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.

• Saira Fatima vs State etcPLJ 2024 Cr.C. 403, 2024 PCRLJ 1289 · Lahore High Court · 2023-05-30
  joinder of chargesseparate trialdishonoured chequediscretionary powercriminal procedurefair trialinherent powers
  Summary & questions settled

  This petition under Section 561-A, Code of Criminal Procedure 1898 challenged the dismissal of the petitioner's application for the joinder of charges under Section 234, Code of Criminal Procedure 1898 in multiple cases involving dishonoured cheques. The core legal question was whether the provision for joinder of charges is mandatory or discretionary, and whether an accused can demand such joinder as a matter of right. The Court held that Section 234, Code of Criminal Procedure 1898 is permissive and discretionary, not mandatory. It serves as an exception to the general rule of separate trials for distinct offences under Section 233, Code of Criminal Procedure 1898. The Court affirmed that an accused cannot insist on the joinder of charges unless they can demonstrate that separate trials would cause prejudice or amount to an illegality. Finding that the lower courts correctly exercised their discretion and that no prejudice was shown, the Court dismissed the petition, noting that inherent powers under Section 561-A, Code of Criminal Procedure 1898 are not to be used to substitute appellate or revisional jurisdiction.

  Questions settled

  • Is the joinder of charges under Section 234 of the Code of Criminal Procedure 1898 mandatory or discretionary?
  • Can an accused demand the joinder of charges as a matter of right?
  • Does the failure to join charges for offences of the same kind committed within one year automatically render separate trials illegal?
  • Under what circumstances can the High Court exercise its inherent powers under Section 561-A of the Code of Criminal Procedure 1898 to order the joinder of charges?
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• Saima Batool vs Additional District Judge, etc.2024 LHC 2443 · Lahore High Court · 2024-04-30Read full judgment →
• Saifal son of Ishaque, Mashooq son of Saifal & Ayub Son of Yaqoob vs The State2024 SHC 966 · Sindh High Court · 2024-09-20
  pre-arrest bailamicable settlementSulhnon-compoundable offenceprohibitory clausefurther inquiry
  Summary & questions settled

  This matter concerns a pre-arrest bail application filed by three applicants, Saifal, Mashooq, and Ayub, who were charged in Crime No. 363/2024 registered at Police Station Sukhan under sections 380, 457, and 34 of the Pakistan Penal Code 1860. The applicants sought confirmation of their interim pre-arrest bail after the Sessions Court declined their request. The core legal question was whether pre-arrest bail could be confirmed despite the non-compoundable nature of the offences, given that the parties had reached an amicable settlement outside of court. The Court held that the settlement between the parties, grounded in the principle of 'Sulh', justified the grant of bail, noting that non-compoundability does not strictly preclude bail when parties have reconciled. Furthermore, the Court observed that the alleged offences did not fall within the prohibitory clause of section 497 of the Code of Criminal Procedure 1898, and the case required further inquiry. Consequently, the Court confirmed the interim pre-arrest bail, emphasizing the importance of amicable settlements and the statutory provisions regarding further inquiry in criminal proceedings.

  Questions settled

  • Does the non-compoundable nature of an offence prevent the grant of bail when the parties have reached an amicable settlement?
  • Can pre-arrest bail be granted for offences that do not fall within the prohibitory clause of section 497 of the Code of Criminal Procedure 1898?
  • Is a case considered to require further inquiry under section 497(2) of the Code of Criminal Procedure 1898 when the parties have reconciled?
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• Saif Power Limited vs Sui Northern Gas Pipelines Limited etc2024 LHC 2172 · Lahore High Court · 2024-04-22Read full judgment →
• Said Gul vs The State & another2024 PHC 408 · Peshawar High Court · 2024-08-30Read full judgment →
• Said Bahadar vs Amin-Ur-Rehman and another2024 PCRLJ 138 · Peshawar High Court · 2021-06-03
  acid throwingmurderdelayed FIRbenefit of doubteyewitness credibilitymedical evidencecriminal appealacquittal
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of the appellant under section 302(b) of the Pakistan Penal Code 1860 for allegedly throwing acid on the deceased, resulting in severe burns and subsequent death. The core legal questions involved the reliability of delayed FIR registration, the credibility of an alleged eyewitness whose name was omitted, the sufficiency of medical and recovery evidence, and the benefit of doubt arising from glaring contradictions in the prosecution's case. The Peshawar High Court held that unexplained delayed registration of the FIR, doubtful ocular evidence, planted recoveries, and material contradictions rendered the prosecution's case highly doubtful. Consequently, the court set aside the conviction, acquitted the appellant of the charge, and dismissed the connected revision petition as infructuous. The key principle laid down is that where the prosecution fails to establish guilt through confidence-inspiring, direct, or corroborative evidence, and leaves unexplained delays and contradictions, the benefit of the doubt must be extended to the accused, leading to acquittal.

  Questions settled

  • Whether an unexplained and prolonged delay in the registration of an FIR creates a serious dent in the prosecution case?
  • Is the testimony of a belatedly introduced eyewitness reliable without corroboration in an unwitnessed crime?
  • Can medical evidence alone sustain a conviction for murder in the absence of trustworthy direct or circumstantial evidence connecting the accused to the crime?
  • Whether recoveries of incriminating articles made in a suspicious manner can serve as valid corroborative evidence against an accused?
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• Sahibzadi Saira Mehreen Abbasi, etc. vs Federation of Pakistan, etc2024 LHC 1403, 2024 PLJ Lahore 632 · Lahore High Court · 2024-03-30Read full judgment →
• Sahibzada Saeed and others vs Govt. of Khyber Pakhtunkhwa Through Chief Secretary and others2024 PHC 334 · Peshawar High Court
  Medical Teaching InstitutionsBoard of Governorsdoctrine of pleasurecaretaker government mandateremoval without show causeconstitutional petitionjurisdiction of High Court
  Summary & questions settled

  This consolidated judgment by the Peshawar High Court addresses multiple constitutional petitions filed by members and chairpersons of the Board of Governors (BoGs) of various Medical Teaching Institutions (MTIs) challenging their removal or appointment across three distinct categories: those appointed by an elected government and removed by a caretaker setup (Category A), those appointed by a caretaker setup and removed by an elected government (Category B), and those appointed and removed by an elected government (Category C). The core legal questions concern the jurisdiction of the High Court versus the MTI Appellate Tribunal, the scope of the Chief Minister's pleasure under section 5(3) of the Medical Teaching Institutions Reforms Act 2015, and the mandate of a caretaker government to make appointments or terminations under the Elections Act 2017. The court held that simpliciter removal of BoG members without accusations of misconduct does not bar the jurisdiction of the High Court under section 5(7) of the 2015 Act, that the 'doctrine of pleasure' does not confer arbitrary removal powers without due process, and that caretaker governments lack the mandate to make major policy decisions or long-term appointments. Consequently, the court disposed of Category A and C petitions with remands for fresh consideration, and dismissed Category B petitions.

  Questions settled

  • Whether an appeal lies before the MTI Appellate Tribunal against the simpliciter removal of a member of the Board of Governors without any accusation or blame of misconduct?
  • Does the doctrine of pleasure under section 5(3) of the Medical Teaching Institutions Reforms Act 2015 empower the Chief Minister to remove a member of the Board of Governors without a show cause notice and an opportunity of hearing?
  • What is the scope of authority of a caretaker government regarding making appointments and terminations in public offices under the Elections Act 2017?
  • Whether the High Court can exercise judicial review over the removal of members of the Board of Governors of Medical Teaching Institutions?
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• Sahib Zada Sana Ullah vs Returning Officer and others2024 PHC 14 · Peshawar High Court · 2024-01-10Read full judgment →
• Sahib Dino Janwari vs Province of Sindh & others2024 SHC 638 · Sindh High Court · 2024-05-29Read full judgment →
• Sahar Gul s/o Soor Gul, r/o Sadda Lower Kurram vs The State etc2024 PHC 216, PLJ 2024 Cr.C. 1036, 2025 YLR 5 · Peshawar High Court · 2024-06-11Read full judgment →
• Sagheer Ahmed vs The State and another2024 SCP 116, 2024 SCMR 913, PLJ 2024 SC (Cr.C.) 164 · Supreme Court of Pakistan · 2024-03-13
  post-arrest bailnarcoticsforensic analysis delaysafe custodyfurther inquirystatutory barcriminal procedure
  Summary & questions settled

  This petition for leave to appeal challenged the Lahore High Court's order dismissing the petitioner's post-arrest bail application in a narcotics case involving the recovery of 1420 grams of charas. The core legal question was whether the prosecution's failure to adhere to the mandatory timeline for sending seized narcotics to the Forensic Science Laboratory constituted sufficient grounds to grant bail. The Supreme Court observed that the samples were sent to the laboratory over a month after the seizure, violating Rule 4(2) of the Control of Narcotic Substances (Government Analysts) Rules, 2001, which mandates dispatch within seventy-two hours. The Court held that this unexplained delay, combined with the lack of evidence regarding the safe custody of the narcotics, created a case of further inquiry. Furthermore, noting that the maximum sentence did not trigger the statutory bar under the Control of Narcotic Substances Act, 1997, the Court granted bail. The key principle laid down is that an unreasonable delay in sending narcotic samples for forensic analysis, coupled with a failure to establish safe custody, entitles an accused to the concession of bail.

