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. 232,594 judgments in total.

• Mena Energy DMCC vs Hascol Petroleum Limited2025 SHC 282 · Sindh High Court · 2025-02-27Read full judgment →
• Mehrab Bangulani vs The State2025 PCRLJ 369 · Sindh High Court · 2024-10-03
  criminal appealmurder convictionbenefit of doubthearsay evidencecircumstantial evidencepolice investigationacquittalwitness credibility
  Summary & questions settled

  This criminal appeal challenged the conviction and life sentence of the appellant for murder under the Pakistan Penal Code 1860. The core legal question was whether the prosecution had proven the appellant's guilt beyond reasonable doubt based on the evidence presented. The High Court allowed the appeal and acquitted the appellant, holding that the prosecution's case was fundamentally flawed. The court established that hearsay evidence provided by police officials, without independent corroboration, is insufficient to sustain a conviction, particularly in capital cases. Furthermore, the court held that where the prosecution presents two conflicting versions of events—one from the police and one from a key witness—and fails to establish a continuous chain of circumstantial evidence linking the accused to the crime, the accused is entitled to the benefit of the doubt. The court emphasized that the initial onus of proof rests entirely on the prosecution, and a failure to discharge this burden cannot be remedied by the accused's inability to explain circumstances, nor by the absence of evidence from the defense.

  Questions settled

  • Can a conviction be sustained solely on the basis of hearsay evidence provided by police officials without independent corroboration?
  • Does the failure of the prosecution to establish a continuous chain of circumstantial evidence entitle the accused to an acquittal?
  • Is the accused required to discharge the burden of proof when the prosecution's case is inherently unreliable?
  • What is the legal consequence of the prosecution presenting two conflicting versions of the same criminal incident?
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• Mehr Rehman vs The Justice of Peace (West), Islamabad, etc2025 IHC 48 · Islamabad High Court · 2025-01-28Read full judgment →
• Mehmood-Ul-Haq vs Waqas Mehmood Maan and 21 others2025 MLD 169 · Lahore High Court · 2024-10-24Read full judgment →
• Mehmood Khan s/o Abdul Ghani Patha vs The State2025 SHC LAR 1614 · Sindh High Court · 2025-05-30
  narcoticschain of custodybenefit of doubtcriminal appealacquittalsafe custodychemical examiner report
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of the appellants for an offence under Section 9(c) of the Control of Narcotics Substance Act, 1997, involving the recovery of 40 kilograms of Charas. The core legal question is whether the prosecution successfully established the guilt of the appellants beyond a reasonable doubt, particularly concerning the integrity of the chain of custody of the recovered narcotics. The Court held that the prosecution failed to prove the safe custody and secure transmission of the recovered contraband. Specifically, the investigating officer failed to maintain proper records in the police station register (Malkhana) or the roznamcha regarding the storage and dispatch of the samples to the chemical laboratory. Furthermore, material contradictions between the testimonies of the prosecution witnesses regarding the recovery process and vehicle details undermined the prosecution's case. Consequently, the Court set aside the convictions and acquitted the appellants, holding that any reasonable doubt in the prosecution's evidence must be resolved in favor of the accused as a matter of right.

  Questions settled

  • Does the failure of the prosecution to prove the safe custody and secure transmission of recovered narcotics warrant the acquittal of the accused?
  • Is the prosecution required to maintain an unbroken chain of custody for narcotics samples to sustain a conviction under the Control of Narcotics Substance Act, 1997?
  • Does a material contradiction in the testimony of prosecution witnesses regarding the recovery process create a reasonable doubt sufficient to entitle the accused to an acquittal?
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• Mehmood Khan Achakzai vs The State and another2025 PCRLJ 492 · Balochistan High Court · 2024-07-19
  quashment of FIRcriminal trespassabuse of processconstitutional petitionmens reacivil disputeHigh Court jurisdiction
  Summary & questions settled

  This Constitution Petition sought the quashment of an FIR registered under Sections 447 and 448 of the Pakistan Penal Code 1860, alleging criminal trespass on state land. The core legal question was whether the FIR's contents sufficiently established the essential ingredients of criminal trespass, specifically the requisite intent to intimidate, insult, or annoy the person in possession. The Court held that the FIR failed to disclose these essential elements, noting that the property in question was a plot rather than a house, rendering Section 448 inapplicable, and that the allegations lacked the necessary criminal intent required under Section 441. Emphasizing that criminal trespass requires a dominant intent to commit an offence or cause annoyance, rather than mere civil possession disputes, the Court ruled that continuing the proceedings would be an abuse of the court's process. Consequently, the Court quashed the FIR and the impugned order of the Magistrate, affirming its constitutional authority to prevent the misuse of criminal law in matters that are essentially civil in nature or lack evidentiary foundation.

  Questions settled

  • Does the occupation of a plot of land without the intent to intimidate, insult, or annoy the possessor constitute criminal trespass under Section 441 of the Pakistan Penal Code 1860?
  • Can a High Court quash criminal proceedings if the FIR fails to disclose the essential ingredients of the alleged offence?
  • Is the registration of an FIR and subsequent investigation subject to judicial review under Article 199 of the Constitution of the Islamic Republic of Pakistan 1973?
  • Does the definition of house trespass under Section 442 of the Pakistan Penal Code 1860 apply to a vacant residential plot?
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• Mehmood Asghar vs The State2025 SHC KHI 1990 · Sindh High Court · 2025-07-17
  quashment of FIRcriminal breach of trustprivate money lendinginterest-based loansinherent jurisdictionfraudcontractual obligations
  Summary & questions settled

  This Criminal Miscellaneous Application challenged an FIR registered under Sections 420/34 of the Pakistan Penal Code 1860, alleging fraud and embezzlement. The applicant contended that the FIR was barred by the West Pakistan Private Money Lenders Ordinance 1960 and the Sindh Prohibition of Interest on Private Loan Act 2023, arguing the transaction was an interest-based loan. The court examined the scope of these statutes, holding that they target commercial money-lending businesses and interest-based practices, not isolated contractual obligations or private transactions devoid of interest. The court found that the allegations in the FIR pertained to dishonest inducement and criminal breach of trust rather than prohibited interest-based lending. Consequently, the court ruled that the general penal provisions were applicable, and the special statutes did not bar the proceedings. The court affirmed that factual disputes regarding the nature of the transaction must be adjudicated by the trial court upon recording evidence. The application for quashment was dismissed, and the trial court's order accepting the challan was maintained.

  Questions settled

  • Does the West Pakistan Private Money Lenders Ordinance 1960 apply to isolated, non-commercial private loans?
  • Can an FIR for fraud and criminal breach of trust be quashed on the ground that the underlying transaction was an interest-based loan?
  • Does the Sindh Prohibition of Interest on Private Loan Act 2023 bar criminal proceedings for transactions that are not demonstrably interest-based?
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• Mehdi Ishaque S/O Ishaque Khan vs Learned IV.Jm Karachi East & Others2025 SHC 338 · Sindh High Court · 2025-03-11
  right of private defencecounter FIRquashing of ordercriminal revisiondacoityself-defense
  Summary & questions settled

  The applicant, who was the complainant in an FIR relating to a dacoity, challenged an order of the Magistrate directing the registration of an FIR against him for killing one of the accused and injuring another, despite the police report and investigation establishing that the applicant acted in self-defense. The core legal question was whether a Magistrate could legally order a counter-FIR against a complainant who acted in exercise of the right of self-defense during a robbery, particularly when the co-accused was subsequently tried and convicted. The High Court held that the Magistrate's order was unjustified, unwarranted, and contrary to the principle that two FIRs cannot be registered for the same incident. The Court set aside the impugned order to the extent of directing the registration of an FIR against the applicant, reaffirming the validity of the plea of self-defense established during the police investigation and trial.

  Questions settled

  • Can a Magistrate direct the registration of a counter-FIR against a complainant who acted in self-defense during the commission of an offense?
  • Whether two FIRs can be registered for the same incident?
  • Is an order directing the registration of a second FIR sustainable when the primary incident has already been investigated and resulted in the conviction of the co-accused?
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• Mehboob vs The State2025 SHC HYD 1744 · Sindh High Court · 2025-05-30
  rapeabductionDNA evidenceenhancement of sentencecredibility of victim testimonymedical jurisprudencecriminal appeal
  Summary & questions settled

  This criminal jail appeal challenged the judgment of the trial court convicting the appellant for offences under Sections 376 and 365-B of the Pakistan Penal Code 1860 and sentencing him to ten years' rigorous imprisonment. The prosecution case was that the appellant, along with others, forcibly entered the house of the complainant, abducted his teenage daughter at gunpoint, and subsequently subjected her to rape. The core legal questions revolved around the credibility of the ocular testimony of the victim and her family members, the evidentiary value of the medical and DNA evidence, and the sustainability of the conviction in light of alleged discrepancies. The Sindh High Court dismissed the appeal, holding that the victim's testimony—corroborated by independent medical officers and positive DNA profiling linking the appellant to the crime—conclusively established the guilt of the accused. Furthermore, invoking its appellate powers, the Court enhanced the appellant's sentence to fourteen years' imprisonment, laying down that heinous offences committed by close family members against vulnerable victims warrant strict penal treatment and that overwhelming oral and forensic evidence fully sustains a conviction.

