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.

• Production Engineer PPL, I/C Camp office, Kandhkot and 04 others vs2023 SHC 654, 2024 PLD Sindh 259 · Sindh High Court · 2023-08-24Read full judgment →
• Principal Khyber Institute of Education vs University of Peshawar through Registrar and others2024 MLD 305 · Peshawar High Court · 2022-07-25Read full judgment →
• Prime Builders vs Pakistan Industrial Development Corporation (Pvt) Ltd &2024 SHC 872, 2025 PLD Sindh 166 · Sindh High Court · 2024-08-15Read full judgment →
• Premium Textile Mills Ltd. & Others vs Federation of Pakistan & Others2024 SHC 904, 2025 CLC 332 · Sindh High Court · 2024-09-06Read full judgment →
• Power Station (Pvt) Ltd vs NEPRA and Others2024 SHC 1208 · Sindh High Court · 2024-10-31Read full judgment →
• Postmaster General Balochistan vs Amanat Ali and others, Muhammad2024 SCP 271, 2024 SCMR 1484, 2024 PLC (C.S.) 1051, 2024 PLJ SC 696 · Supreme Court of Pakistan · 2024-04-17
  service tribunalquantum of punishmentmisappropriation of public fundsdismissal from servicereduction in time scaledepartmental inquirycivil servantmisconduct
  Summary & questions settled

  These civil appeals arose from judgments of the Federal Service Tribunal which had converted the major penalty of dismissal from service into a minor penalty of reduction in time scale for two years against postal department employees found guilty of facilitating a massive financial fraud and embezzlement of public funds at a post office through dereliction of duty and violation of rules. The core legal question was whether the Service Tribunal was justified in interfering with the quantum of punishment awarded by the competent authority without identifying any legal defect in the inquiry reports or proceedings. The Supreme Court allowed the appeals, holding that while the Tribunal possesses the power to modify penalties, such discretion must be exercised judiciously with a proper application of mind and proportionate to the gravity of the misconduct, especially where public funds and embezzlement are involved, and that the administrative authority's primary role in awarding punishment should not be interfered with lightly. The key principle laid down is that the Service Tribunal cannot arbitrarily or without sound rationale reduce a major penalty to a minor one in cases of proven financial corruption and gross negligence, and the primary assessment of punishment by the competent department must be respected unless found unreasonable or unlawful.

  Questions settled

  • Does the Service Tribunal have the power to modify the quantum of punishment awarded to a civil servant by a departmental authority?
  • Under what circumstances can a court or tribunal substitute its own finding on punishment for that of the administrative authority?
  • Can employees involved in the embezzlement of public funds be let off with a minor penalty without proper justification by the Service Tribunal?
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• Popular International (Pvt.) Limited through duly authorized officer vs Pakistan through Secretary, Revenue and Ex-Officio Chairman and another2024 PTD 846, 2024 PLD Sindh 325, 2024 PTD 1121 · Sindh High Court · 2023-11-06Read full judgment →
• Pirbhu Lal vs Jhaman Das & another2024 SHC 1148 · Sindh High Court · 2024-10-02
  criminal appealacquittalbenefit of doubtappreciation of evidencecivil disputewitness credibilitysettlement
  Summary & questions settled

  This criminal appeal challenged the judgment of the Additional Sessions Judge, which set aside the conviction of the respondent, Jhaman Das, for offenses under sections 337-F(vi) and 504 of the Pakistan Penal Code 1860. The core legal question concerned whether the appellate court erred in acquitting the respondent due to alleged contradictions in the prosecution's evidence and the existence of admitted civil litigation between the parties. Upon review, the High Court noted significant inconsistencies in the testimonies of the complainant and prosecution witnesses, alongside the admitted enmity between the parties, which cast reasonable doubt on the prosecution's case. The court observed that the benefit of doubt must be extended to the accused as a matter of right when evidence is not confidence-inspiring. Ultimately, the parties reached a mutual settlement to maintain peace and avoid further criminal activity. Consequently, the High Court disposed of the appeal by consent, directing the Deputy Commissioner and the Senior Superintendent of Police to monitor compliance with the peace arrangement, without disturbing the acquittal.