  Questions settled

  • Does an unexplained delay in sending narcotic samples to a forensic laboratory constitute grounds for further inquiry in bail proceedings?
  • Does the statutory bar under Section 51 of the Control of Narcotic Substances Act 1997 apply to offenses carrying a maximum sentence of fourteen years?
  • Is the prosecution required to establish the safe custody of recovered narcotics during the period between seizure and forensic analysis?
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• Sagheer Ahmad vs Sessions Judge, Kasur & others2024 LHC 5364 · Lahore High Court · 2024-11-22Read full judgment →
• Safdar Ali Jalbani vs ZTBL through Authorized Person2024 CLD 845, 2024 PLJ Karachi 109 · Sindh High Court · 2024-03-26Read full judgment →
• Safar Gul vs The State2024 PCRLJ 891 · Balochistan High Court · 2023-11-20
  Qatl-i-Amdocular evidenceinterested witnessesabscondencecriminal appealmedical evidencecorroboration
  Summary & questions settled

  This criminal appeal challenges the conviction of the appellant for Qatl-i-Amd under Section 302(b) of the Pakistan Penal Code 1860, following a trial court judgment. The core legal question was whether the prosecution successfully established the appellant's guilt beyond reasonable doubt, given the reliance on ocular testimony from related witnesses and the absence of the recovered crime weapon. The Court held that the conviction was sound, dismissing the appeal. It affirmed that the testimony of related witnesses is not inherently unreliable if it remains consistent, confidence-inspiring, and is supported by independent circumstances. Furthermore, the Court established that abscondence by an accused constitutes a strong piece of corroborative evidence when considered alongside direct ocular and medical accounts. Additionally, the Court clarified that the non-recovery of a weapon of offense does not vitiate the prosecution’s case where other substantive evidence independently proves the charge. The judgment reinforces that minor discrepancies in witness statements, which are natural over time, do not undermine the prosecution's case when the overall evidence is consistent and reliable.

  Questions settled

  • Does the relationship of prosecution witnesses to the deceased automatically render their testimony unreliable?
  • Can an accused be convicted based on ocular evidence despite the non-recovery of the crime weapon?
  • Is abscondence of an accused considered a valid piece of corroborative evidence in a murder trial?
  • Do minor discrepancies in the statements of eye-witnesses necessitate the rejection of the entire prosecution case?
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• Saeed-uz -Zaman and another vs Adil Shah and 03 others2024 PHC 256 · Peshawar High Court · 2024-06-03Read full judgment →
• Saeed- Ullah vs The Returning Officer of PK-56 Mardan & 2 others2024 PHC 54 · Peshawar High Court · 2024-01-07Read full judgment →
• Saeed Ullah vs The Returning Officer of PK-56 District Mardan and others2024 PHC 12 · Peshawar High Court · 2024-01-11Read full judgment →
• Saeed Noor Khan and others vs Syed Adnan Ali and others2024 SHC 352 · Sindh High Court · 2024-04-25Read full judgment →
• Saeed and others vs Begum Jan and others2024 PLJ AJ&K 1 · High Court of Azad Jammu and Kashmir · 2023-05-08Read full judgment →
• Saeed Akhtar & another vs Zafarullah Khan & others2024 SHC 970 · Sindh High Court · 2024-09-20Read full judgment →
• Saeed Ahmed, Noor Muhammad vs The State & another2024 SCP 325, 2024 PLD Supreme Court 1241 · Supreme Court of Pakistan · 2024-08-23
  pre-arrest bailplea of alibifurther inquirymalafidecolumn No.2 of challantentative assessment
  Summary & questions settled

  This matter arises from petitions for pre-arrest bail filed by Saeed Ahmed and Noor Muhammad in connection with FIR No.31/22 registered under sections 302, 324, 337-H(ii), 337-F(v), 114, 148 and 149 PPC at Police Station Jarwar, District Ghotki. The core legal question was whether the petitioners were entitled to pre-arrest bail in light of their plea of alibi, police exoneration, and placement in column No.2 of the challan, pointing toward malafide and further inquiry. The Supreme Court held that the petitioners' apprehension of arrest was well-founded, investigation was complete, no recovery was required from them, and their case fell within the scope of further inquiry based on a tentative assessment of the record, including hospital slips, ATM CCTV footage, and call data records. The Court confirmed the pre-arrest bail, reaffirming that bail should not be withheld as a punishment and that pre-arrest bail is justified where mala fide and ulterior motives are established alongside a case of further inquiry.

  Questions settled

  • Whether pre-arrest bail can be granted when an accused is declared innocent during investigation and placed in column No.2 of the challan?
  • Does a plea of alibi supported by hospital records, CCTV footage, and call data records make out a case for further inquiry under criminal law?
  • Can bail be withheld as a punishment when the accused are no longer required for further investigation or recovery?
  • Whether pre-arrest bail is justified where the apprehension of arrest at the instance of the complainant is tainted with malafide and ulterior motives?
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• Saeed Ahmed vs Election Commission of Pakistan & others2024 SHC 1084 · Sindh High Court · 2024-10-17Read full judgment →
• Saeed Ahmed Sidhu vs Election Commission of Pakistan etc2024 PLJ Lahore 398 · Lahore High Court · 2024-01-11Read full judgment →
• Sadoro Mirbahar vs The State2024 PCRLJ 632 · Sindh High Court · 2022-10-12
  murderextortionpolice encounteranti-terrorismocular testimonymedical evidenceforensic ballisticsinterested witness
  Summary & questions settled

  This judgment disposes of criminal appeals filed by the appellant, Sadoro Mirbahar, against his convictions and sentences passed by the Anti-Terrorism Court Larkana in two special cases arising from back-to-back incidents involving murder, attempted murder, extortion, and an attack on a police party. The core legal questions involved the credibility of eyewitness testimonies, the effect of minor contradictions in ocular evidence, the evidentiary value of firearm recoveries supported by forensic reports, and whether relationship of witnesses to the deceased renders them interested witnesses. The Sindh High Court held that the prosecution successfully proved its case beyond a reasonable doubt through consistent ocular accounts, medical evidence, and corroborative forensic science laboratory reports linking the recovered weapon to the crime empties. The court ruled that mere relationship to the deceased does not discredit natural witnesses in the absence of enmity or a motive for false substitution, and minor contradictions are natural over time. The appeals were consequently dismissed, upholding the convictions and sentences.

  Questions settled

  • Whether minor contradictions and inconsistencies in the statements of eyewitnesses are sufficient to discard the prosecution case?
  • Does the mere blood relationship of an eyewitness to the deceased render them an 'interested witness' requiring mandatory corroboration?
  • Can a positive forensic match between crime empties and a weapon recovered from the accused serve as reliable corroborative evidence of guilt?
  • Whether the unexamined status of certain prosecution witnesses warrants an adverse presumption under Article 129(g) of the Qanun-e-Shahadat Order, 1984 in the presence of overwhelming direct evidence?
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• Sadiq Poultry Farms (Private) Limited etc vs First Habib Modaraba2024 LHC 4053, 2025 PLD Lahore 161, 2025 CLD 277 · Lahore High Court · 2024-09-30Read full judgment →
• Sadiq Hussain and another vs Deputy Director, Federal Investigation2024 LHC 6351, 2025 PLJ Lahore 300 · Lahore High CourtRead full judgment →
• Sadia Aziz vs DPO etc2024 LHC 2076, 2024 PLJ Lahore 413 · Lahore High Court · 2024-05-02Read full judgment →
• Saddam vs The State etc.2024 PHC 150 · Peshawar High Court · 2024-04-18Read full judgment →
• Saddam Hussain vs The State2024 YLR 1021 · Balochistan High Court · 2023-03-14
  narcoticschain of custodydelay in FIRchemical examinercriminal appealacquittalbenefit of the doubt
  Summary & questions settled

  This criminal appeal challenges the judgment of the trial court convicting and sentencing the appellant under Section 9(b) of the Control of Narcotic Substances Act, 1997 for the alleged possession of 150 grams of baked charas. The core legal questions involved the reliability of the prosecution's case in light of an unexplained delay in lodging the FIR and transmitting the recovered sample to the chemical examiner, as well as a broken chain of custody. The Balochistan High Court held that the prosecution failed to prove prompt registration of the FIR and the safe custody and transmission of the sample in accordance with the law, leaving the chain of custody doubtful. The court laid down the principle that unexplained delays in FIR registration and sample transmission, coupled with the failure to examine the official who transported the sample, create serious doubt in the prosecution's case, entitling the accused to the benefit of the doubt and resulting in acquittal.

  Questions settled

  • Does an unexplained delay in lodging an FIR affect the veracity of a narcotics case?
  • What is the legal effect of an unexplainable delay in transmitting a narcotics sample to the chemical examiner?
  • Is the failure to examine the constable who transported the sample fatal to the chain of custody?
  • When is an accused entitled to an acquittal in a narcotics possession case?
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• Saddam Hussain vs The State and another2024 PCRLJ 1499 · Peshawar High Court · 2023-11-10
  post-arrest bailhonour killingfurther inquiryexhumation reportnon-compoundable offencecompromise in bail matters
  Summary & questions settled

  This bail application arose from a petition filed by Saddam Hussain, accused of the murder of his sister, Mst. Asma, allegedly on the pretext of honour, in a case registered under sections 302/311/109/34 of the Pakistan Penal Code 1860. The prosecution alleged the deceased was administered poison and later the death was staged as a suicide, with an exhumation report revealing a ligature mark. The core legal question was whether the petitioner was entitled to post-arrest bail given the nature of the evidence and the fact that the legal heirs had no objection to his release. The Court held that the case against the petitioner was one of further inquiry, as the determination of individual culpability among the inmates of the house required a full trial. Furthermore, the Court emphasized that while section 311 of the Pakistan Penal Code 1860 is non-compoundable, the lack of desire by the complainant party to prosecute, combined with the arguable nature of the case, justified the grant of bail. The Court admitted the petitioner to bail, noting that the evidentiary value of the prosecution's case remained a matter for trial.

