Assistant2025 SHC 610, PTCL 2025 CL. 597 · Sindh High CourtRead full judgment →
• M/s. Ramada Industries (Pvt) Ltd., Karachi vs The Commissioner I. R. Zone-2025 SHC 612 · Sindh High Court · 2025-03-21Read full judgment →
• M/S. R & J Builders and Developers & another vs Muhammad Sajjad &2025 SHC KHI 1903, 2025 SHC KHI 1904 · Sindh High CourtRead full judgment →
• M/s. Peshawar Electric Supply Company Ltd. (PESCO), WAPDA House,PTCL 2025 CL. 307 · Appellate Tribunal Inland Revenue · 2024-02-01Read full judgment →
• M/s. Peng's Hair and Beauty Clinic and others vs The Purple Pink and others2025 SHC 622 · Sindh High Court · 2025-04-23Read full judgment →
• M/s. Pak Sun Green [PVT] Ltd. and others vs Federation of Pakistan and2025 SHC 424 · Sindh High Court · 2025-03-20Read full judgment →
• M/s. OilBoy (Pvt.) Ltd vs M/s. Pak Qatar Investment (Pvt.) Ltd2025 SHC 406 · Sindh High Court · 2025-03-20Read full judgment →
• M/s. New Era Fabric, Karachi vs Commissioner Inland Revenue Zone-I, CTO,2025 SHC 608 · Sindh High Court · 2025-04-16Read full judgment →
• M/s. National Construction Limited through Project Manager (West)2025 PLJ Quetta 66 · Balochistan High CourtRead full judgment →
• Nafeesa Rehman vs The Election Tribunal Balochistan, Quetta and 2 others2025 PLD Balochistan 9 · Balochistan High Court · 2024-02-07Read full judgment →
• M/s. Lucky Tex (Pvt.) Limited vs M/s. Cresox (Pvt.) Limited2025 SHC 268, 2025 CLD 561 · Sindh High Court · 2025-02-11Read full judgment →
• M/s. Kassim Textile Mills (Pvt.) Limited and others vs Commissioner Inland2025 SCP 182, PTCL 2025 CL. 664 · Supreme Court of Pakistan
  minimum taxcarry forward tax creditincome taxfiscal statute interpretationretrospective applicationstatutory interpretationtax liabilityFinance Acttaxpayer reliefFBR circulars
  Summary & questions settled

  The Supreme Court decided a batch of civil appeals and petitions concerning the interpretation of Section 113(2)(c) of the Income Tax Ordinance, 2001, specifically whether minimum tax paid by a company with assessed losses (and thus zero actual tax payable) could be carried forward for adjustment against future tax liability prior to the 2021 amendment. The Court held that, as Section 113(2)(c) stood before the Finance Act, 2021, the benefit of carry-forward was only available where the minimum tax paid exceeded an "actual tax payable," meaning a positive quantum of tax. It was not applicable where the actual tax payable was zero due to losses. The Court emphasized the strict interpretation of fiscal statutes, stating that there is no room for equity or intendment when the language is clear and unambiguous. The Finance Act, 2021, which allowed carry-forward even with zero tax payable, was deemed prospective, not retrospective, and FBR circulars cannot override statutory language.

  Questions settled

  • Can minimum tax paid by a company with zero actual tax payable due to losses be carried forward for adjustment against future tax liability under Section 113(2)(c) of the Income Tax Ordinance, 2001, as it stood before the Finance Act, 2021?
  • Are fiscal statutes to be interpreted strictly, or can principles of equity and intendment be applied?
  • Can an amendment to a fiscal statute be applied retrospectively without express language or necessary intendment?
  • Do circulars issued by the Federal Board of Revenue override the explicit language of a statute?
  • What is the meaning of "actual tax payable" in Section 113(2)(c) of the Income Tax Ordinance, 2001, prior to the 2021 amendment?
  Read full judgment →
• M/S. J.S Bank Ltd vs M/S. Gulistan Textile Mills Ltd2025 SHC 628 · Sindh High Court · 2025-04-30Read full judgment →
• M/S. J.S Bank Ltd vs Gulistan Spinning Mills Ltd2025 SHC 630 · Sindh High Court · 2025-04-30Read full judgment →
• M/s. Ikram ud din, Karachi vs The DCIR, Unit-4, Range-B, Zone-II, RTO-1,PTCL 2025 CL. 489 · Appellate Tribunal Inland Revenue · 2024-12-13Read full judgment →
• M/s. Gizri Corporation Pvt. Ltd vs Pakistan Industrial Development2025 SHC 336, 2025 SHC 334 · Sindh High Court · 2025-03-13Read full judgment →