  Questions settled

  • Does the existence of admitted enmity and civil litigation between parties create reasonable doubt in a criminal case?
  • Is a single circumstance creating reasonable doubt sufficient to warrant the acquittal of an accused?
  • Can an appellate court set aside a conviction based on contradictions and lacunas in the prosecution's evidence?
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• Pir Syed Ghulam Samdani & another vs Chief Administrator Auqaf & 032024 LHC 5831 · Lahore High CourtRead full judgment →
• Pervez Elahi vs Election Commission of Pakistan, etc2024 SCP 41, 2024 PLD Supreme Court 571 · Supreme Court of Pakistan · 2024-01-26
  nomination papersright to contest electionpro-enfranchisementelection expensesexclusive bank accountmisdeclaration of assetselectoral processsubstantial defect
  Summary & questions settled

  This matter concerns the rejection of the petitioner's nomination papers for a Provincial Assembly seat, primarily on grounds of failing to maintain an exclusive bank account for each contested seat and alleged non-disclosure of assets. The core legal questions were whether a candidate must open a separate bank account for every individual seat contested and whether the Returning Officer properly rejected the nomination for an alleged asset omission. The Supreme Court held that the requirement for an exclusive bank account under the Elections Act, 2017, is for the purpose of managing election expenses generally, not per seat, and that one account suffices for multiple seats. Furthermore, the Court held that the asset in question was acquired after the mandatory reporting date of June 30th, rendering the objection invalid. The Court emphasized that the right to contest elections is a fundamental right, requiring strict construction of provisions that curtail it. It established that election laws must be interpreted in a pro-enfranchisement manner, and nomination papers should not be rejected for non-substantial defects that can be remedied.

  Questions settled

  • Does the Elections Act 2017 require a candidate to maintain a separate exclusive bank account for every individual seat they are contesting?
  • Is the right to contest an election a fundamental right that requires strict construction of statutory provisions curtailing it?
  • Can a Returning Officer reject a nomination paper for a defect that is not of a substantial nature?
  • Should a statement of assets and liabilities be based on the preceding thirtieth day of June as per the Elections Act 2017?
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• Pervez Akhtar vs Ali Salman and another2024 CLC 1558 · Lahore High Court · 2023-04-14Read full judgment →
• Pervaiz Rasheed and others vs PTV2024 SCP 125, 2024 SCMR 942, 2024 PLC (C.S.) 803, 2024 PLJ SC 816 · Supreme Court of Pakistan · 2024-03-21
  review jurisdictionArticle 184(3)public sector appointmentfinancial liabilityfundamental rightsarbitrary determinationSupreme Court review
  Summary & questions settled

  These review petitions challenge a 2018 Supreme Court judgment concerning the appointment of Mr. Attaul Haq Qasmi as Director/Chairman/Managing Director of Pakistan Television Corporation (PTV). The core legal questions involved whether the original judgment correctly invoked Article 184(3) of the Constitution and whether the findings of illegality, financial loss, and personal liability imposed on government officials were factually and legally sound. The Supreme Court allowed the review petitions and recalled the 2018 judgment. The Court held that the invocation of Article 184(3) requires a clear nexus to fundamental rights or public importance, which was absent. Furthermore, the Court determined that the calculation of financial loss was arbitrary, based on conjecture regarding notional airtime revenue, and failed to account for inflation regarding salary comparisons. The Court emphasized that imposing personal liability for financial losses on public officials without evidence of corruption, nepotism, or personal benefit lacks legal basis and precedent. The original judgment contained material factual errors and legal misapplications, necessitating its recall.

  Questions settled

  • Does the invocation of Article 184(3) of the Constitution require a clear demonstration of public importance and the undermining of fundamental rights?
  • Can a court impose personal financial liability on public officials for administrative decisions without evidence of corruption or personal benefit?
  • Is a calculation of financial loss based on notional revenue, such as airtime value, legally sustainable for recovery purposes?
  • What is the scope of the Supreme Court's review jurisdiction regarding material factual errors?
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• Pervaiz Khan vs The State and another2024 PCRLJ 1118 · Peshawar High Court · 2023-07-03
  murder convictioneyewitness testimonyabsconsioncorroboratory evidencecriminal appealminor contradictionsappreciation of evidence
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of the appellant for murder under Section 302/34 of the Pakistan Penal Code 1860, following a trial court judgment. The core legal questions concerned the reliability of eyewitness testimony given the passage of time and the evidentiary value of the appellant's absconsion. The Peshawar High Court dismissed the appeal, upholding the conviction. The Court held that the prosecution successfully proved its case beyond reasonable doubt through consistent eyewitness accounts and medical evidence. Regarding the legal principles, the Court established that minor contradictions in the testimony of prosecution witnesses, arising due to the passage of time between the occurrence and the trial, are natural and do not warrant discarding the entire evidence if the witnesses remain consistent on material particulars. Furthermore, the Court affirmed that while absconsion alone is insufficient to sustain a capital conviction, it constitutes a significant corroboratory piece of evidence when supported by other reliable incriminating material, such as eyewitness testimony and forensic reports. The conviction was thus maintained.