  Questions settled

  • Can bail be granted in a non-compoundable offence if the complainant party is no longer willing to prosecute?
  • Does the existence of a ligature mark on a deceased's body automatically preclude the grant of bail to an accused in a murder case?
  • Is a case considered one of 'further inquiry' when the prosecution relies on circumstantial evidence and the specific role of the accused remains to be determined at trial?
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• Saddam Hussain and another vs The State2024 PCRLJ 499, PLJ 2024 Cr.C. 632 · Federal Shariat Court · 2023-11-16
  dacoity with murderharaabahsentencing reasoningcriminal appealremandSection 367(5) CrPCSection 396 PPC
  Summary & questions settled

  This matter concerns criminal appeals against a conviction for dacoity with murder. The appellants were convicted by the trial court under Section 396 of the Pakistan Penal Code, 1860, despite the involvement of only three accused persons, whereas the definition of dacoity under Section 391 requires five or more persons. Furthermore, the trial court failed to provide mandatory reasons for declining to impose the death penalty, violating Section 367(5) of the Code of Criminal Procedure, 1898, particularly given the charges under the Offences against Property (Enforcement of Hudood) Ordinance, 1979. The core legal question was whether the trial court erred in its application of the penal provisions and its failure to adhere to procedural sentencing requirements. The Federal Shariat Court held that the conviction was legally flawed due to the misapplication of the dacoity statute and the omission of mandatory sentencing reasoning. Consequently, the court set aside the judgment and remanded the case for a fresh decision, emphasizing that trial courts must strictly comply with statutory sentencing obligations and provide reasoned justifications when departing from capital punishment.

  Questions settled

  • Does the offence of dacoity under the Pakistan Penal Code, 1860 require the involvement of at least five persons?
  • Is a trial court legally obligated to state reasons in its judgment when it chooses not to impose the death penalty for an offence punishable by death?
  • Can a conviction under Section 396 of the Pakistan Penal Code, 1860 be sustained when only three persons are involved in the commission of the crime?
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• Sadaqat Khan Mahar and others vs Province of Sindh & others2024 SHC 590, 2025 PLC (C.S.) 326 · Sindh High Court · 2024-05-22
  deceased quotacivil servantspublic employmentconstitutional protectionlimitation periodSindh High Court
  Summary & questions settled

  This matter involves constitutional petitions filed by legal heirs of deceased civil servants of the Government of Sindh, seeking appointments under the quota reserved for deceased employees in accordance with government policies and judicial precedents. The core legal question concerns whether the two-year limitation period introduced for applying under the deceased civil servants quota applies retrospectively to heirs whose predecessors died before the introduction of the restraining clause. The Sindh High Court held that the two-year limitation period is not applicable to cases where the civil servant died before the introduction of the cap, and directed the competent authority to consider the applications in light of established Supreme Court dicta. The court laid down the principle that beneficial policies for deceased employees' quotas aim to minimize family miseries, protect fundamental rights under the Constitution, and cannot be curtailed by retrospective application of restrictive rules.

  Questions settled

  • Whether the two-year limitation period to apply for employment under the deceased civil servants quota applies retrospectively?
  • Does the denial of appointment under a beneficial deceased quota violate constitutional guarantees under Articles 27, 34, and 35 of the Constitution of Pakistan?
  • Are legal heirs entitled to appointment under the deceased civil servants quota if the government employee died before the introduction of the cap in the relevant rules?
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• Sadaqat Ali and another vs Mst. Nasreen Akhtar2024 SCP 414, 2025 SCMR 358 · Supreme Court of Pakistan · 2024-12-19
  rent evictionex parte proceedingsservice of noticeSection 12(2) CPCconcurrent findingssub-lesseefraud and misrepresentation
  Summary & questions settled

  This civil petition challenges a Sindh High Court order confirming concurrent findings of the Rent Controller and District Court regarding an eviction application. The core legal question was whether the ex parte eviction judgment against the petitioners was obtained through fraud or misrepresentation, as alleged under Section 12(2) of the Code of Civil Procedure, 1908, and whether the service of notice was valid. The Supreme Court held that the Rent Controller had exhausted all legal modes of service, including bailiff, registered post, and publication, rendering the service valid. Consequently, the ex parte proceedings resulted from the petitioners' willful absence rather than any fraud or misrepresentation by the respondent. The Court affirmed the concurrent findings of the lower courts, noting that the petitioners failed to establish any valid grounds for interference. The key principle laid down is that where a party is served through multiple modes of service and fails to appear, the resulting ex parte judgment cannot be set aside on grounds of fraud or misrepresentation, and concurrent findings of fact by lower courts remain undisturbed absent compelling legal error.

  Questions settled

  • Can an ex parte judgment be set aside under Section 12(2) of the Code of Civil Procedure 1908 if the party was served through multiple modes including publication?
  • Does the failure to appear after valid service of notice constitute a valid ground to claim fraud or misrepresentation in eviction proceedings?
  • Is a court required to interfere with concurrent findings of fact by lower courts in a rent eviction case where service of notice was properly effected?
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• Sadaqat & another, Habib Ullah, The State vs The State & another, Sadaqat2024 LHC 6372 · Lahore High CourtRead full judgment →
• Sadaf Ihsan vs Government of Pakistan through Secretary Parliament2024 YLR 2076 · Peshawar High Court · 2024-04-02Read full judgment →
• Sabre Travel Network Pakistan (Pvt.) Ltd vs Pakistan & others2024 SHC 1276 · Sindh High Court · 2024-11-21Read full judgment →
• Sabir Press Calendar vs The Commissioner Inland Revenue, Faisalabad &2024 LHC 5858, PTCL 2025 CL. 64 · Lahore High CourtRead full judgment →
• Sabir Hussain vs Additional District Judge etc.2024 LHC 621, 2025 CLC 785 · Lahore High Court · 2024-01-30Read full judgment →
• Sabir Ali vs Munawar & others2024 LHC 1827, 2024 PLJ Lahore 501, 2025 PLD Lahore 286 · Lahore High Court · 2024-04-24Read full judgment →
• Sabiha Bibi vs Abdul Wahab, etc2024 LHC 5093 · Lahore High Court · 2024-11-11Read full judgment →
• Sabhago vs S.S.P Sanghar and others2024 SHC 1126 · Sindh High Court · 2024-09-26
  quashing of orderfree-will marriageconversion to Islamjustice of peaceregistration of FIRpolice protectionminority age under Muslim lawharassment
  Summary & questions settled

  The applicant invoked section 561-A of the Code of Criminal Procedure 1898 to challenge an order of the Ex-Officio Justice of Peace, which dismissed his request for the registration of a police case against private respondents regarding the alleged abduction of his daughter, Birjo. The record revealed that the daughter, now known as Aisha, had converted to Islam, contracted a free-will marriage with Naseer Ahmed, and previously obtained a protection order from the Sessions Court. The core legal question concerned whether the Justice of Peace erred in refusing to direct the registration of an FIR where an adult woman contracted a free-will marriage and alleged no abduction, and whether such a marriage was valid under Muslim law despite contentions regarding age. The Sindh High Court held that a major individual possesses the freedom to contract a marriage of their choice and that the marriage was valid under Islamic law. The court dismissed the criminal miscellaneous application, ruling that no cognizable offense was made out and directing police protection for the married couple while barring harassment by the applicant's family.

  Questions settled

  • Whether an Ex-Officio Justice of Peace is justified in refusing to direct the registration of an FIR when the alleged victim appears voluntarily and confirms a free-will marriage?
  • Does a major individual have the fundamental right to contract a marriage of their own choice without interference or harassment from family members?
  • Whether a marriage contracted by a minor nearing puberty is valid under Muslim Law and protected against criminal allegations of abduction?
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• Saba Gul & 02 others vs Additional District Judge, Faisalabad & 02 others2024 LHC 4177 · Lahore High Court · 2024-10-09Read full judgment →
• Saba Farhat Rashid vs Farhat Rashid2024 SHC 538 · Sindh High Court · 2024-05-24Read full judgment →
• Saasa Corporation (Pvt) Limited vs M/s Sefam Pvt Limited2024 LHC 4319 · Lahore High Court · 2024-09-30Read full judgment →
• Saalim Kalo vs The State2024 MLD 1010 · Sindh High Court · 2023-11-30
  vicarious liabilitycommon intentionmurderfree fightcriminal appealsentence reductionhurtPakistan Penal Code
  Summary & questions settled

  This criminal appeal challenges the judgment of the trial court whereby the appellant was convicted and sentenced under Sections 302(b)/34, 324, 337-A(i), and 337-A(ii) of the Pakistan Penal Code 1860. The core legal question was whether the appellant, who performed a minor role of inflicting lathi blows, could be held vicariously liable for the murder committed independently by his co-accused during a sudden incident on the land of the accused party. The Sindh High Court held that in the absence of evidence establishing a common intention or material facilitation for the murder, a co-accused cannot be held vicariously liable merely for being part of the attacking party. The court set aside the conviction under Section 302/34, maintained the convictions for minor injuries, and converted the sentences to the period already undergone by the appellant, establishing the principle that vicarious liability requires clear proof of shared intent and active participation in the primary offense.