  Questions settled

  • Whether a conviction for rape and abduction can be sustained solely on the basis of the victim's testimony when corroborated by medical and DNA evidence?
  • Can the appellate court enhance the sentence awarded by the trial court in a criminal appeal filed by the convict?
  • Does a delayed FIR vitiate the prosecution case where a plausible explanation exists and the accused is a close family member?
  • What is the evidentiary value of a DNA report in establishing the identity of the perpetrator in a sexual assault case?
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• Mehboob vs The State and others2025 SCP 81, 2025 SCMR 856 · Supreme Court of Pakistan · 2025-03-05
  leave to appealdouble murdergrave and sudden provocationconviction conversionsentence reductionPakistan Penal CodePakistan Arms OrdinanceCode of Criminal Procedure
  Summary & questions settled

  This petition for leave to appeal challenged a Peshawar High Court judgment that upheld the petitioner's convictions and sentences for double murder. The petitioner had killed his sister and a relative after finding them in a compromised position, acting under grave and sudden provocation. The trial court convicted him under Section 302(b) of the Pakistan Penal Code, 1860, sentencing him to life imprisonment on two counts, and also under Section 13 of the Pakistan Arms Ordinance, 1965. The High Court dismissed both the petitioner's appeal against conviction and the complainant's revision for sentence enhancement. The Supreme Court converted the petition into an appeal, partly allowing it. It held that the petitioner's actions, being spontaneous and under sudden provocation, fell under Section 302(c) of the Pakistan Penal Code, 1860. Consequently, the conviction was converted from Section 302(b) to Section 302(c), and the sentence of life imprisonment on two counts was reduced to fourteen years, with the benefit of Section 382-B of the Code of Criminal Procedure, 1898.

  Questions settled

  • Can a conviction under Section 302(b) of the Pakistan Penal Code, 1860, be converted to Section 302(c) of the Pakistan Penal Code, 1860, on appeal?
  • What factors determine the application of 'sudden provocation' under Section 302(c) of the Pakistan Penal Code, 1860?
  • Can a sentence of life imprisonment for murder be reduced to fourteen years under Section 302(c) of the Pakistan Penal Code, 1860, with the benefit of Section 382-B of the Code of Criminal Procedure, 1898?
  • Is a spontaneous reaction to a compromising situation sufficient to invoke the defense of grave and sudden provocation?
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• Mehboob Akhtar Mian and others vs The State and others2025 SHC KHI 1793, 2025 SHC KHI 1794 · Sindh High CourtRead full judgment →
• Mehak Jan vs The State, Imtiaz2025 SHC 4 · Sindh High Court · 2025-01-13Read full judgment →
• Meezan Bank Limited vs Eduljee Dinshaw Pvt. Ltd. & others2025 SHC 626 · Sindh High Court · 2025-04-30Read full judgment →
• Meer Muhammad Chandio vs The State2025 YLR 999 · Sindh High Court · 2024-10-08
  pre-arrest bailanticipatory baildelay in FIRfurther inquiryhatchet blowcriminal procedure
  Summary & questions settled

  This is a criminal miscellaneous application filed by applicant Meer Muhammad seeking pre-arrest bail in Crime No.136 of 2024 registered at Police Station Mirpur Bathoro, for offences under Sections 114, 337-F(vi), 337-L(2) and 504 of the Pakistan Penal Code 1860, after his bail was refused by the Court of Sessions. The core legal question was whether the applicant was entitled to pre-arrest bail given the specific role attributed, delayed lodging of the FIR, and the non-fatal nature of the injury. The Sindh High Court held that since the injury was on a non-vital part of the body, the FIR was lodged with an inordinate delay without plausible explanation, and the case had been challaned with the accused joining the trial, the case against the applicant called for further inquiry under Section 497(2) of the Code of Criminal Procedure 1898. The Court laid down the principle that unexplained delay in lodging the FIR combined with injuries on non-vital parts of the body makes out a case for further inquiry warranting the confirmation of pre-arrest bail.

  Questions settled

  • Whether unexplained delay in lodging the FIR is fatal to the prosecution case warranting pre-arrest bail?
  • Does causing an injury to a non-vital part of the body attract further inquiry under subsection (2) of Section 497 of the Code of Criminal Procedure 1898?
  • Can pre-arrest bail be confirmed when co-accused have already been granted bail and the challan has been submitted?
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• Meer Hassan Khan & Another vs Ministry Of Science & Technology Through Its Secretary, Govt Of Pakistan & Another2025 IHC 286 · Islamabad High Court · 2025-04-15Read full judgment →
• MCB Bank Limited vs Uzma Tehreem & others2025 SCP 206 · Supreme Court of Pakistan · 2025-05-29
  recovery of financecontinuing guaranteeleave to defendlimitationcourt feerestructuring agreementdischarge of suretycontumacious conduct
  Summary & questions settled

  This appeal arose from a recovery suit filed under the Financial Institutions (Recovery of Finances) Ordinance 2001. The High Court's Division Bench had partly accepted the respondents' appeal, granting leave to defend to Respondent No. 1 (a director/guarantor) on the grounds that she had not executed a fresh guarantee for a restructured term loan. The core legal questions were whether the respondents' appeal was time-barred due to a 173-day delay in paying the requisite court fee, and whether the guarantor's liability was discharged under Section 133 of the Contract Act 1872. The Supreme Court allowed the appeal, setting aside the Division Bench's decision. The Court held that the appeal was time-barred as the respondents' failure to cure the court fee defect within the stipulated time constituted contumacious conduct. On the merits, the Court ruled that the original guarantee was a continuing one, and because Respondent No. 1 signed the restructuring agreement as a guarantor, she consented to the variance, meaning her liability was not discharged under Section 133.

  Questions settled

  • Whether an appeal is liable to be dismissed as time-barred if the appellant fails to affix the requisite court fee within the allowed time and the delay is contumacious?
  • Does a restructuring of a finance facility discharge a surety under Section 133 of the Contract Act 1872 if the surety signed the restructuring agreement as a guarantor?
  • Can a continuing guarantee be deemed discharged upon the renewal or restructuring of a loan facility in the absence of a written notice of discontinuance?
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• Mazhar Gilani vs The Registrar, Lahore High Court, Lahore & others2025 LHC 856 · Lahore High CourtRead full judgment →
• Matloob Hussain vs The State & 02 others2025 IHC 418 · Islamabad High Court · 2025-05-27
  registration of FIREx-Officio Justice of Peacecognizable offencepolice inactionland disputeconstitutional petitioncriminal procedure
  Summary & questions settled

  The petitioner challenged an order passed by the Additional Sessions Judge-IV Islamabad-East/Ex-Officio Justice of Peace, whereby his application under Section 22-A & B of the Code of Criminal Procedure 1898 seeking registration of a First Information Report (FIR) was dismissed. The core legal question was whether the Ex-Officio Justice of Peace erred in refusing to direct the registration of an FIR regarding a land dispute involving allegations of illegal dispossession, criminal intimidation, and police inaction. The Islamabad High Court held that no illegality or irregularity was found in the impugned order, as police reports and revenue records established that the proposed accused were in peaceful possession of the land and that no cognizable offence was made out. The petition was accordingly dismissed. The key principle laid down is that where an inquiry and police report reveal no cognizable offence and indicate that the dispute pertains to land possession with prior civil claims, an Ex-Officio Justice of Peace is justified in declining a direction to register an FIR.

  Questions settled

  • Whether an Ex-Officio Justice of Peace is bound to order the registration of an FIR when police reports indicate that no cognizable offence has been made out?
  • Can a petition under Section 22-A & B of the Code of Criminal Procedure 1898 be maintained where the dispute essentially relates to land possession and civil claims?
  • Is the SHO duty-bound to register an FIR under Section 154 of the Code of Criminal Procedure 1898 when allegations of a cognizable offence are contradicted by official inquiry reports?
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• Matloob and others vs Taj Din (deceased) through Legal Heirs and others2025 SCP 24, 2025 SCMR 601, 2025 PLJ SC 231 · Supreme Court of Pakistan · 2025-01-15
  co-operative societynomineeinheritancesuccessionproprietary rightsallotmentlegal heirs
  Summary & questions settled

  This petition under Article 185(3) of the Constitution of Islamic Republic of Pakistan, 1973, challenged a Lahore High Court judgment regarding the inheritance of land allotted under a Co-operative Farming Scheme. The core legal question was whether a nominee of a deceased member of a Co-operative Society can substitute the legal heirs of the deceased member and claim proprietary rights to the allotted land. The Supreme Court held that a nominee does not become the owner of the deceased's interest; rather, nomination merely confers a right to collect or receive assets and does not operate as a gift or a will. The Court affirmed that membership in a society is distinct from succession to the estate of a deceased member. Consequently, the Court dismissed the petition, ruling that in the presence of legal heirs, the nominee cannot succeed to the deceased member's interest, which must devolve upon the heirs according to the applicable law of succession. The Court also noted evidence of fraud regarding the petitioner's claim.