  Questions settled

  • Can minor contradictions in the testimony of prosecution witnesses, arising from the passage of time, invalidate their entire account?
  • Is the factum of absconsion sufficient by itself to sustain a conviction on a capital charge?
  • Does the presence of natural and confidence-inspiring eyewitnesses require independent corroboration to sustain a conviction?
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• Pervaiz Ali vs Province of Sindh2024 SHC 32 · Sindh High Court · 2024-01-25
  fundamental right to educationclosed schoolsbiometric attendanceScheduled New Expenditureteacher recruitmentpublic librarieseducational reformsconstitutional petition
  Summary & questions settled

  The petitioner filed a constitutional petition under Article 199 of the Constitution of Pakistan 1973, seeking the restoration of a Government Boys Primary School in Sindh that had been deleted from the database, alongside the rectification of biometric attendance errors for its sole teacher. Taking judicial notice of the systemic crisis of closed, deleted, and non-viable schools across Sindh, the High Court of Sindh ordered comprehensive inspections by District Magistrates. The reports revealed thousands of schools closed due to non-posting of teachers, lack of infrastructure, and non-sanctioning of Scheduled New Expenditure (SNE). The Court held that education is an inalienable fundamental right under Article 25-A of the Constitution, which the State has a non-negotiable duty to provide. The Court disposed of the petition with exhaustive directions, including: the immediate restoration of deleted schools; transparent, merit-based recruitment of teachers within two months; the mandatory sanctioning of SNEs; the implementation of the Dr. Iqbal Hussain Durrani Education Reforms Committee report; the transition of degree programs from two to four years; and the revitalization of public libraries and digital labs.

  Questions settled

  • Whether the state can justify the closure or deletion of public schools on the grounds of financial constraints or non-availability of teachers under Article 25-A of the Constitution?
  • Can the discretionary powers of the Chief Minister under Section 24 of the Sindh Civil Servants Act 1973 be used to grant personal financial benefits or scholarships from public endowment funds?
  • What is the role of the District Judiciary in monitoring and ensuring the proper functioning and removal of encroachments from public educational institutions?
  • Is the state constitutionally mandated to provide free and compulsory secondary education under the Directive Principles of State Policy and Article 25-A?
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• Pervaiz Ahmed @ Paroo Rajper vs The State2024 SHC 112 · Sindh High Court · 2024-02-13
  murderdeath sentenceconfirmation referencerefusal to marryeyewitness testimonyrelated witnessesmotivemedical evidence
  Summary & questions settled

  This criminal jail appeal and confirmation reference arise from a judgment of the trial court convicting the appellant, Pervaiz Ahmed, under section 302(b) of the Pakistan Penal Code 1860 for the premeditated murder of a young girl following her refusal to marry him, sentencing him to death. The core legal questions involve whether the prosecution successfully established its case through ocular and medical evidence despite minor contradictions, the non-production of an eyewitness who was allegedly won over, and the reliability of related witnesses. The Sindh High Court held that the prosecution proved its case beyond reasonable doubt through trustworthy eyewitness testimony, corroborated by medical evidence and a proven motive, and that the mere relationship of witnesses to the deceased or the non-production of a won-over witness does not impair the prosecution's case. The court maintained the conviction, dismissed the appeal, and confirmed the death sentence.

  Questions settled

  • Whether the testimony of related eyewitnesses can be relied upon to sustain a conviction in a murder trial in the absence of independent corroboration?
  • Does the non-production of an eyewitness for cross-examination due to being won over vitiate the entire prosecution case?
  • Whether minor contradictions and discrepancies in the statements of prosecution witnesses are sufficient to create a doubt regarding the guilt of the accused?
  • What is the standard for awarding capital punishment versus a lesser penalty in cases of Qatl-e-Amd proven beyond reasonable doubt?
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• PC Veeram Khan and another vs The State2024 YLR 2323 · Sindh High Court · 2024-02-19
  criminal breach of trustmisappropriation of service weaponbenefit of doubtunexplained delay in FIRnon-sealing of recovered weaponadverse inferenceanti-corruption appeal
  Summary & questions settled