  Questions settled

  • Can an accused performing a minor role be held vicariously liable for murder committed by a co-accused without proof of a common intention?
  • Whether an appellant can be released on the basis of a sentence already undergone when convictions for major offenses are set aside?
  • Does the absence of pre-planning and the occurrence of an incident on the accused party's land negate common intention?
  • Is a co-accused responsible for independent acts of violence committed by another participant in a sudden fight?
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• Saadullah vs Provincial Police Officer Khyber Pakhtunkhwa, Peshawar and 3 others2024 PLJ Tr.C. (Services) 65 · Khyber Pakhtunkhwa Service Tribunal
  service appeallimitation periodvoid orderdepartmental inquirycondonation of delaypolice service
  Summary & questions settled

  This service appeal concerns a police constable who challenged departmental orders from 2011 and 2013, which imposed a minor punishment of withholding an increment. The appellant sought to challenge these orders in 2020, arguing that the initial disciplinary action was void because it was passed under the repealed Removal from Service Ordinance, 2000, and therefore, the law of limitation did not apply. The core legal question was whether a stale claim could be entertained on the ground that the impugned order was void. The Khyber Pakhtunkhwa Service Tribunal held that the appeal was time-barred and dismissed it. The Tribunal ruled that the principle that 'no limitation runs against a void order' is not an inflexible rule. It emphasized that a litigant cannot remain indolent for years and then seek to challenge an order by labeling it void. The Tribunal affirmed that the law of limitation is a substantive legal requirement, and a party must approach the appropriate forum with due diligence within the prescribed period, as failure to do so creates valuable rights for the opposing party.

  Questions settled

  • Does the principle that 'no limitation runs against a void order' provide an absolute exemption from the law of limitation?
  • Can a litigant seek condonation of delay for a stale claim by merely labeling the impugned order as void?
  • Is the law of limitation a mere technicality or a substantive legal requirement that creates rights for the opposing party?
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• Saadia Khalil vs Learned Addl. District Judge, Lahore and 2 Others2024 LHC 3901, 2024 PLJ Lahore 828, 2025 CLC 478 · Lahore High Court · 2024-08-15Read full judgment →
• Saadat Ali Dahri vs Shah Nawaz & others2024 SHC 22 · Sindh High Court · 2024-01-17Read full judgment →
• Saadabad Coop Housing Society vs Province of Sindh & Others2024 SHC 314 · Sindh High Court · 2024-04-16Read full judgment →
• Saad Ullah Khan vs The State etc.2024 PHC 152 · Peshawar High Court · 2024-04-05Read full judgment →
• Saad Muhammad Abbasi vs Syed Ejaz Ali, etc2024 IHC 142, 2024 CLD 1099, 2024 MLD 1501, 2024 PLJ Islamabad 315 · Islamabad High Court · 2024-05-31Read full judgment →
• Saad Aqil vs Province of Sindh & Others2024 SHC 130 · Sindh High Court · 2024-02-15Read full judgment →
• S.M. Food Makers Limited vs Federation of Pakistan etc2024 CLD 1230 · Competition Commission of Pakistan · 2024-08-26Read full judgment →
• Rustam, Ali Asghar vs The State2024 SHC 1358 · Sindh High Court · 2024-11-19
  Jail Criminal AppealMurder convictionDeath sentenceBenefit of doubtFIR delayContradictory evidenceMotiveAcquittal
  Summary & questions settled

  This Jail Criminal Appeal challenged a judgment convicting the appellant for qatl-e-Amd under Section 302(b) PPC and sentencing him to death. The core legal question was whether the prosecution had proven the appellant's guilt beyond a reasonable doubt, considering significant delays in FIR registration, material contradictions in eyewitness accounts, lack of supporting medical records for initial treatment, and the prosecution's failure to establish a motive. The Sindh High Court allowed the appeal, set aside the conviction and sentence, and acquitted the appellant by extending the benefit of the doubt. The court held that a single circumstance creating reasonable doubt in a prudent mind is sufficient for acquittal, which is a matter of right, not grace or concession. Consequently, the death sentence reference was answered in the negative.

  Questions settled

  • Can a conviction for murder be sustained despite a significant delay in the registration of the First Information Report?
  • What is the impact of material contradictions in the statements of prosecution witnesses on the outcome of a criminal trial?
  • Is the benefit of doubt a matter of grace or a matter of right for an accused person?
  • Can a single circumstance creating reasonable doubt lead to the acquittal of an accused?
  • What is the significance of an unproven motive in a murder trial?
  Read full judgment →
• Rustam son of Gul Nawaz and others vs The State etc2024 PHC 332 · Peshawar High Court · 2024-10-08Read full judgment →
• Rukhsar Ahmad vs The State and others2024 LHC 4549, 2025 PCRLJ 700 · Lahore High Court · 2024-09-16
  post-arrest bailDrugs Act 1976Drug Regulatory Authority of Pakistan Act 2012procedural safeguardsshow cause noticeFIR quashmentconstitutional jurisdictionDistrict Quality Control Board
  Summary & questions settled

  The Petitioner sought post-arrest bail regarding an FIR registered for alleged violations of the Drugs Act, 1976 and the Drug Regulatory Authority of Pakistan Act, 2012. The core legal question was whether the registration of the FIR was lawful despite the failure of the authorities to refer the matter to the District Quality Control Board and issue a mandatory show-cause notice as required by the Punjab Drugs Rules 2007. The Court held that the procedural requirements under Rule 5(3) of the Punjab Drugs Rules 2007 are mandatory, as they serve to protect individual rights and ensure due process. Consequently, the Court found the initiation of proceedings without these safeguards to be coram non judice and without lawful authority. The key principle laid down is that procedural safeguards in statutes, particularly those affecting individual rights, must be strictly followed; failure to do so invalidates the action. The Court quashed the FIR and directed the matter be remitted for de novo proceedings, emphasizing the High Court's constitutional authority to rectify such illegalities.

  Questions settled

  • Is the requirement to issue a show cause notice under Rule 5(3) of the Punjab Drugs Rules 2007 mandatory before initiating prosecution?
  • Does a High Court have the constitutional authority to quash an FIR registered without following the mandatory procedural requirements of the Drugs Act, 1976?
  • Can the heading of a statutory section control or override its substantive provisions?
  • Is the registration of an FIR for drug-related offenses valid if the case was not referred to the District Quality Control Board as required by law?
  Read full judgment →
• Rukhsana vs Muhammad Khan and 2 others2024 MLD 1349 · Balochistan High Court · 2022-08-17Read full judgment →
• Rozina Ahmed vs Province of Punjab, etc.2024 LHC 1233, 2024 PLJ Lahore 565 · Lahore High Court · 2024-03-13
  constitutional petitionservice lawappointment withdrawalprovisional result cardcut-off datedoctrine of locus poenitentiaevested rights
  Summary & questions settled

  This constitutional petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973 challenged the orders of the respondent authorities withdrawing the appointment of the petitioner as an Educator (ESE Sci-Math) on the ground that her Master of Computer Science (MCS) degree result card was incompatible with the cut-off date of the recruitment advertisement. The core legal question was whether a candidate who obtained a provisional result card prior to the cut-off date and subsequently secured a final transcript can be disqualified and removed from service after fulfilling all selection criteria and joining duty. The Lahore High Court held that the provisional result card conclusively established that the petitioner passed her examination before the cut-off date, and the subsequent issuance of the final transcript with minor score variations was a routine academic process by the university rather than a disqualifying defect. The court ruled that once an appointment has been made after fulfilling codal formalities and the employee has assumed duties, vested rights are created which cannot be arbitrarily withdrawn, invoking the well-established doctrine of locus poenitentiae.

  Questions settled

  • Whether an appointment to a public post can be withdrawn on the ground that the provisional result card submitted before the cut-off date differs slightly from the final transcript subsequently issued?
  • Does the doctrine of locus poenitentiae bar the executive authorities from cancelling an appointment letter issued after the completion of all codal formalities?
  • Whether a candidate who passes an examination prior to the cut-off date of an advertisement can be disqualified merely because the final academic transcript was issued after the cut-off date?
  Read full judgment →
• Roshan Ali Mahar s/o Hakim vs Ghulam Ali Dahar and Four (4) Others2024 SHC 280 · Sindh High Court · 2024-04-01Read full judgment →
• Roque Martin D'Mello & others vs Federation of Pakistan & others2024 SHC 882, 2025 MLD 49 · Sindh High Court · 2024-08-23Read full judgment →
• Rohan Ahmad vs The State, etc2024 SCP 22, 2024 PLD Supreme Court 492 · Supreme Court of Pakistan · 2024-01-15
  statutory bailpost-arrest bailfair trialdue processcriminal procedureblasphemy lawstrial delay
  Summary & questions settled

  This matter concerns a petition for leave to appeal against the High Court's refusal to grant post-arrest bail to an accused charged under the Prevention of Electronic Crimes Act, 2016 and the Pakistan Penal Code, 1860. The core legal question was whether the petitioner was entitled to statutory bail under the third proviso to Section 497 of the Code of Criminal Procedure, 1898, given that his detention exceeded two years and the trial had been suspended due to pending proceedings in the High Court. The Supreme Court held that the petitioner was entitled to bail, setting aside the High Court's order. The Court established that the statutory right to bail under Section 497, CrPC is grounded in the constitutional guarantees of fair trial and due process under Articles 4, 9, and 10A of the Constitution of Pakistan, 1973. It further held that for bail to be denied, the prosecution must prove that trial delays were caused by the accused's deliberate, concerted efforts to obstruct proceedings, rather than by court-related delays or administrative inaction.