  Questions settled

  • Does the nomination of a person by a member of a Co-operative Society operate as a gift or a will?
  • Can a nominee substitute the legal heirs of a deceased member of a Co-operative Society regarding the deceased's interest in the society?
  • Does the membership of a Co-operative Society automatically confer the right to succeed to the estate of the deceased member?
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• Mati Ullah vs Amin Ullah, etc2025 PHC 212 · Peshawar High Court · 2025-07-28Read full judgment →
• Mateen Khan and others vs Muhammad Ishaque Ali Bux and others2025 SHC HYD 2097 · Sindh High Court · 2025-08-19Read full judgment →
• Matco Rice (Pvt.) Limited vs Syed Aley Sadquain Naqvi and others2025 SHC KHI 1988 · Sindh High Court · 2025-08-04Read full judgment →
• Master Riaz Ahmad, etc, Yaseen Farooq, vs The State, etc, Master Riaz2025 LHC 3235 · Lahore High CourtRead full judgment →
• Mastan Wali Khan vs Prime Minister of Pakistan/Chairman, Gilgit-Baltistan2025 IHC 538 · Islamabad High CourtRead full judgment →
• Masjid-e-Saheem & others vs Pakistan Defence Officers Housing Authority2025 SHC 314 · Sindh High CourtRead full judgment →
• Mashab Ali vs Learned Judge Family Court (East), Islamabad etc2025 IHC 90, 2025 CLC 987 · Islamabad High Court · 2025-02-28Read full judgment →
• Maryam Bibi vs The State and 08 others2025 LHC 5459 · Lahore High Court · 2025-08-26Read full judgment →
• Maroof Ahmed vs The Government of Sindh & Others2025 SHC KHI 1549 · Sindh High Court · 2025-05-23Read full judgment →
• Maqsood Ahmed Khan vs Syed Firdous & others2025 SHC KHI 1078 · Sindh High Court · 2025-05-08Read full judgment →
• Maqbool Hussain and 26 others vs Province of Sindh & others2025 SHC HYD 1511 · Sindh High Court · 2025-05-22
  service lawfraudulent appointmentsalary stoppagedue processcivil servantrecruitment processadministrative inquiry
  Summary & questions settled

  This petition was filed by individuals claiming to be regular employees of the Education and Literacy Department, Government of Sindh, seeking the restoration of salaries and continued employment after their payments were abruptly stopped. The petitioners asserted they were appointed in 2012 through proper procedures and had served for over five years. The respondents contested this, arguing that, with one exception, the petitioners were never lawfully recruited, their documentation was forged, and their salaries were disbursed in violation of sanctioned strength. The core legal question was whether the petitioners, lacking proof of lawful appointment, could claim a vested right to continued employment and salary disbursement. The Court held that the petitioners failed to substantiate their claims with official records, whereas the respondents provided evidence that the appointments were not made through the prescribed recruitment process. The Court affirmed that fraud vitiates any claim to service, regardless of the length of time salaries were received. While acknowledging a procedural lapse regarding the lack of show-cause notices, the Court ruled that this did not cure the fundamental absence of a lawful appointment. The petition was dismissed, and an inquiry into the departmental officials responsible for the unauthorized appointments was ordered.

  Questions settled

  • Can an employee claim a vested right to service based on length of employment if the initial appointment was fraudulent?
  • Does the failure to issue a show-cause notice before stopping salaries cure the fundamental lack of a lawful appointment?
  • Is the burden of proof on the employee to establish a legitimate claim to civil service when the appointment is disputed?
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• Maqbool Ali vs The State, etc2025 LHC 376 · Lahore High Court · 2025-02-20
  post-arrest bailnarcotics recoverypowers of Pakistan RangersControl of Narcotic Substances Actarrest by private individualheroin recovery
  Summary & questions settled

  Through this petition, the petitioner sought post-arrest bail in a case registered under Section 9 (1)-6c of the Control of Narcotic Substances Act, 1997, following the recovery of 1060 grams of heroin by Pakistan Rangers. The core legal questions involved whether Pakistan Rangers had the authority to arrest and detain offenders under the Control of Narcotic Substances Act, 1997, and whether an arrest by a Sub-Inspector of Pakistan Rangers below the specified rank vitiated the proceedings. The Lahore High Court held that Pakistan Rangers officers are authorized under relevant statutory notifications and that, furthermore, the subsequent handing over of the accused to the local police—a power available even to private individuals under Section 59 of the Code of Criminal Procedure, 1898—regularized the proceedings. The court established the principle that recovery of a huge quantity of narcotics connected the accused prima facie to the crime, warranting the dismissal of the bail petition.

  Questions settled

  • Whether Pakistan Rangers have the authority to arrest and detain offenders under the Control of Narcotic Substances Act, 1997?
  • Does an arrest by a Pakistan Rangers officer below the prescribed rank vitiate the entire criminal proceedings?
  • Can a private individual arrest and hand over an accused to the local police under the Code of Criminal Procedure, 1898?
  • Does the recovery of a huge quantity of heroin disentitle an accused to post-arrest bail?
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• Maqbool Ali and another vs Mst. Raheela and others2025 SCP 185 · Supreme Court of Pakistan · 2025-05-13
  constitutional jurisdictionwrit of certiorariconcurrent findingsremandrecovery of dowerfamily courtsubstitution of findings
  Summary & questions settled

  This matter arose from a petition assailing a Peshawar High Court judgment that had allowed a writ petition against concurrent judgments of the Family Court and appellate Court dismissing respondent No.1's suit for recovery of dower, by not only setting aside those judgments but also proceeding to decree the suit itself. The core legal question was whether the High Court, while issuing a writ of certiorari under constitutional jurisdiction with respect to concurrent judgments dismissing a family suit, can substitute its own findings and decree the suit. The Supreme Court held that while the High Court may interfere with concurrent findings of fact if they are based on misreading or non-consideration of evidence, it exceeds its constitutional jurisdiction by substituting its own findings and decreeing the suit instead of remanding the matter. The key principle laid down is that upon finding sufficient grounds to interfere with concurrent factual determinations in writ jurisdiction, the proper course for the High Court is to remand the case to the inferior court or tribunal for a fresh decision rather than acting as a court of appeal or facts.

  Questions settled

  • Whether the High Court in exercise of its constitutional jurisdiction can substitute its own findings of fact and decree a suit after setting aside concurrent judgments of the lower courts?
  • What is the proper course of action for the High Court when it finds grounds to interfere with concurrent findings of fact of subordinate courts or tribunals?
  • Can the High Court act as a court of appeal and decide disputed questions of fact while exercising writ jurisdiction?
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• Maqarab Khan and others vs Muhammad Javaid Khan2025 PHC 200 · Peshawar High Court · 2025-07-02Read full judgment →
• Manzur-ul-Haq vs The Federation of Pakistan and others2025 LHC 443, 2025 PLJ Lahore 465 · Lahore High Court · 2025-02-27Read full judgment →
• Manzoor, Raja, Mushtaque and Dur Muhammad vs The State2025 SHC 8 · Sindh High Court · 2025-01-13
  hurt offensesTa'azirDamansentencing guidelinesfirst-time offendercriminal appealhabitual offender
  Summary & questions settled

  This criminal appeal challenged the judgment of the Additional Sessions Judge, Matiari, which convicted the appellants for various hurt offenses under the Pakistan Penal Code 1860. The core legal question was whether the trial court correctly imposed sentences of imprisonment as Ta'azir upon first-time offenders who did not meet the criteria of being habitual, hardened, or honor-based criminals. The High Court held that the trial court erred in awarding imprisonment. The Court affirmed the convictions and the payment of Daman but set aside the custodial sentences. The key principle laid down is that under Section 337-N of the Pakistan Penal Code 1860, imprisonment as Ta'azir for hurt offenses is not the default punishment for first-time offenders. Such custodial sentences are reserved for habitual, desperate, or dangerous criminals, or those acting under the pretext of honor. Absent such evidence, the court must limit the punishment to financial compensation as prescribed by law, thereby ensuring proportionality in sentencing for non-hardened offenders.

  Questions settled

  • Under what circumstances can a court impose imprisonment as Ta'azir for hurt offenses under the Pakistan Penal Code 1860?
  • Is imprisonment mandatory for a first-time offender convicted of hurt offenses under the Pakistan Penal Code 1860?
  • Does the absence of proof that an accused is a habitual or hardened criminal preclude the imposition of imprisonment as Ta'azir?
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• Manzoor Qadir vs Federation of Pakistan, etc2025 IHC 504 · Islamabad High Court · 2025-06-18Read full judgment →
• Manzoor Hussain Awan and another vs Azad Jammu and Kashmir Ehtesab2025 MLD 911 · Supreme Court of Azad Jammu and Kashmir · 2024-12-12
  acquittal appealdouble presumption of innocencemens reacorruption referenceremand ordercriminal liabilityadministrative negligence
  Summary & questions settled

  This matter concerns appeals against a High Court judgment that remanded a criminal case involving allegations of corruption and forgery. The appellants, government officials, were initially acquitted by the Ehtesab Court of charges related to facilitating the promotion of a co-accused based on a forged certificate. The core legal question was whether the High Court erred in setting aside the acquittal and remanding the case without demonstrating that the trial court's findings were perverse or legally flawed. The Supreme Court held that the prosecution failed to establish mens rea or personal gain by the appellants, noting they acted in a routine administrative capacity following a selection committee's approval. The Court reaffirmed the principle of the 'double presumption of innocence' afforded to an accused upon acquittal, emphasizing that appellate courts should not interfere with an acquittal unless the judgment is perverse, arbitrary, or suffers from grave misreading of evidence. Consequently, the Court set aside the High Court's remand order regarding the appellants, restoring their acquittal, while maintaining the remand for the main accused.