  This matter involves two criminal appeals assailing the judgments of the Special Judge Anti-Corruption (Provincial) Larkana, whereby the appellants were convicted and sentenced under Section 409 of the Pakistan Penal Code 1860 read with Section 5(2) of the Pakistan Criminal Law Amendment Act 1947 for allegedly misappropriating official service rifles and failing to return them or depositing fake replacements. The core legal questions revolved around whether the prosecution successfully established the charge of criminal breach of trust beyond a reasonable doubt, the effect of inordinate and unexplained delay in lodging the FIRs, the failure to follow mandatory procedures regarding the sealing and safe transmission of recovered weapons, and the lack of independent corroboration. The Sindh High Court allowed the appeals, set aside the convictions and sentences, and acquitted the appellants by extending the benefit of the doubt. The court held that multiple serious lapses by the prosecution—including unexplained delays in lodging FIRs, failure to seal the alleged weapons at the time of recovery, non-examination of key recovery witnesses, violation of provisions requiring independent private mashirs, and failure to prove safe custody and transmission of evidence—vitiated the evidentiary value of the prosecution case, entitling the accused to acquittal as a matter of right.

  Questions settled

  • Does an inordinate and unexplained delay in lodging an FIR create a reasonable doubt in the prosecution case?
  • What is the legal effect on the prosecution case when alleged recovered weapons are not sealed at the time of recovery and lack safe transmission?
  • Can an accused be convicted of criminal breach of trust under Section 409 PPC when recovery memos are not prepared and essential witnesses are withheld?
  • Does the failure to associate private independent witnesses during recovery proceedings violate statutory safeguards under criminal procedure?
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• Parvez Khan Son of Talazar vs The State2024 SHC 152 · Sindh High Court · 2024-01-31
  narcotics traffickingcriminal appealpossession of narcoticsdriver liabilitychemical examiner reportofficial witnessesburden of proofprocedural technicalities
  Summary & questions settled

  This criminal appeal challenged the conviction and sentence of the appellant, who was found guilty of transporting 46 kilograms of heroin powder in a truck. The core legal questions concerned whether the prosecution sufficiently established the appellant's guilt, whether the driver of a vehicle can be held liable for narcotics found therein, and whether procedural omissions regarding the investigation and chemical analysis vitiated the conviction. The Sindh High Court dismissed the appeal, holding that the prosecution successfully proved the charge beyond reasonable doubt. The court affirmed that a driver in charge of a vehicle is presumed to have knowledge and control over its contents, establishing liability for narcotics found within. Furthermore, the court held that official witnesses are competent, and their testimony is not discarded solely due to their status. Emphasizing a dynamic approach, the court ruled that minor procedural technicalities should not override substantive evidence of guilt, particularly when the prosecution has discharged its initial burden, thereby shifting the onus to the accused under the Control of Narcotic Substances Act 1997, to prove otherwise.

  Questions settled

  • Is the driver of a vehicle legally responsible for the transportation of narcotics found within the vehicle?
  • Can the testimony of official witnesses be discarded solely because they are police or excise officials?
  • Does the failure to associate private witnesses in a narcotics search under Section 103 of the Code of Criminal Procedure 1898 vitiate a conviction?
  • Can a complainant also act as the investigating officer in a criminal case?
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• Parvez Elahi vs Additional Sessions Judge and 3 others2023 LHC 4588, 2024 PCRLJ 55, PLJ 2024 Cr.C. 66 · Lahore High Court · 2023-09-18
  physical remandrevisional jurisdictionjudicial orderSpecial JudgeCode of Criminal Procedureremand refusalsupervisory jurisdiction
  Summary & questions settled

  This petition under Section 561-A of the Code of Criminal Procedure 1898 challenged an order by an Additional Sessions Judge that had set aside a Magistrate’s refusal to grant physical remand. The petitioner contended that the Magistrate’s order was not a judicial order subject to revision and that, alternatively, only a 'Special Judge' appointed under the Pakistan Criminal Law Amendment Act 1958 possessed revisional jurisdiction. The Court held that an order refusing physical remand constitutes a judicial function, rendering it amenable to the revisional jurisdiction of the Court of Sessions under Sections 435 and 439-A of the Code of Criminal Procedure 1898. Furthermore, the Court clarified that the jurisdiction of a 'Special Judge' under the Pakistan Criminal Law Amendment Act 1958 pertains to proceedings initiated after the submission of a charge-sheet or complaint, and does not exclude the supervisory powers of the Court of Sessions over remand proceedings conducted by ordinary Magistrates. Consequently, the Court dismissed the petition, affirming that the Court of Sessions correctly exercised its revisional powers to correct the Magistrate's order.