  Questions settled

  • Does the statutory right to bail under the third proviso to Section 497 of the Code of Criminal Procedure, 1898, stem from constitutional guarantees?
  • Can an accused be denied statutory bail if the delay in trial is caused by the court's own administrative actions or suspension of proceedings?
  • What standard of proof must the prosecution meet to demonstrate that an accused is responsible for trial delays sufficient to deny statutory bail?
  • Does the mere filing of adjournment requests by an accused automatically justify the denial of statutory bail?
  Read full judgment →
• Robkar-e-Adalat vs Deputy Commissioner, Mirpur & others2024 SC AJK 24 · Supreme Court of Azad Jammu and Kashmir · 2024-04-18Read full judgment →
• Robina Kausar vs Muhammad Latif2024 LHC 5640, 2025 CLC 911 · Lahore High Court · 2024-12-03Read full judgment →
• Rizwan Sami Khan vs The State etc2024 LHC 5634, 2025 YLR 811, PLJ 2025 Cr.C. 360 · Lahore High Court · 2024-11-20
  rape convictionbenefit of doubtcriminal appealpotency testevidentiary gapschain of custodysexual offences
  Summary & questions settled

  This criminal appeal challenges the conviction of the appellant, Rizwan Sami Khan, for offences under Sections 376, 292, 500, and 509 of the Pakistan Penal Code 1860, following an alleged incident of rape and the recording of illicit material. The core legal question was whether the prosecution successfully proved the charges beyond a reasonable doubt given the evidentiary gaps. The Lahore High Court held that the prosecution failed to establish its case, citing the non-recovery of the weapon, the withholding of natural witnesses, the failure to produce the alleged incriminating memory card and photographs in court, and the absence of a chain of custody for the evidence. Furthermore, the court emphasized the critical failure to conduct a medico-legal examination of the victim and a potency test of the accused, which are essential in sexual offence cases. Consequently, the court set aside the conviction and acquitted the appellant, granting him the benefit of doubt. The judgment reaffirms that in criminal trials, the burden of proof rests entirely on the prosecution, and failure to present essential forensic and medical evidence creates fatal doubts.

  Questions settled

  • Is the potency test of an accused mandatory in cases involving sexual offences under the Pakistan Penal Code 1860?
  • Does the failure to produce material evidence in court, such as memory cards or photographs, entitle an accused to an acquittal?
  • Can a conviction for rape be sustained when the prosecution fails to produce natural witnesses and medico-legal reports?
  • What is the legal consequence of the prosecution's failure to establish the safe custody of case property?
  Read full judgment →
• Rizwan Rasheed & another vs The State2024 SCP 269, 2024 SCMR 1968 · Supreme Court of Pakistan · 2024-03-21
  abduction for ransomterrorismAnti-Terrorism Actspeedy trialThird Schedulemens reacompoundable offencecompromise
  Summary & questions settled

  This criminal appeal concerns the conviction of petitioners for abduction for ransom and murder. The core legal question was whether the offence of abduction for ransom, when committed without a specific design, purpose, or intent of terrorism, falls under the Anti-Terrorism Act, 1997 (ATA) or the Pakistan Penal Code (PPC), and whether the conviction under the ATA was sustainable in the absence of such intent. The Supreme Court held that the inclusion of an offence in the Third Schedule of the ATA 1997 merely mandates trial by an Anti-Terrorism Court for the purpose of a speedy trial but does not automatically classify the act as terrorism. Unless the ingredients of Section 6 of the ATA 1997—specifically the design, purpose, or intent of terrorism—are satisfied, the offence remains triable under the PPC. Consequently, the Court set aside the convictions under the ATA, accepted a compromise regarding the murder charge under Section 302 PPC, and maintained the conviction under Section 365-A PPC, establishing that heinousness alone does not equate to terrorism.

  Questions settled

  • Does the inclusion of an offence in the Third Schedule of the Anti-Terrorism Act, 1997 automatically classify the act as terrorism?
  • Can an accused be convicted under the Anti-Terrorism Act, 1997 for abduction for ransom if there is no evidence of a design, purpose, or intent of terrorism?
  • Is the offence of kidnapping or abduction for ransom triable by an Anti-Terrorism Court even if it does not constitute an act of terrorism?
  • Does a compromise between the legal heirs and the accused in a murder case under Section 302 PPC result in acquittal?
  Read full judgment →
• Rizwan Ali vs Chairman Board of Director, FESCO and 4 others2024 PLC (C.S.) 695 · Lahore High Court · 2023-12-21
  constitutional petitionmaintainabilitymaster and servantservice disputesenioritystatutory rulesprivate limited company
  Summary & questions settled

  The petitioner challenged an order dated 16.06.2014 passed by the Board of Directors of the Faisalabad Electric Supply Company (FESCO) regarding seniority fixation, alongside a subsequent 2023 agenda item. The core legal question was whether a constitutional petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973 is maintainable against a private limited company like FESCO regarding service disputes, specifically when the company's employment rules are non-statutory. The Court held that the petition was not maintainable. Relying on established Supreme Court precedents, the Court determined that FESCO, as a private limited company with its own Board of Directors, operates under the principle of 'master and servant' rather than being governed by statutory rules. Consequently, internal service disputes cannot be enforced through constitutional jurisdiction. Furthermore, the Court rejected the argument that the State-Owned Enterprises (Governance and Operations) Act, 2023 applied retrospectively to the 2014 decision. The key principle laid down is that where the conditions of service of employees of a corporate body are not regulated by statutory rules, the relationship is governed by the master-servant doctrine, rendering constitutional petitions for service disputes non-maintainable.

  Questions settled

  • Is a constitutional petition under Article 199 of the Constitution of Islamic Republic of Pakistan, 1973 maintainable against a private limited company regarding service disputes?
  • Does the principle of 'master and servant' apply to employees of a corporate body whose service conditions are not regulated by statutory rules?
  • Can the State-Owned Enterprises (Governance and Operations) Act, 2023 be applied retrospectively to decisions made prior to its enactment?
  Read full judgment →
• Rizwan Ahmed vs Federation of Pakistan and others2024 CLC 1703 · Lahore High Court · 2024-06-20Read full judgment →
• Riffat Humayun vs Pakistan Television Corporation Ltd & Others2024 SHC 354, 2024 PLC (C.S.) 1415 · Sindh High Court · 2024-04-24
  res judicatalocus poenitentiaesuperannuationstatus quo orderrecovery of salarycivil servicecause of action
  Summary & questions settled

  This High Court Appeal arises from a civil suit challenging the recovery of salary received by the Appellant during a period of continued service at the Pakistan Television Corporation Ltd (PTV) following her retirement. The Appellant had previously obtained status quo orders to remain in service, which were later vacated upon the dismissal of her constitutional petition. The core legal question concerns whether an employee who persists in service beyond retirement age under the protection of interim court orders is entitled to retain remuneration received during that period, and whether the employer is barred from recovery. The Court dismissed the appeal, affirming that the suit was barred by the principle of res judicata. The Court held that the principle of locus poenitentiae is inapplicable where no lawful order from a competent authority exists, and payments were made solely under the compulsion of interim orders. Consequently, an employee cannot profit from their own self-initiated litigation or use court orders to shield themselves from the consequences of unauthorized service extensions, rendering the recovery of such payments legally justified.

  Questions settled

  • Can an employee retain salary received during a period of service continued solely under the protection of an interim status quo order after the underlying petition is dismissed?
  • Does the principle of locus poenitentiae protect an employee from the recovery of salary payments made in the absence of a lawful order from a competent authority?
  • Is a suit barred by res judicata if it attempts to re-litigate issues regarding the recovery of payments already addressed in a previous constitutional petition?
  Read full judgment →
• Rifat Saeed and Another vs Zahid Saeed and Eleven (11) Others2024 SHC 76 · Sindh High Court · 2024-02-01Read full judgment →
• Rida Qazi etc vs Government of Punjab etc2024 LHC 6036 · Lahore High Court · 2024-12-18Read full judgment →
• Riazuddin Qureshi Thr. Syed Muhammad Farhaj Uddin vs International2024 SHC 658 · Sindh High Court · 2024-03-27Read full judgment →
• Riaz Khan S/O Mushad Gul vs The State2024 SHC 776 · Sindh High Court · 2024-07-15
  post-arrest bailnarcotics possessionprocedural lapsemodern investigative techniquesstatutory barsearch and seizurecriminal procedure
  Summary & questions settled

  This post-arrest bail application concerns an accused charged with the possession of 2110 grams of Charas. The core legal question is whether the applicant is entitled to bail despite the recovery of narcotics, particularly in light of the prosecution's failure to adhere to Supreme Court directives regarding the documentation of arrests and searches. The High Court granted bail, holding that the police's failure to record or photograph the search and arrest using modern devices, as mandated by the Supreme Court in Zahid Sarfaraz Gill v. The State, constitutes a significant procedural lapse. The court established that while the offense of narcotics trafficking is heinous, bail is not an acquittal but a transfer of custody, and courts retain the power to grant bail despite statutory bars in narcotics legislation. The court emphasized that procedural apathy by the prosecution in failing to comply with constitutional commands and Supreme Court directives regarding modern investigative techniques should benefit the accused at the bail stage, without prejudice to the merits of the case.