  Questions settled

  • Does the mere issuance of a promotion order by an official, following a selection committee's approval, constitute criminal liability in the absence of proven corrupt intent?
  • What is the threshold for an appellate court to interfere with a trial court's judgment of acquittal?
  • Does the principle of double presumption of innocence apply to an accused who has been acquitted by a trial court?
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• Manzoor Ahmed vs The State2025 SCP 228 · Supreme Court of Pakistan · 2025-05-22
  circumstantial evidenceretracted confessionbenefit of doubtdelayed FIRcapital punishmentlast seen evidencecriminal appeal
  Summary & questions settled

  This criminal appeal challenged the conviction of the appellant for murder under Section 302(b) and sodomy under Section 377 of the Pakistan Penal Code 1860. The core legal question was whether the prosecution’s case, resting entirely on circumstantial evidence—specifically a retracted judicial confession, a last-seen witness, and the recovery of a weapon—was sufficient to sustain a capital sentence. The Supreme Court held that the prosecution failed to establish an unbroken chain of evidence. It observed that the retracted confession lacked independent corroboration, the weapon recovery was from a public place without forensic linkage, and the medical evidence regarding sodomy was inconclusive without DNA comparison. Furthermore, the court emphasized that an unexplained 47-hour delay in registering the FIR cast significant doubt on the veracity of the prosecution's version. Consequently, the court set aside the lower courts' judgments, holding that where circumstantial evidence is incomplete and creates reasonable doubt, the benefit must accrue to the accused. The appellant was acquitted.

  Questions settled

  • Can a conviction be sustained on the basis of a retracted judicial confession without independent corroboration?
  • Does an unexplained delay in registering an FIR necessarily invalidate the prosecution's case?
  • Is a recovery of a weapon from a public place sufficient to link an accused to a crime in the absence of forensic evidence?
  • What is the standard of proof required when a case rests entirely on circumstantial evidence?
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• Manzar Abbas vs Mian Muhammad Azam and 2 others2025 CLC 621 · Lahore High Court · 2024-01-09Read full judgment →
• Manthar Ali Lashari vs Engineer @ Jajo & Others2025 SHC SUK 2042 · Sindh High Court · 2025-07-31
  criminal transfer applicationwitness protectiontransfer of criminal caseapprehension of dangersessions trial
  Summary & questions settled

  This matter concerns a Criminal Transfer Application filed by the complainant seeking to transfer a Sessions case from the Court of Additional Sessions Judge, Kandiaro, to another jurisdiction, citing threats to life and liberty due to the presence of proclaimed absconders from the same area. The core legal question was whether the apprehension of danger and the necessity of travel between Mehrabpur and Kandiaro constitute sufficient grounds for the transfer of a criminal trial. The Court held that the mere distance of 40 kilometers and associated travel concerns do not constitute valid legal grounds for transferring a criminal case. Furthermore, the Court emphasized that the complainant has adequate legal remedies available to ensure safety during court proceedings. The ratio of the decision is that a transfer application cannot be granted solely on the basis of travel distance or generalized fears when statutory protections are available. The key principle laid down is that the Witness Protection Act, 2013, provides the appropriate mechanism for addressing security concerns during trial, rather than the transfer of the proceedings themselves.

  Questions settled

  • Does the distance between the complainant's residence and the trial court constitute a valid ground for the transfer of a criminal case?
  • Can a criminal case be transferred solely on the basis of generalized fears of safety when statutory protection mechanisms are available?
  • Is the Witness Protection Act, 2013, the appropriate remedy for a complainant fearing for their safety during trial proceedings?
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• Mansoor Mujahid vs The State2025 YLR 187 · Sindh High Court · 2024-10-07
  murdercircumstantial evidencebenefit of the doubtdelayed FIRdoubtful recoveryexculpatory judicial confessioncriminal appeal
  Summary & questions settled

  This criminal appeal challenges the judgment of the trial court convicting the appellants under Section 302(b) read with Section 34 of the Pakistan Penal Code 1860 and Section 297 read with Section 34 of the Pakistan Penal Code 1860. The core legal question involves whether the prosecution successfully established the guilt of the appellants beyond a reasonable doubt in the absence of direct eyewitnesses, relying instead on weak circumstantial evidence, delayed reporting, doubtful recoveries, and an exculpatory judicial confession. The Sindh High Court held that the prosecution failed to prove its case beyond a reasonable doubt due to unexplained delays in lodging the FIR and recording witness statements, material contradictions and tampering in recovery memos, and unverified forensic evidence. Consequently, the High Court set aside the convictions and sentences, extending the benefit of the doubt to the appellants and ordering their immediate acquittal and release. The key principle laid down is that when direct evidence is lacking, weak and uncorroborated circumstantial evidence coupled with unexplained investigative delays cannot sustain a conviction, and a single circumstance creating a reasonable doubt entitles the accused to acquittal as a matter of right.

  Questions settled

  • Whether an accused is entitled to an acquittal when the prosecution relies solely on circumstantial evidence that suffers from unexplained delays and doubtful recoveries?
  • Can a conviction for murder be sustained on the basis of an exculpatory judicial confession and compromised forensic evidence?
  • What is the evidentiary value of statements recorded under Section 161 of the Code of Criminal Procedure 1898 when there is an unexplained delay in their recording?
  • What presumption arises under Article 129(g) of the Qanun-e-Shahadat Order 1984 when material prosecution witnesses are given up during trial?
  Read full judgment →
• Mansoor Ahmed Khan, Director of Mangla Metals (Pvt.) Ltd., Islamabad vs Kohsar Hydro Ltd. through Chief Executive Officer (CEO), Mirpur and others2025 PLD High Court (AJ&K) 1, 2025 PLJ AJ&K 23 · High Court of Azad Jammu and KashmirRead full judgment →
• Manan Khan s/o Awal Khan Pathan vs The State2025 SHC LAR 1926 · Sindh High Court · 2025-07-22
  narcoticschain of custodychemical examiner reportbenefit of doubtsafe transmissioncriminal appealacquittal
  Summary & questions settled

  This criminal appeal challenges the conviction of the appellant for an offence under Section 9(c) of the Control of Narcotic Substances Act, 1997, resulting in a sentence of life imprisonment. The core legal questions concern whether the prosecution established an unbroken chain of custody for the recovered narcotics and whether the chemical examiner's report met mandatory procedural protocols. The Court held that the prosecution failed to prove its case beyond a reasonable doubt due to significant procedural lapses. Specifically, the failure to produce the Head Moharrir (custodian of case property) and the official who transported the samples to the laboratory created a fatal break in the chain of custody. Furthermore, the chemical examiner's report was found defective for failing to detail the specific testing protocols required by law. The Court emphasized that in narcotics cases, the prosecution must strictly establish the safe custody and transmission of evidence. Consequently, the conviction was set aside, and the appellant was acquitted, with the Court reiterating that any missing link in the chain of custody entitles the accused to the benefit of the doubt.

  Questions settled

  • Does the failure to examine the Head Moharrir regarding the custody of case property constitute a fatal defect in a narcotics case?
  • Is a chemical examiner's report that fails to detail the specific testing protocols used admissible to sustain a conviction?
  • Does the failure to establish the safe transmission of samples from the recovery site to the laboratory entitle the accused to the benefit of the doubt?
  • Can a conviction be sustained when the complainant is also the investigating officer and there are significant contradictions in the prosecution's evidence?
  Read full judgment →
• Manahil Imran & another vs Muhammad Sadiq Khurshid & another2025 SHC KHI 1832 · Sindh High Court · 2025-07-07Read full judgment →
• Manaf Ali & 26 Others vs Federal Employees Cooperative Housing Society2025 IHC 142 · Islamabad High Court · 2025-04-07Read full judgment →
• Malik Taus Ur Rehman vs Special Judge Central Islamabad & another2025 IHC 436 · Islamabad High Court · 2025-06-17Read full judgment →
• Malik Shoukat Ali Awan vs Ghulam Hussain (deceased) through LRs. etc2025 LHC 558 · Lahore High Court · 2025-02-19Read full judgment →
• Malik Saghir Ahmed Nazir vs The State and 4 others2025 SHC 541 · Sindh High Court · 2025-02-14
  quashing of FIRcognizance of offenceinvestigation reportB classmalafide intentionelectricity theftcriminal miscellaneous application
  Summary & questions settled

  This criminal miscellaneous application challenges an order passed by a Judicial Magistrate accepting a police challan and taking cognizance of an offence against the applicant under Sections 392, 397, and 34 of the Pakistan Penal Code. The core legal question revolves around whether the Magistrate lawfully took cognizance of the offence without proper application of mind and without considering the initial police investigation report which had recommended disposal of the case in "B" class after finding the applicant innocent while performing official duties preventing electricity theft. The Sindh High Court held that the impugned order was passed in haste, overlooking the peculiar facts, and that the complainant, an advocate, had initiated the proceedings with mala fide intentions to counter allegations of electricity theft. Consequently, the court set aside the impugned order and quashed the FIR and its consequent proceedings. The key principle laid down is that criminal proceedings initiated with ulterior motives or mala fides, particularly ignoring exonerating material collected during police investigation, are liable to be quashed to prevent abuse of the court's process.

  Questions settled

  • Whether a Magistrate can accept a police challan and take cognizance without considering the initial exonerating investigation report?
  • Can criminal proceedings be quashed when an FIR is lodged with mala fide intentions and ulterior motives?
  • Does the High Court have the authority to set aside an order of cognizance passed in haste and without the application of a conscious judicial mind?
  Read full judgment →
• Malik Muhammad Sarfraz Nazam Awan vs Federal Government, Ministry of Commerce through its Secretary, Islamabad and 3 others2025 LHC 1092, 2025 PLJ Lahore 568 · Lahore High CourtRead full judgment →
• Malik Muhammad Imran & 3 others vs The State & others2025 LHC 3333 · Lahore High Court
  murder referenceocular evidenceinjured witnessdelayed FIRmedical evidence contradictioncriminal appealacquittalbenefit of doubt
  Summary & questions settled

  This criminal appeal challenges the convictions and sentences imposed by the trial court for murder and related offences under the Pakistan Penal Code 1860. The core legal questions concerned the reliability of the prosecution's ocular account, the impact of significant delays in FIR registration, and the effect of contradictions between medical and ocular evidence. The Lahore High Court held that the prosecution failed to prove its case beyond a reasonable doubt. The court found that the FIR was lodged after an unexplained delay and appeared to be the result of deliberation. Furthermore, the court observed that the testimony of injured witnesses, while indicating their presence, did not automatically establish their truthfulness, especially when contradicted by medical evidence. The court emphasized that when primary ocular evidence is disbelieved, corroborative evidence like weapon recoveries and motive loses its significance. Consequently, the court set aside the convictions and sentences, acquitted the appellants, and answered the murder reference in the negative, establishing that a single doubt-creating circumstance in the prosecution's case warrants the acquittal of the accused.

  Questions settled

  • Does the presence of injuries on an eyewitness automatically render their testimony truthful and reliable?
  • What is the legal effect of a significant, unexplained delay in the registration of an FIR?
  • Can a conviction be sustained when there is a glaring contradiction between the ocular account and the medical evidence?
  • Does the failure to prove the alleged motive weaken the prosecution's case?
  Read full judgment →
• Malik Muhammad Akram Bhatti vs Nadeem Abbas etc2025 LHC 3460 · Lahore High Court · 2025-05-16Read full judgment →
• Malik Mudassar Ali and others vs Secretary, Public Prosecution2025 LHC 1154 · Lahore High Court
  prosecutorial independencedisciplinary proceedingslegal opinionacquittal appealcriminal prosecution serviceconstitutional jurisdictionpublic servant
  Summary & questions settled

  This writ petition under Article 199 of the Constitution of Pakistan, 1973 was filed by members of a District Appeal Committee challenging disciplinary proceedings and inquiry reports initiated against them for concurring with a trial prosecutor's opinion that a particular acquittal judgment was not fit to be appealed. The core legal question centered on whether departmental proceedings under the PEEDA Act, 2006 could be initiated against prosecutors for their legal opinions without a reference from the Prosecutor General under Section 10(2) of the Punjab Criminal Prosecution Service (Constitution, Functions and Powers) Act, 2006. The Lahore High Court held that the petition was maintainable notwithstanding Article 212 since it concerned statutory powers rather than service terms and conditions, and that disciplinary proceedings initiated without a formal reference from the Prosecutor General or District Public Prosecutor were illegal and without jurisdiction. The key principle laid down is that prosecutors acting bona fide in rendering legal opinions are protected under the law, and departmental action against them for such opinions requires strict adherence to statutory prerequisites including a reference from the Prosecutor General.

  Questions settled

  • Whether disciplinary proceedings can be initiated against a prosecutor for forming a legal opinion without a reference from the Prosecutor General?
  • Does the bar contained in Article 212 of the Constitution of Pakistan bar a constitutional petition challenging disciplinary action that does not touch upon the terms and conditions of service?
  • Are prosecutors protected under the law for rendering bona fide legal opinions regarding the fitness of a case for appeal?
  • What is the statutory role and hierarchical authority of the Prosecutor General under the Punjab Criminal Prosecution Service Act, 2006?
  Read full judgment →
• Malik Hamid Raza vs Additional District Judge, etc2025 LHC 4664 · Lahore High Court · 2025-06-12Read full judgment →
• Malik Farman Ullah Khan vs The Controlling Authority, Board of Intermediate and Secondary Education_Chief Minister and others2025 MLD 73 · Peshawar High Court · 2023-05-30Read full judgment →
• Malik Basit vs Mst. Razia Sultana, etc2025 IHC 208 · Islamabad High Court · 2025-03-24Read full judgment →
• Malik Ameer Haider Sangha vs Federation of Pakistan and 05 others2025 LHC 3836 · Lahore High Court · 2025-06-02Read full judgment →
• Malik Abdul Rauf vs Malik Abdul Razzaq (deceased) through L.Rs., etc2025 LHC 526 · Lahore High Court · 2025-02-26Read full judgment →
• Malik Abdul Rasheed vs Jafar Hussain Bhatti2025 IHC 514 · Islamabad High Court · 2025-07-02Read full judgment →
• Makhdoom Haider Shah vs Mustafa Haider Shah and another2025 MLD 397 · Peshawar High Court · 2024-10-04
  post-arrest bailbail cancellationmurdertrial in progressmisuse of bailperverse order
  Summary & questions settled

  This criminal petition was filed by the complainant seeking the cancellation of post-arrest bail granted to the accused/respondent by the Additional Sessions Judge-VI, Haripur, in a case involving multiple murders. The core legal question was whether the bail granted to the accused should be cancelled, particularly given that the trial had already commenced. The Peshawar High Court dismissed the petition, holding that the complainant failed to demonstrate any strong or exceptional grounds required for the cancellation of bail. The Court emphasized that once bail is granted by a court of competent jurisdiction, it cannot be recalled unless the order is patently illegal, perverse, or if the accused has misused the concession of liberty, such as by tampering with evidence or absconding. Furthermore, the Court reiterated the established principle that bail cancellation petitions should not be encouraged when the trial is already in progress, as this avoids premature discussion on the merits of the case. Finding no perversity or disregard for legal principles in the impugned bail order, the High Court declined to interfere.

  Questions settled

  • What are the specific grounds required for the cancellation of bail once it has been granted by a court of competent jurisdiction?
  • Should a court entertain a petition for the cancellation of bail when the trial of the case is already in progress?
  • What constitutes a perverse order in the context of granting bail?
  Read full judgment →
• Makhdoom Fazal Hussain Qureshi through Lawful Attorney vs The Returning Officer, National Assembly - 219 (Na-219 Hyderabad-II) and 2 others2025 YLR 1092 · Sindh High Court · 2024-01-06Read full judgment →
• Major Tariq Lodhi through Attorney Rahim Bux Maitlo, vs Mst. Asma2025 SHC KHI 1847 · Sindh High Court · 2025-06-05Read full judgment →
• Majid Javed alias Javed Ali vs The State, etc2025 LHC 4548 · Lahore High Court · 2025-06-25
  Criminal RevisionSummoning of witnessCourt witnessProduction of documentsJust decision of the caseMaterial irregularityQatl-e-Amd
  Summary & questions settled

  This criminal revision petition challenged an order passed by the Additional Sessions Judge, Multan, which dismissed the petitioner's application to summon a Control Room Wireless Operator as a court witness along with specific call records. The core legal question was whether the trial court erred in refusing to exercise its powers under the Code of Criminal Procedure 1898 to summon evidence deemed essential for the defense. The High Court allowed the revision, set aside the impugned order, and directed the trial court to summon the witness and the records. The court held that under Section 540 of the Code of Criminal Procedure 1898, the court is empowered and obligated to summon any witness whose evidence is essential for a just decision. Furthermore, under Section 265-F(7), the court must issue process for witnesses requested by the accused unless the application is vexatious or intended to delay proceedings. The court emphasized that relevant evidence, such as control room records, must be admitted to prevent a miscarriage of justice.

  Questions settled

  • Is the trial court obligated to summon a witness if their evidence is essential for the just decision of the case under Section 540 of the Code of Criminal Procedure 1898?
  • Under what circumstances can a trial court refuse an application by an accused to summon a witness for examination after entering their defence?
  • Does the failure of a trial court to provide cogent reasons for rejecting an application to summon a material witness constitute a material irregularity?
  Read full judgment →
• Majid Ali vs The State & another2025 LHC 4774 · Lahore High Court · 2025-04-24
  post-arrest bailcriminal breach of trustcommercial transactioncivil liabilityfiduciary capacityentrustment of property
  Summary & questions settled

  The petitioner sought post-arrest bail in a case registered under Section 406 of the Pakistan Penal Code 1860, following allegations of criminal breach of trust regarding the non-payment for stainless steel sheets purchased from the complainant. The core legal question was whether a commercial transaction involving the purchase of goods, where payment remains outstanding, constitutes criminal breach of trust under Section 405 of the Pakistan Penal Code 1860. The Court held that the transaction was essentially a commercial sale rather than an entrustment of property. It emphasized that for Section 406 to apply, there must be a fiduciary relationship where property is entrusted to the accused to be retained or disposed of under specific conditions, not merely a failure to pay for purchased goods. The Court determined that the allegations, even if true, suggested a civil liability or potentially cheating under Section 420 of the Pakistan Penal Code 1860, rather than criminal breach of trust. Consequently, the Court granted post-arrest bail, noting that the petitioner's continued incarceration was unnecessary given the nature of the dispute.