  Questions settled

  • Does the failure of police to record or photograph a search and arrest using modern devices, as mandated by the Supreme Court, entitle an accused to bail?
  • Do the Sessions Court and High Court retain the power to grant bail in narcotics cases despite the bar contained in Section 51 of the Control of Narcotic Substances Act 1997?
  • Is the grant of bail equivalent to an acquittal of the accused?
  Read full judgment →
• Riaz Khan etc vs Mst. Amina Beghum etc2024 PHC 370, 2025 PLJ Peshawar 81 · Peshawar High CourtRead full judgment →
• Riaz Hussain vs Province of Sindh Through Chief Secretary Sindh2024 PLC (C.S.) 1097 · Sindh High Court · 2021-02-10
  civil servant promotionannual confidential reportslocus standiservice tribunal jurisdictionprovincial selection boardwrit petition
  Summary & questions settled

  The petitioner, serving as a Project Director, challenged the decision of the Provincial Selection Board No. II allowing the promotion of respondent No. 8 to the post of Superintending Engineer (Civil) (BS-19) in the absence of certain Annual Confidential Reports. The core legal question was whether the petitioner had the locus standi to challenge the promotion and whether the High Court had jurisdiction given that the matter pertained to terms and conditions of service. The Sindh High Court held that the petitioner failed to demonstrate any infringement of his fundamental rights, lacked locus standi as an aggrieved person, and that the matter fell within the exclusive jurisdiction of the Service Tribunal under Article 212 of the Constitution read with Section 4 of the Service Tribunals Act. The court dismissed the petition in limine, laying down the principle that service matters relating to promotion and ACRs are barred from writ jurisdiction under Article 212 and that evaluation by selection boards should not be lightly interfered with.

  Questions settled

  • Whether a civil servant has the locus standi to challenge the promotion of a co-employee without showing an infringement of a fundamental right?
  • Does the High Court have jurisdiction under Article 212 of the Constitution to entertain petitions relating to the terms and conditions of service such as promotion?
  • What is the effect of the absence of Annual Confidential Reports on the consideration of a civil servant for promotion by the Provincial Selection Board?
  Read full judgment →
• Riaz Ahmed vs The State2024 YLR 1144 · Sindh High Court · 2023-12-11
  post-arrest baildishonour of chequeprohibitory clausecriminal liabilitycommercial integritybail as rulestale cheque
  Summary & questions settled

  This bail application concerns an accused seeking post-arrest bail in a case registered under Section 489-F of the Pakistan Penal Code 1860, involving the alleged dishonor of a cheque. The core legal question was whether the applicant was entitled to bail for an offense that does not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898, particularly given the delay in FIR registration and the nature of the offense. The Court held that the offense under Section 489-F, punishable by up to three years, does not fall within the prohibitory clause of Section 497, Cr.P.C., and therefore, the grant of bail is the rule and refusal is the exception. The Court emphasized that Section 489-F is not a mechanism for debt recovery, which should be pursued through civil remedies like Order XXXVII of the Code of Civil Procedure 1908. Finding no exceptional circumstances to warrant detention, the Court granted post-arrest bail, noting that bail is a procedural relief independent of the ultimate trial outcome.

  Questions settled

  • Does an offense under Section 489-F of the Pakistan Penal Code 1860 fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Is Section 489-F of the Pakistan Penal Code 1860 intended to be used as a mechanism for the recovery of money?
  • Can bail be refused in a non-prohibitory offense absent exceptional circumstances like abscondence or tampering with evidence?
  • What is the legal status of a cheque presented for encashment beyond a reasonable time under the Negotiable Instruments Act 1881?
  Read full judgment →
• Riaz Ahmed Khan vs Election Commission of Pakistan, etc.2024 LHC 193 · Lahore High Court · 2024-01-26Read full judgment →
• Riaz Ahmed Khan vs Election Commission of Pakistan, etc2024 LHC 193 · Lahore High Court · 2024-01-26Read full judgment →
• Riaz Ahmad etc vs Secretary to Govt. of the Punjab etc2024 LHC 4101, 2025 MLD 21 · Lahore High Court · 2024-03-11Read full judgment →
• Riasat Ali vs The State, etc.2024 LHC 2316, 2024 PLJ Lahore 527, 2024 PCRLJ 1511 · Lahore High Court · 2024-05-16
  territorial jurisdictionElectricity Utilities CourtFederal Investigation Agencypost-arrest bailplace of occurrencecognizance of offencecriminal trialdoubt as to district
  Summary & questions settled

  This matter involves a writ petition addressing a jurisdictional deadlock regarding the forum for taking cognizance, conducting trial, and adjudicating a post-arrest bail application for an offence under Section 462-J of the Pakistan Penal Code registered at the Federal Investigation Agency (FIA) Circle, Gujrat, where the alleged crime occurred within District Mandi Bahauddin. The core legal question concerned whether registration of a case by the FIA dictates the venue of trial, and which court possesses territorial and special jurisdiction to entertain the bail and trial. The Lahore High Court held that the FIA is solely an investigating agency and its governing statute does not determine trial venues; thus, the parent statute of the offence governs jurisdiction. Under Section 177 of the Code of Criminal Procedure 1898, the trial venue is determined by the place of occurrence, and offences relating to electricity under Chapter XVII-B of the Pakistan Penal Code 1860 are triable by a Court of Session designated as an Electricity Utilities Court under Section 462-G(a). The Court laid down that the court competent to conduct the trial also possesses jurisdiction to entertain bail, and resolved the doubt under Section 185(1) of the Code of Criminal Procedure 1898 by directing the designated Electricity Utilities Court within the territorial limits of the place of occurrence to proceed with the matter.

  Questions settled

  • Does the registration of a case by the Federal Investigation Agency determine the venue of trial for scheduled offences?
  • Which court has the territorial jurisdiction to take cognizance and conduct the trial for offences relating to electricity under Chapter XVII-B of the Pakistan Penal Code 1860?
  • Is a court competent to conduct the trial of a case also competent to entertain and decide a petition for bail in that case?
  • How is jurisdiction determined by the High Court when a question arises as to which of two or more subordinate courts ought to inquire into or try an offence?
  Read full judgment →
• Riasat Ali Sahi vs Ijaz Ahmad and others2024 LHC 966 · Lahore High Court · 2024-03-06Read full judgment →
• Riasat Ali and Fakhar Zaman vs The State and another2024 SCP 167, 2024 SCMR 1224, PLJ 2024 SC (Cr.C.) 208 · Supreme Court of Pakistan · 2024-04-16
  murderocular evidencemedical evidence conflictblackening woundunnatural conduct of witnessesadverse inferencebenefit of doubtcriminal acquittal
  Summary & questions settled

  This matter arose from a criminal petition filed by convict Riasat Ali challenging his conviction and life sentence under Section 302(b) PPC for the murder of Asadullah Khan, after his co-convict was acquitted pursuant to a compromise regarding the murder of another deceased. The core legal question before the Supreme Court was whether the ocular and circumstantial evidence established the petitioner's guilt beyond a reasonable doubt. Re-appraising the evidence, the Supreme Court found critical contradictions: medical evidence showing blackening and charring around the entrance wound contradicted ocular testimony that shots were fired from 5.5 feet away; recovery of crime empties was contradicted by discrepancies in the site plan; and the eye-witnesses' unnatural conduct and uninjured status during close-range firing rendered their presence doubtful. Furthermore, non-production of a key material witness warranted an adverse inference under Article 129(g) of the Qanoon-Shahadat Order, 1984. Consequently, the Supreme Court allowed the appeal, set aside the conviction, and acquitted the petitioner due to reasonable doubt.