  Questions settled

  • Does the failure to pay for goods purchased in a commercial transaction constitute criminal breach of trust under Section 406 of the Pakistan Penal Code 1860?
  • What are the essential ingredients required to establish the offence of criminal breach of trust under Section 405 of the Pakistan Penal Code 1860?
  • Can a mere assertion in an F.I.R. that goods were held as a 'trust' convert a commercial sale into a criminal breach of trust?
  • Is the offence of cheating under Section 420 of the Pakistan Penal Code 1860 bailable under the Code of Criminal Procedure 1898?
  Read full judgment →
• Mairemunishahan vs Director General of Immigration & Passports, etc2025 IHC 218 · Islamabad High Court · 2025-04-09Read full judgment →
• Mahle Engine Components Japan Corporation and others vs Azam Autos2025 SHC 1, 2025 PLJ Karachi 55 · Sindh High CourtRead full judgment →
• M. Shaheryar vs The State2025 PLD Sindh 90 · Sindh High Court · 2024-07-24
  pre-arrest bailconcurrent jurisdictiondishonoured chequejudicial proprietymaliceprohibitory clausesessions court
  Summary & questions settled

  This matter involves an application for pre-arrest bail filed directly before the High Court by the accused, Muhammad Shaheryar, in connection with an FIR registered under Section 489-F of the Pakistan Penal Code 1860 regarding dishonoured cheques. The core legal questions addressed relate to whether an accused can bypass the Court of Session to approach the High Court directly for pre-arrest bail under Section 498 of the Code of Criminal Procedure 1898, and whether pre-arrest bail should be confirmed based on merits and established mala fides. The Sindh High Court held that while judicial propriety generally dictates approaching the court of first instance first, compelling circumstances—such as threats or barriers preventing access to the lower court—permit the High Court to entertain a direct pre-arrest bail application by invoking its concurrent and co-extensive jurisdiction. The court confirmed the pre-arrest bail, laying down the principle that if an accused establishes compelling reasons for bypassing the Sessions Court and makes out a proper case for bail, the High Court is fully empowered to grant relief on merits.

  Questions settled

  • Can an accused approach the High Court directly for pre-arrest bail without first moving the Sessions Court?
  • Whether the jurisdiction of the High Court and the Court of Session to grant pre-arrest bail is concurrent and co-extensive?
  • Does the existence of compelling circumstances justify bypassing the court of first instance in pre-arrest bail matters?
  • Can merits of the case and mala fides be considered together while deciding a pre-arrest bail application?
  Read full judgment →
• M Muhammad Feroz-ud-din Hilali vs Nadir & others2025 SCP 105 · Supreme Court of Pakistan · 2025-03-25
  Order XVII Rule 3 CPCSection 100 CPCfailure to produce evidenceadjournment applicationclosure of sideconcurrent findingsIllegal Dispossession Act 2005leave to appeal
  Summary & questions settled

  Civil petition for leave to appeal arose from the concurrent dismissal of the petitioner's suit and subsequent appeals. Originally, the petitioner's complaint under the Illegal Dispossession Act, 2005 was dismissed, following which his civil suit was also dismissed by the trial court under Order XVII Rule 3 of the Code of Civil Procedure 1908 after repeated adjournments and failure to produce evidence. The first appeal and second appeal under Section 100 CPC were likewise dismissed. Before the Supreme Court, the petitioner contended that the trial court misapplied Order XVII Rule 3 CPC without formally closing his side for evidence prior to dismissing the suit. The Supreme Court held that Order XVII Rule 3 CPC is triggered when a party fails to produce evidence despite opportunities, permitting the court to decide the suit forthwith. Furthermore, the petitioner had omitted this specific objection in his grounds before the lower appellate forums. Upholding the concurrent findings of the three courts below, the Supreme Court refused leave and dismissed the petition.

  Questions settled

  • Whether the trial court can forthwith decide a suit under Order XVII Rule 3 of the Code of Civil Procedure 1908 upon the dismissal of an adjournment application when a party fails to produce evidence despite being granted a last opportunity?
  • Is a party permitted to raise a new plea regarding the formal closure of evidence before the Supreme Court when such ground was not raised before the lower appellate courts?
  • What is the scope of interference by the Supreme Court against concurrent findings of fact recorded under Section 100 of the Code of Civil Procedure 1908?
  Read full judgment →
• Lutaf Ali vs The State2025 YLR 604 · Sindh High Court · 2024-10-22
  murderretracted judicial confessioneye-witness testimonycriminal appealcharge framingunborn childdelay in FIRappreciation of evidence
  Summary & questions settled

  This criminal appeal challenged the conviction of the appellant for the murder of his mother-in-law. The trial court had convicted the appellant on two counts of murder, including the death of the deceased's unborn child, under Section 302(b) of the Pakistan Penal Code 1860. The core legal questions concerned the reliability of eye-witness testimony, the impact of a one-day delay in lodging the FIR, the admissibility of a retracted judicial confession, and the validity of a conviction for an offense not included in the formal charge. The High Court held that the prosecution proved the murder of the mother-in-law beyond a reasonable doubt through consistent eye-witness accounts, medical evidence, and a voluntary judicial confession. However, the Court set aside the conviction regarding the unborn child, ruling that the appellant could not be convicted for an offense for which he was not formally charged. The judgment reaffirms that while corroboration is a rule of caution, credible eye-witness testimony remains sufficient for conviction, and procedural fairness requires that an accused be formally charged for every offense for which they are convicted.

  Questions settled

  • Can an accused be convicted for an offense that was not included in the original charge?
  • Is a retracted judicial confession admissible if it was made voluntarily and with the object of telling the truth?
  • Does a delay in lodging an FIR necessarily invalidate the prosecution's case?
  • Is corroboration of eye-witness testimony a rule of law or a rule of caution?
  Read full judgment →
• Lt. Col. (R) Khalil-Ur-Rehman vs Judicial Magistrate (Section 30), Islamabad-West, Etc2025 IHC 578 · Islamabad High Court · 2025-08-13Read full judgment →
• Loung and 02 others vs The State2025 SHC HYD 1839 · Sindh High Court · 2025-07-04
  criminal appealmurder convictionrelated witnessesinterested witnessesfalsus in unoinvestigative lapsesFIR delaycommon intention
  Summary & questions settled

  This criminal appeal challenges the judgment of the 2nd Additional Sessions Judge, Badin, which convicted the appellants for murder and related offences under the Pakistan Penal Code 1860. The core legal questions concerned the reliability of related eyewitnesses in the presence of admitted enmity, the impact of a 14-hour delay in lodging the FIR, and whether procedural investigative lapses warranted acquittal. The Court dismissed the appeal, upholding the convictions and sentences. It held that the prosecution proved its case beyond reasonable doubt through consistent ocular testimony corroborated by medical and forensic evidence. The Court affirmed that related witnesses are natural witnesses if their presence is probable, and enmity is a double-edged sword that can provide a motive for the crime rather than just a reason for false implication. Furthermore, the Court clarified that the maxim falsus in uno, falsus in omnibus is not applied mechanically to trivial inconsistencies, and minor investigative irregularities do not vitiate a case when the core evidence remains cogent and confidence-inspiring.

  Questions settled

  • Does the existence of prior enmity between parties automatically render the testimony of related eyewitnesses unreliable?
  • Can a conviction be sustained when there are minor investigative lapses or procedural irregularities in the police investigation?
  • Is the doctrine of falsus in uno, falsus in omnibus to be applied mechanically to every minor inconsistency in witness testimony?
  • Does a delay in lodging an FIR necessarily invalidate the prosecution's case if the delay is explained by the need to attend to the injured and deceased?
  Read full judgment →
• Liaquat Ali vs Federation of Pakistan & others2025 SHC KHI 1998 · Sindh High Court · 2025-08-05Read full judgment →
• Liaquat Ali s/o Ali Nawaz and others vs The State2025 SHC LAR 1608 · Sindh High Court · 2025-05-30
  criminal appealbenefit of doubtocular evidenceFIR delayappreciation of evidencemurder convictionmedical jurisprudence
  Summary & questions settled

  This criminal appeal challenged the conviction and life imprisonment sentence imposed by the Trial Court for murder under Section 302(b) of the Pakistan Penal Code 1860. The core legal question was whether the prosecution successfully established the appellants' guilt beyond reasonable doubt, given significant evidentiary discrepancies. The High Court held that the prosecution failed to meet this standard, citing multiple fatal flaws: an unexplained four-hour delay in FIR registration, material contradictions between the number of shots fired and recovered empties, and an ambiguous medical report failing to identify the fatal injury. Furthermore, the court noted the unnatural conduct of eyewitnesses who remained unscathed during alleged close-range firing, casting doubt on their presence. The court reiterated the principle that where prosecution evidence is riddled with contradictions, lacunae, and unreliable testimony, the benefit of doubt must be extended to the accused. Consequently, the court set aside the impugned judgment and acquitted the appellants, emphasizing that criminal conviction requires proof beyond reasonable doubt, which was absent in this case.

  Questions settled

  • Does an unexplained delay in the registration of an FIR provide sufficient grounds to doubt the prosecution's case?
  • Can a conviction be sustained when there is a material contradiction between the number of shots alleged to have been fired and the number of crime empties recovered?
  • Does the failure of eyewitnesses to sustain injuries during alleged close-range firing cast doubt on their presence at the crime scene?
  • Is a conviction sustainable when the prosecution fails to attribute specific roles to individual accused persons in a joint trial?
  Read full judgment →
• Liaqat Ali Fazlani vs GM SSGC and others2025 SHC KHI 1933 · Sindh High Court · 2025-07-17
  constitutional petitionmaster and servantnon-statutory ruleswrit jurisdictiondisciplinary proceedingsshow-cause noticestate-owned entity
  Summary & questions settled

  This constitutional petition was filed by a Deputy Manager of Sui Southern Gas Company (SSGC) challenging a suspension order and a show-cause notice issued for unauthorized absence from duty. The petitioner, facing disciplinary proceedings under SSGC's Human Resources Policy, sought to set aside the proceedings and perform his duties until his upcoming retirement. The core legal question was whether a constitutional petition under Article 199 of the Constitution of Pakistan 1973 is maintainable for an employee of a state-owned entity whose terms of service are governed by non-statutory rules. The High Court of Sindh dismissed the petition in limine, holding that because SSGC's HR Policy is non-statutory, the relationship between the parties is governed by the principle of master and servant. Consequently, the court's writ jurisdiction cannot be invoked to enforce contractual terms of service, and the petitioner's proper remedy is to approach a civil court or seek internal departmental redress, while ensuring that the employer respects the fundamental right to a fair trial under Article 10-A.

  Questions settled

  • Is a constitutional petition under Article 199 of the Constitution maintainable for an employee of a state-owned corporation whose service rules are non-statutory?
  • Does the adoption of internal service rules or an HR policy by a state-owned company's Board of Directors elevate those rules to statutory status?
  • What is the appropriate legal remedy for a non-worker managerial employee of a state-owned entity seeking to challenge disciplinary actions when governed by the principle of master and servant?
  • Does the fundamental right to a fair trial under Article 10-A of the Constitution apply to disciplinary inquiries conducted under non-statutory service rules?
  Read full judgment →
• LESCO through its Chief Executive Officer, Lahore etc vs M/s. Exporient2025 LHC 3958 · Lahore High Court · 2025-04-30Read full judgment →
• Lawyers Coop. Housing Society Ltd Larkana vs Asst. Registrar Coop.2025 SHC KHI 1551 · Sindh High Court · 2025-05-23Read full judgment →
• Lal Shad vs The State2025 IHC 46 · Islamabad High Court · 2025-02-04
  post-arrest bailControl of Narcotic Substances Actconscious possessiondriver liabilityrule of consistencyprohibitory clause
  Summary & questions settled

  This petition for post-arrest bail was filed in the Islamabad High Court by the petitioner, who was arrested in connection with FIR No. 493 registered under Section 9(1)3c of the Control of Narcotic Substances Act, 1997. The prosecution alleged that 3,472 grams of charas were recovered from underneath the front passenger seat of a vehicle driven by the petitioner. The core legal questions pertained to whether the driver of a vehicle can be attributed conscious possession of narcotics recovered from the vehicle and whether the rule of consistency applies when bail was granted to a co-accused passenger. The court dismissed the bail petition, holding that as the driver of the vehicle, the petitioner had control, charge, and conscious knowledge of articles contained therein. The court further held that the rule of consistency did not apply because the petitioner's role as the driver differed from that of the passenger, and the offense fell within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898.

  Questions settled

  • Does the driver of a vehicle exercise control and conscious possession over narcotics recovered from within that vehicle?
  • Can the rule of consistency be invoked for bail when the applicant is the driver of a vehicle and the co-accused granted bail was merely a passenger?
  • Is an applicant entitled to post-arrest bail under Section 497 Cr.P.C. when a commercial or substantial quantity of narcotics is recovered from a vehicle under their control?
  Read full judgment →
• Lal Muhammad vs The State2025 YLR 769 · Sindh High Court · 2024-08-19
  post-arrest bailidentification paradeprohibitory clausefurther inquiryrobberyevidentiary value
  Summary & questions settled

  This bail application concerns an accused, Lal Muhammad, seeking post-arrest bail in a case involving robbery and causing injury (Sections 394, 397, and 34, Pakistan Penal Code 1860). The core legal question was whether the applicant was entitled to bail given the prosecution's reliance on an identification parade conducted with significant delay and the absence of recovery of the alleged robbed property. The Court held that the identification parade, conducted ten days after the applicant's arrest, lacked authenticity due to the unexplained delay. Furthermore, the Court noted the absence of recovery of the alleged robbed mobile phone or any device linking the applicant to the crime. Crucially, the Court observed that the offenses charged did not fall within the prohibitory clause of Section 497, Code of Criminal Procedure 1898. Consequently, the Court granted bail, holding that the case against the applicant required further inquiry under Section 497(2), Code of Criminal Procedure 1898. The principle laid down is that an identification parade held with unexplained delay loses its evidentiary value, and where the offense does not fall within the prohibitory clause, the case warrants further inquiry for bail purposes.

  Questions settled

  • Does an identification parade held with an unexplained delay lose its authenticity for the purpose of bail?
  • Does a case where the maximum punishment for the charged offenses does not exceed the prohibitory clause of Section 497, Code of Criminal Procedure 1898, warrant further inquiry?
  • Is the absence of recovery of robbed property a relevant factor in determining the entitlement to post-arrest bail?
  Read full judgment →
• Lal Bux Narejo vs Province of Sindh and others2025 PLJ Karachi 97 · Sindh High Court · 2025-04-03Read full judgment →
• Lajpat vs The State2025 SHC 758 · Sindh High Court · 2025-05-06Read full judgment →
• Lahore High Court Bar Association and others vs Province of Punjab and others2025 LHC 3893 · Lahore High Court · 2025-06-02Read full judgment →
• Lahore Development Authority through Director General vs Farah Inam2025 MLD 182 · Lahore High Court · 2024-09-26Read full judgment →
• Kulsoom and another vs Province of Sindh through Home Secretary, Sindh2025 MLD 201 · Sindh High Court · 2024-07-26Read full judgment →
• Kousar Ghulam Haider vs Abdul Waseem, etc.2025 IHC 212 · Islamabad High Court · 2025-04-08Read full judgment →
• Kiran Ehsan, Rehana Kauser vs The State, etc, Kiran Ehsan, etc2025 LHC 4162, 2025 LHC 4176 · Lahore High Court · 2025-06-11Read full judgment →
• Kiran Bibi vs Addl. Sessions Judge, etc2025 LHC 987 · Lahore High Court · 2025-03-06
  criminal revision petitionoutraging modestyAnti-Rape ActSpecial Courtalteration of chargejurisdictionscheduled offences
  Summary & questions settled

  This criminal revision petition challenged an order passed by the Additional Sessions Judge/GBV/Special Court, which deleted the offence under Section 354 PPC from the charge and referred the file to the District and Sessions Judge for entrustment to a Judicial Magistrate on the ground that the remaining offences were not scheduled offences under the Anti-Rape (Investigation and Trial) Act, 2021. The core legal question concerned the propriety of deleting an offence during trial by making a tentative assessment of the material without recording evidence, and whether the Special Court correctly relinquished jurisdiction. The Lahore High Court held that the impugned order contained no illegality, perversity, or jurisdictional defect, as the Special Court possessed the prerogative under Section 16(3) of the Anti-Rape Act read with Section 227 of the Code of Criminal Procedure, 1898 to alter or amend charges and determine if an offence is made out. The Court laid down that Special Courts must interpret the Anti-Rape Act purposively, and that a trial court is competent to alter charges or evaluate the applicability of scheduled offences based on the material on record.

  Questions settled

  • Whether a Special Court under the Anti-Rape (Investigation and Trial) Act, 2021 can delete an offence and transfer the case if it finds that no scheduled offence is made out?
  • Can a criminal court alter or delete a charge during trial before recording evidence?
  • What constitutes the foundational requirement to establish an offence under Section 354 of the Pakistan Penal Code 1860?
  • Does a Special Court have the power to try non-scheduled offences when they are inextricably linked with scheduled offences?
  Read full judgment →
• Kifayat Ullah Khan vs Waheed UIIah, etc2025 PHC 204 · Peshawar High Court · 2025-07-11Read full judgment →
• Khursheed Ahmed vs Ghulam Abbas Jagirani & others2025 SHC LAR 2239 · Sindh High Court · 2025-09-04Read full judgment →
• Khurshed Ali Khan vs Muhammad Ayub and others2025 SCP 174 · Supreme Court of Pakistan · 2025-05-08
  dismissal for non-prosecutionrestoration applicationcondonation of delayripe for hearingsettlement of issuescivil procedureleave to appeal
  Summary & questions settled

  The petitioner filed a civil suit which was subsequently dismissed for non-prosecution when the plaintiff failed to appear on the date fixed for evidence, despite the defendants being present. A belated restoration application accompanied by an application for condonation of delay was dismissed by the trial court for insufficient grounds, and the appellate court upheld this decision. The core legal question before the Supreme Court was whether a suit could be dismissed for non-prosecution on a date fixed for hearing when other miscellaneous applications were also pending. The Supreme Court held that once issues are framed, the suit becomes ripe for hearing, and it is well within the trial court's discretion to dismiss the suit for non-prosecution upon the plaintiff's default on such a date, regardless of pending incidental applications. The petition for leave to appeal was accordingly dismissed.