  Questions settled

  • Whether conflict between medical evidence regarding firearm distance/blackening and eye-witness testimony creates reasonable doubt requiring acquittal?
  • Does the failure to produce a material eye-witness named in the prosecution case justify drawing an adverse inference under Article 129(g) of the Qanoon-Shahadat Order, 1984?
  • Can the uninjured status and unnatural conduct of alleged eye-witnesses during close-range firing render their presence at the crime scene doubtful?
  Read full judgment →
• Re: FTO's own motion U/S 9 of Fto Ordinance 2001 vs The Secretary,2024 FTO 1 · Federal Tax Ombudsman · 2024-07-03Read full judgment →
• Reliance Weaving Mills Limited vs Federal Board of Revenue (FBR) through Chairman, etc2024 LHC 5453 · Lahore High Court · 2024-11-15Read full judgment →
• Rehmatullah and others vs The State2024 SCP 268, 2024 SCMR 1782, PLJ 2024 SC (Cr.C.) 345 · Supreme Court of Pakistan · 2024-07-29
  circumstantial evidenceextra-judicial confessionpolice custodymedical evidencerecovery of assetsmotivebenefit of doubtacquittal
  Summary & questions settled

  This criminal appeal arose from the conviction of three appellants for murder under Section 302(b)/34 PPC, where the trial and High Court sentenced them to life imprisonment based on circumstantial evidence. The Supreme Court examined whether the chain of circumstantial evidence was sufficiently complete to sustain the conviction. The Court observed that the prosecution's case relied on an alleged extra-judicial confession made while in police custody, which is inadmissible under the law. Furthermore, the recoveries of a motorcycle and mobile phone were deemed unreliable as no proof of ownership or SIM card connection to the deceased was established. The medical evidence contradicted the prosecution's motive of attempted sodomy, as no relevant injuries were found, and the removal of the deceased's eye with a sharp-edged weapon remained unexplained by any recovered weapon. Applying the principle that every link in a circumstantial chain must be proved and incompatible with innocence, the Court held that the prosecution failed to prove its case beyond reasonable doubt. Consequently, the appeals were allowed, and the appellants were acquitted.

  Read full judgment →
• Rehmatullah and others vs Muhammad Ibrahim and others2024 YLR 1556 · Balochistan High Court · 2022-07-06Read full judgment →
• Rehmatullah and 2 others vs The State2024 YLR 595 · Balochistan High Court · 2023-01-05
  post-arrest bailstatutory delayhardened criminalproviso to Section 497criminal trialbail applicationmurder
  Summary & questions settled

  This matter concerns a post-arrest bail application filed by applicants charged under Sections 302, 337-A(ii), 337-F(ii), 147, 148, 149, and 109 of the Pakistan Penal Code 1860. Following a previous conviction that was remanded for non-compliance with Section 353 of the Code of Criminal Procedure 1898, the applicants sought bail on the grounds of statutory delay, having been detained for over two years. The core legal question was whether the statutory right to bail under Section 497 of the Code of Criminal Procedure 1898 for detention exceeding two years is absolute, or if it is barred by the proviso excluding 'hardened, desperate or dangerous criminals.' The Court held that the bail application must be dismissed. It established that the exclusionary proviso in Section 497(1) of the Code of Criminal Procedure 1898 applies to accused persons who are deemed 'hardened, desperate or dangerous,' regardless of whether they are previous convicts. The Court affirmed that it may form this opinion based on the materials available in the case under trial.

  Questions settled

  • Does the statutory delay provision in Section 497 of the Code of Criminal Procedure 1898 grant an absolute right to bail for an accused detained for over two years?
  • Can the court classify an accused as a 'hardened, desperate or dangerous criminal' under Section 497 of the Code of Criminal Procedure 1898 without a prior conviction?
  • Is the exclusionary proviso in Section 497 of the Code of Criminal Procedure 1898 applicable to an accused who is not a previously convicted offender?
  Read full judgment →
• Rehmat Ullah vs The State and another2024 YLR 161 · Lahore High Court · 2023-09-04
  post-arrest bailPunjab Food Authority Actsubstandard meatprohibitory clausecriminal recordtentative assessment
  Summary & questions settled

  The petitioner sought post-arrest bail in a case involving alleged violations of the Punjab Food Authority Act, 2011, specifically regarding the possession of substandard meat. The core legal question was whether the petitioner was entitled to bail given the evidentiary gaps in the prosecution's case and the nature of the alleged offences. The Lahore High Court held that the prosecution failed to provide the necessary veterinary certificate or expert report substantiating the claim that the meat was injurious to human health, noting that a visual inspection by non-experts is insufficient. Furthermore, the court observed that the alleged offences did not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898, and the petitioner had already been detained for approximately two months without any prior convictions in other registered cases. Consequently, the court granted post-arrest bail, emphasizing that tentative assessment of the record revealed insufficient grounds for continued incarceration, particularly where the prosecution's evidence lacked scientific verification.

  Questions settled

  • Is a visual inspection by non-experts sufficient to establish that food items are injurious to human consumption?
  • Does the absence of a veterinary certificate or expert report in the police file constitute a ground for granting bail?
  • Can bail be granted when the alleged offences do not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Does the existence of previous FIRs without convictions preclude the grant of bail?
  Read full judgment →
• Rehmat Karim vs Government of Gilgit-Baltistan through Chief Secretary2024 PLC (C.S) 96 · Gilgit Baltistan Chief Court · 2023-06-12
  regularization of servicecontingent paid staffMotor Vehicle Examinerwrit petitionGilgit-Baltistanservice matters
  Summary & questions settled

  The petitioner, a contingent paid staff member performing duties in the Excise and Taxation Department, filed a writ petition under Article 86(2) of the Government of Gilgit-Baltistan Order, 2018, seeking regularization of his service as a Motor Vehicle Examiner (BPS-14) against a vacant post, relying on his meritorious service, recommendations by local authorities, and being a land donor for the department. The respondents contested the maintainability, arguing he was appointed without a specific designation on a contingent basis and that his case did not fulfill the statutory requirements under the Gilgit-Baltistan Regularization of Services Act, 2020. The Gilgit Baltistan Chief Court disposed of the writ petition by referring the matter to the regularization committee to consider the petitioner's case in light of the departmental recommendations, holding that the regularization case requires administrative consideration under the relevant statutory provisions.

  Questions settled

  • Whether a contingent paid employee can claim regularization as a Motor Vehicle Examiner without fulfilling the statutory prerequisites under the Gilgit-Baltistan Regularization of Services Act, 2020?
  • Does the temporary assignment of a higher post's charge to a contingent staff member confer a legal right to regularization against that post?
  • Can a writ petition be disposed of with a direction to the regularization committee to consider an employee's case based on departmental recommendations?
  Read full judgment →
• Rehm Dad vs Province of Punjab through its Chief Secretary, Lahore &2024 SCP 93, 2024 PLD Supreme Court 499 · Supreme Court of Pakistan · 2024-02-15
  Intra-court appealLaw Reforms OrdinanceLand acquisitionMaintainabilityOriginal orderBoard of RevenuePunjab Land Acquisition Rules
  Summary & questions settled

  This civil petition challenges a High Court judgment that dismissed an Intra-Court Appeal (ICA) as non-maintainable. The core legal question is whether the proviso to Section 3(2) of the Law Reforms Ordinance, 1972, bars an ICA against an order passed by the Board of Revenue under the Punjab Land Acquisition Rules, 1983. The Supreme Court held that the ICA is maintainable. The court clarified that the proviso to Section 3(2) of the Law Reforms Ordinance, 1972, only precludes an ICA if the law applicable to the proceedings provides a statutory right of appeal, revision, or review against the 'original order.' Since the application under the 1983 Rules did not provide such remedies, the bar was inapplicable. The court established that the 'original order' is the order initiating the specific proceedings, not the historical acquisition notification. Furthermore, while rules framed under a statute are part of the parent act, the absence of an appellate remedy within that framework preserves the right to an ICA.

  Questions settled

  • Is an intra-court appeal maintainable under the proviso to Section 3(2) of the Law Reforms Ordinance, 1972, if the relevant law provides no right of appeal, revision, or review against the original order?
  • Does the 'original order' for the purpose of the proviso to Section 3(2) of the Law Reforms Ordinance, 1972, refer to the order commencing the specific proceedings or the initial acquisition notification?
  • Are rules framed under a statute considered part of the parent act for determining the applicable law under the proviso to Section 3(2) of the Law Reforms Ordinance, 1972?
  Read full judgment →
• Rehana Nazir vs District Police Officer, etc2024 LHC 3460, 2025 PCRLJ 1 · Lahore High Court · 2024-07-19
  habeas corpusjuvenile justicechild protectiondestitute childrendiversion measuresjuvenile courtprobation officer
  Summary & questions settled

  This constitutional petition was filed under Article 199 of the Constitution of Pakistan 1973, read with Section 491 of the Code of Criminal Procedure 1898, seeking the recovery of an eleven-year-old child from alleged illegal custody. The child was produced by the police, who revealed he was implicated in a theft case but released on surety under the Juvenile Justice System Act 2018. Observing the child and his siblings to be in a pitiable, neglected condition, the High Court entrusted their custody to the Child Protection and Welfare Bureau under the Punjab Destitute and Neglected Children Act 2004. The Court noted a systemic failure by state functionaries to implement the Juvenile Justice System Act 2018. It held that the enforcement of statutory welfare laws is a mandatory constitutional duty of the state. Consequently, the Court issued comprehensive directives to the government, police, and prosecution to establish specialized juvenile courts, observation homes, and Juvenile Justice Committees, and to prioritize diversion measures over formal trials.