  Questions settled

  • Whether a suit can be dismissed for non-prosecution when other pending applications are listed on the same day?
  • At what stage does a civil suit become ripe for hearing for the purpose of dismissal due to non-appearance?
  • Whether the absence of a plaintiff on the date fixed for evidence warrants the dismissal of the suit for non-prosecution?
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• Khurram Masih vs The State2025 IHC 234 · Islamabad High Court · 2025-04-14
  narcotics possessionsafe custodychemical analysiscriminal appeallaboratory reportschain of custodybenefit of doubt
  Summary & questions settled

  This appeal challenges a conviction under Section 9(c) of the Control of Narcotic Substances Act, 1997, for the possession of 21,025 grams of Charas. The core legal question concerns whether the prosecution established the safe custody and transmission of the recovered contraband, given contradictions in laboratory reports and witness testimony regarding the identity of the official who deposited the samples. The court held that while the prosecution failed to prove the safe transmission of all twenty samples due to discrepancies naming an official not produced as a witness, it successfully established the possession of five kilograms of Charas supported by a consistent laboratory report. Consequently, the court partially allowed the appeal, reducing the sentence to seven years and six months of rigorous imprisonment. The judgment affirms the principle that in narcotics cases, the prosecution must strictly prove the safe custody and transmission of samples; discrepancies in laboratory reports regarding the identity of the person depositing samples create reasonable doubt, requiring the exclusion of those specific samples from the conviction calculation.

  Questions settled

  • Does a discrepancy in the name of the official depositing samples in laboratory reports vitiate the entire prosecution case in narcotics trials?
  • Can a conviction for narcotics possession be sustained for a lesser quantity than originally charged if the prosecution fails to prove the safe transmission of all recovered samples?
  • Does the failure to exhibit the vehicle used for transporting narcotics during the trial automatically entitle the accused to an acquittal?
  • Is the investigation of a narcotics case by the complainant himself a ground for automatic acquittal?
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• Khudadad, The State vs The State & another, Khudadad2025 LHC 3318 · Lahore High Court · 2025-05-12
  criminal appealmurder referencebenefit of doubtocular evidencemedical evidenceFIR delayweapon recoveryappellate jurisdiction
  Summary & questions settled

  This criminal appeal challenges the conviction and death sentence imposed by the trial court for the murder of the deceased. The core legal question is whether the prosecution established the appellant's guilt beyond reasonable doubt, given the alleged evidentiary inconsistencies. The Lahore High Court allowed the appeal, set aside the conviction, and acquitted the appellant, answering the murder reference in the negative. The court held that the prosecution's case was undermined by an unexplained delay in FIR registration, material improvements in the statements of eyewitnesses, and a glaring contradiction between the ocular account and medical evidence regarding the firing distance and weapon type. Additionally, the court found the alleged motive unproven and the recovery of the weapon suspicious, particularly as the inquest report failed to record the recovery of crime empties. The court reaffirmed the principle that any material loophole or inconsistency in the prosecution's evidence entitles the accused to the benefit of doubt, necessitating acquittal to avoid the risk of punishing an innocent person.

  Questions settled

  • Does an unexplained delay in the registration of an FIR, coupled with the non-production of a key police witness, create reasonable doubt regarding the prosecution's case?
  • Can a conviction be sustained when there is a material contradiction between the ocular account and the medical evidence regarding the distance from which shots were fired?
  • Does the failure of the prosecution to prove the alleged motive for a crime entitle the accused to an acquittal?
  • Is the recovery of a weapon reliable when the inquest report fails to mention the recovery of crime empties from the scene?
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• Khizar Hayat vs The State2025 SCP 183 · Supreme Court of Pakistan · 2025-04-28
  criminal appealbenefit of doubtocular evidencecorroborationmotiveFIR delayacquittal
  Summary & questions settled

  This criminal appeal arises from a conviction for murder under section 302(b) of the Pakistan Penal Code 1860. The appellant challenged the Lahore High Court's judgment, which had reduced his death sentence to life imprisonment. The core legal question was whether the prosecution had proven its case beyond reasonable doubt given the evidentiary inconsistencies. The Supreme Court held that the prosecution failed to establish the guilt of the appellant. Key factors included the unexplained delay in lodging the FIR, the failure to recover the alleged torch used for identification during a night-time occurrence, and significant discrepancies between the ocular account and medical evidence. Furthermore, the Court emphasized that since the prosecution failed to prove the motive it had set up, it must suffer the consequences. The Court also reiterated the principle that if eyewitnesses are disbelieved regarding accused persons attributed effective roles, they cannot be relied upon against others without independent corroboration. Consequently, the Court set aside the conviction and acquitted the appellant by extending the benefit of doubt.

  Questions settled

  • Can eyewitnesses be believed against an accused if they have been disbelieved regarding other co-accused persons attributed similar roles?
  • What is the legal consequence when the prosecution sets up a motive but fails to prove it?
  • Is an injured witness's testimony automatically reliable without corroboration when there is a conflict with medical evidence?
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• Kher Din (deceased) through LRs, etc vs Mst. Hayat Bibi, etc2025 PLJ Lahore 55 · Lahore High Court · 2024-03-08Read full judgment →
• Khazana Sugar Mills (Pvt) Limited through General Manager and others vs Federation of Pakistan through Secretary, Ministry of Water & Power, Islamabad and others2025 PLJ Peshawar 119 · Peshawar High CourtRead full judgment →
• Khan Mir Khan (decd) through L.Rs. and others vs Ibrar Latif Khan and others2025 SCMR 412 · Supreme Court of Pakistan · 2024-12-17
  pre-emptioncontiguityspecific Khasra numberrevenue recordleave to appealmutation
  Summary & questions settled

  This petition for leave to appeal arose from a judgment of the Lahore High Court, which set aside concurrent judgments and decrees of the lower courts that had decreed a suit for pre-emption filed by the petitioner. The core legal question concerned whether the pre-emptor established the requisite contiguity with the suit property based on the revenue record, where a specific Khasra number out of a Khata was sold by a sole owner. The Supreme Court held that when a full owner of a Khata sells a specific Khasra number, the vendee becomes the full owner of that specific property and a new Khata is created, meaning contiguity must be determined with reference to the specific Khasra number sold rather than the entire Khata. The Court laid down the principle that a pre-emptor must accept the sale as made and that the sale of a specific Khasra number by a sole owner carves out that specific parcel, rendering general Khata contiguity arguments inapplicable unless established against the specific sold unit.

  Questions settled

  • Whether a pre-emptor can claim contiguity to an entire Khata when a specific Khasra number has been sold by a sole owner?
  • What is the legal effect on the revenue estate when a full owner of a Khata sells a specific Khasra number?
  • Does a pre-emptor disputing a sale need to accept the sale as transacted to succeed in a pre-emption suit?
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• Khan Bahadur Lund vs Federation of Pakistan through Chairman, NADRA, Islamabad & others2025 SHC SUK 304 · Sindh High CourtRead full judgment →
• Khamiso S/o Raju and others vs Mansigno S/o Petho Mal through his L.Rs2025 SHC 328 · Sindh High Court · 2025-03-06Read full judgment →
• Khalil Khan s/o Habibullah and others vs The State2025 SHC 186, 2025 MLD 975 · Sindh High Court · 2025-01-31Read full judgment →
• Khalil Ahmed Thaheem vs Province of Sindh & others2025 SHC SUK 406 · Sindh High Court · 2025-03-17Read full judgment →
• Khalifo Haji Muhammad Hanif since deceased through his legal2025 SHC KHI 2013 · Sindh High CourtRead full judgment →
• Khalid vs The State, etc2025 IHC 80 · Islamabad High Court · 2025-02-17
  pre-arrest bailbail cancellationcriminal procedureprohibitory clauseliberty of the accusedinvestigationFIR nomination
  Summary & questions settled

  This criminal miscellaneous petition sought the cancellation of pre-arrest bail granted to respondents by the Additional Sessions Judge in a case registered under Sections 324, 109, and 34 of the Pakistan Penal Code 1860. The core legal question was whether the trial court’s order granting bail was legally unsustainable, warranting interference by the High Court. The High Court dismissed the petition, holding that the impugned order was consistent with law and facts. The court affirmed that once bail is granted by a competent court, it cannot be cancelled without establishing strong and exceptional grounds, such as the misuse of liberty, tampering with evidence, or the likelihood of absconsion. The court emphasized that mere nomination in an FIR is insufficient to deny bail, particularly when the investigation is complete and no fresh incriminating material exists. Reaffirming that bail is the rule and refusal is the exception, the court held that interference with a bail order is only justified if the order is patently illegal, erroneous, or results in a miscarriage of justice.

  Questions settled

  • What are the established grounds for the cancellation of bail once it has been granted by a competent court?
  • Does mere nomination in an FIR constitute sufficient grounds to deny or cancel pre-arrest bail?
  • Is interference by a superior court in a bail-granting order justified if the order is not patently illegal or erroneous?
  • Does the completion of investigation and submission of a challan influence the court's decision regarding the cancellation of bail?
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