  Questions settled

  • What are the mandatory duties of state functionaries regarding the implementation of the Juvenile Justice System Act 2018?
  • Under what circumstances can a juvenile offender be tried jointly with an adult offender?
  • What is the legal mechanism and purpose of disposing of juvenile cases through diversion under the Juvenile Justice System Act 2018?
  • What protections are guaranteed to female juvenile offenders during arrest, investigation, and detention?
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• Reham Dad vs Province of Punjab through Chief Secretary and others2024 CLC 114 · Lahore High Court · 2022-03-24Read full judgment →
• Regional Manager Utility Stores Corporation of Pakistan, Regional Office2024 PLJ SC (AJ&K) 136 · Supreme Court of Azad Jammu and KashmirRead full judgment →
• Reference by the President of Islamic Republic of Pakistan under Article 186 of the Constitution vs Reference by the President of Islamic Republic of Pakistan Under Article 186 of the Constitution to revisit the case of Zulfiqar Ali Bhutto2024 SCP 8 · Supreme Court of Pakistan · 2024-01-08
  Presidential ReferenceAmicus CuriaeConflict of InterestJudicial ReviewProcedural AdjournmentHistorical Conviction
  Summary & questions settled

  This matter concerns a Presidential Reference filed under Article 186 of the Constitution of Pakistan 1973, seeking to revisit the conviction and death sentence of the late Zulfiqar Ali Bhutto. The proceedings before the Supreme Court focused on procedural preliminaries, specifically the appointment and recusal of amici curiae and legal representation for the family members of the deceased. The Court addressed potential conflicts of interest regarding appointed amici, allowing the withdrawal of one amicus due to a prior family connection to a co-accused in the original case, while retaining another despite a disclosure regarding a familial link to the victim of the original murder case, as no objections were raised by the parties present. The Court also facilitated the exchange of evidentiary material, including reports and recordings, among the counsel and amici. Given the significance of the Reference and the Court's intent to conduct a detailed examination of the historical record, the proceedings were adjourned to the third week of February 2024, partly to accommodate the upcoming general elections and to allow for a thorough review of the voluminous documentation submitted.

  Questions settled

  • Can an amicus curiae be replaced by counsel if the parties involved do not object?
  • Does a familial connection to a party in a historical criminal case necessitate the automatic recusal of an appointed amicus curiae?
  • Is the Supreme Court empowered to adjourn proceedings in a Presidential Reference to allow for the review of voluminous evidentiary material?
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• Reference by the President of Islamic Republic of Pakistan Under Article 186 of the Constitution to revisit the case of Zulfiqar Ali Bhutto reported as PLD 1979 SC Page 38-53 vs [Reference by the President of Islamic Republic of Pakistan under Article 186 of the Constitution]2024 SCP 89, 2024 PLD Supreme Court 509 · Supreme Court of Pakistan · 2024-03-06
  presidential referenceadvisory jurisdictiondue processfair trialhistorical judicial reviewfundamental rights
  Summary & questions settled

  This presidential reference under Article 186 of the Constitution of Pakistan sought the opinion of the Supreme Court regarding the murder trial, conviction, and execution of former Prime Minister Zulfiqar Ali Bhutto. The core legal question addressed was whether the requirements of due process and fair trial were complied with during the proceedings before the Lahore High Court and the Supreme Court. In its opinion, the Court held that the trial and appellate proceedings did not meet the fundamental rights to a fair trial and due process enshrined in the Constitution. However, the Court clarified that neither the Constitution nor the law provides a mechanism to set aside the final judgment of conviction. Furthermore, the Court declined to reappraise evidence in its advisory jurisdiction or answer questions regarding Islamic law and the doctrine of repentance due to a lack of legal assistance on the matter. The key principle laid down is that while the Court can acknowledge major constitutional and legal lapses in historical judicial proceedings under its advisory jurisdiction, it cannot formally set aside or undo final judicial decisions.

  Questions settled

  • Can the Supreme Court set aside a final judgment of conviction and sentence in its advisory jurisdiction under Article 186 of the Constitution?
  • Did the murder trial and subsequent appeal of Zulfiqar Ali Bhutto fulfill the requirements of due process and fair trial?
  • Does the Supreme Court have the power to reappraise evidence and undo a finalized criminal decision through a presidential reference?
  • Whether the proceedings against Zulfiqar Ali Bhutto met the fundamental rights guaranteed under Articles 4, 9, and 10A of the Constitution of Pakistan?
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• Reference by the President of Islamic Republic of Pakistan under Article 186 of the Constitution vs N/A2024 SCP 230 · Supreme Court of Pakistan · 2024-07-05
  presidential referenceadvisory jurisdictionfair trialdue processmurder trialaccomplice testimonyjudicial biasconstitutional interpretation
  Summary & questions settled

  This judgment contains the reasoned opinion of the Supreme Court of Pakistan under Article 186 of the Constitution in a Presidential Reference concerning the murder trial, conviction, and execution of former Prime Minister Shaheed Zulfiqar Ali Bhutto. The core legal questions addressed the compliance of the trial and appellate processes with fundamental rights, due process, and fair trial guarantees, alongside the historical legitimacy of the proceedings conducted during a martial law regime. The Court held that the proceedings of the trial by the Lahore High Court and the appeal by the Supreme Court failed to meet the requirements of the fundamental right to a fair trial and due process, and suffered from grave constitutional and legal lapses, including unauthorized reopening of the investigation, the unprecedented conduct of a murder trial by the High Court rather than a Court of Session, and apparent judicial bias. However, the Court observed that neither the Constitution nor the law provides a mechanism to set aside the final judgment in its advisory jurisdiction. The key principles laid down emphasize that due process and fair trial are foundational elements of criminal jurisprudence and constitutional governance that cannot be bypassed, and that courts must transparently confront past judicial fallibilities to uphold the integrity of the administration of justice.

  Questions settled

  • Whether a presidential reference under Article 186 of the Constitution can be entertained to evaluate the due process and fairness of a historical criminal trial?
  • Whether the trial of a murder case directly by the High Court instead of a Court of Session vitiates the trial and deprives the accused of statutory rights of appeal and sentence confirmation?
  • Whether the testimony of an approver requires strict corroboration in material particulars to form the basis of a conviction in a capital case?
  • Whether the Supreme Court in its advisory jurisdiction under Article 186 of the Constitution has the power to set aside a final judgment of conviction and sentence?
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• Reckitt Benckiser Pakistan Ltd. For Deceptive Marketing Practices vs In The Matter of_ Show Cause Notice Issued To_ Unilever Pakistan Limited2024 CLD 1069 · Competition Commission of Pakistan · 2024-07-31Read full judgment →
• re-Kamran @ Wago vs The State2024 SHC 772 · Sindh High Court · 2024-07-15
  post-arrest bailfurther inquirypolice encounterSindh Arms Act 2013attempt to murderprohibitory clausecriminal procedure
  Summary & questions settled

  This matter concerns post-arrest bail applications filed by the applicant in two FIRs involving charges of attempted murder, obstruction of public servants, and possession of unlicensed weapons. The core legal question was whether the applicant was entitled to bail given the prosecution's allegations of a police encounter, despite the absence of injuries to any police personnel and the completion of the investigation. The Court held that the applicant is entitled to bail, determining that the case falls within the scope of "further inquiry." The Court reasoned that the lack of injuries to police officials, the absence of independent witnesses, and the fact that the investigation was complete warranted the grant of bail. Furthermore, the Court highlighted the legal distinction between "arms" and "firearms" under the Sindh Arms Act 2013, noting that the applicability of specific penal provisions required trial court determination. The key principle laid down is that where the prosecution's story appears improbable and reasonable doubt exists regarding an accused's participation, the accused should not be deprived of their liberty, as freedom is a precious right.

  Questions settled

  • Does the absence of injuries to police personnel in an alleged encounter constitute grounds for further inquiry in a bail application?
  • Is an accused entitled to bail when the investigation is complete and no independent witnesses are associated with the recovery of weapons?
  • What is the legal distinction between 'arms' and 'firearms' under the Sindh Arms Act 2013 regarding the applicability of penal provisions?
  • Should an accused be granted bail when the prosecution fails to substantiate the charge with evidence beyond the testimony of police officials?
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• re-Imtiaz Ali & Raj Kumar vs The State2024 SHC 768, 2025 PCRLJ 786 · Sindh High Court · 2024-07-15
  post-arrest bailprohibitory clauseextra-judicial confessionpolice custodystolen propertyfurther inquirycriminal record
  Summary & questions settled

  This matter arises from post-arrest bail applications filed by the applicants seeking release in F.I.R. Nos. 182 and 183 of 2024 registered under Section 381-A of the Pakistan Penal Code 1860 at Police Station Joharabad, Karachi. The core legal questions involve the admissibility of extra-judicial confessions made in police custody, the evidentiary value of recoveries, and whether bail should be granted when the alleged offence falls outside the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898. The court held that extra-judicial confessions made to police are inadmissible under the Qanun-e-Shahadat Order 1984, that mere registration of other criminal cases without conviction does not justify withholding bail, and that offences not falling within the prohibitory clause warrant bail as a rule. The key principles laid down include that the liberty of a person is a precious right, that grant of bail in non-prohibitory clause offences is the norm with refusal as the exception, and that pending cases without proof of previous conviction cannot form the sole basis to deny bail.

  Questions settled

  • Is an extra-judicial confession made while in police custody admissible in evidence?
  • Can bail be refused to an accused solely on the ground that other criminal cases have been registered against them without proof of conviction?
  • Does an offence under Section 381-A or Section 411 of the Pakistan Penal Code 1860 fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • What is the evidentiary requirement for establishing dishonest receipt of stolen property under Section 411 of the Pakistan Penal Code 1860?
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• Razia Begum & 05 others vs Member (Judicial-III) B.O.R., & 12 others2024 LHC 3377, 2024 PLJ Lahore 698, 2024 CLC 1910 · Lahore High Court · 2024-06-27Read full judgment →