  Questions settled

  • Is an order passed by a Magistrate refusing physical remand a judicial order subject to the revisional jurisdiction of the Court of Sessions?
  • Does the Court of Sessions have jurisdiction to revise an order passed by a Magistrate under Section 167 of the Code of Criminal Procedure 1898?
  • Does the jurisdiction of a 'Special Judge' under the Pakistan Criminal Law Amendment Act 1958 exclude the revisional powers of the Court of Sessions regarding pre-trial remand proceedings?
  • What is the scope of the term 'proceedings' under Section 6 of the Pakistan Criminal Law Amendment Act 1958 regarding the jurisdiction of a Special Judge?
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• Parvez Ahmed vs Province of Sindh & Another2024 SHC 302 · Sindh High Court · 2024-04-17Read full judgment →
• Parveen Akhtar and others vs Custodian of Evacuee Property, Azad2024 PLJ SC (AJ&K) 23 · Supreme Court of Azad Jammu and KashmirRead full judgment →
• Parvaiz Akhter Bhatti and others vs Federation of Pakistan, etc2024 IHC 260 · Islamabad High CourtRead full judgment →
• Paru vs Sagram & another2024 SHC 1118 · Sindh High Court · 2024-09-26
  cancellation of bailpre-arrest bailprohibitory clausedelay in FIRfurther inquirymisuse of bailgrievous hurt
  Summary & questions settled

  This Criminal Miscellaneous Application was filed by the complainant under Section 497(5) of the Code of Criminal Procedure 1898 seeking the cancellation of pre-arrest bail granted to the respondents by the Additional Sessions Judge-II, Tharparkar in a case involving offences under Sections 147, 148, 149, 337-F(vi), 337-F(i), 506(2), and 504 of the Pakistan Penal Code 1860. The core legal questions addressed were whether pre-arrest bail was appropriately granted despite an unexcused delay in lodging the FIR, and whether strong grounds existed to warrant cancellation of bail. The High Court dismissed the application, confirming the trial court's order. The Court held that an unexplained 12-day delay in lodging the FIR raised doubts of consultation and false implication. Furthermore, the non-bailable offences did not fall within the prohibitory clause of Section 497 CrPC, and there was no evidence that the respondents had misused the concession of bail or violated established legal principles governing bail cancellation.

  Questions settled

  • Can bail granted by a court of competent jurisdiction be cancelled without proof of misuse of the concession of bail?
  • Does an inordinate, unexplained delay in lodging an FIR justify the grant of bail on the ground of further inquiry?
  • What are the established grounds on which superior courts may recall or cancel an order granting bail?
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• Paras Ali Gadani vs The State2024 YLR 693 · Sindh High Court · 2022-06-03
  murderfirearm injuryocular evidencemedical corroborationinterested witnessesminor contradictionscriminal appeal
  Summary & questions settled

  This criminal appeal arises from a judgment passed by the Additional Sessions Judge-III/MCTC-II, Sukkur, whereby the appellant Paras Ali was convicted under Section 302(b) of the Pakistan Penal Code 1860 and sentenced to life imprisonment as Tazir with compensation under Section 544-A of the Code of Criminal Procedure 1898. The prosecution case was that the appellant, along with an absconding co-accused, attacked the complainant's brother due to a dispute over neighborhood residence, resulting in fatal firearm injuries. The core legal question was whether the prosecution proved its case beyond reasonable doubt through consistent ocular accounts, medical evidence, and prompt registration of the FIR. The Sindh High Court held that the prosecution successfully established the guilt of the appellant through reliable and confidence-inspiring testimony of eye-witnesses, duly corroborated by medical evidence and recovery of crime weapons, while minor discrepancies did not affect the core case. The appeal was accordingly dismissed, and the conviction and sentence were upheld.

  Questions settled

  • Whether delay in the registration of an FIR is successfully explained when the complainant first shifts the injured victim to the hospital?
  • Does a close inter se relationship between the complainant, witnesses, and the deceased render their testimony inherently unreliable?
  • Can minor contradictions and discrepancies in the statements of prosecution witnesses detract from an otherwise consistent ocular and medical account?
  • Whether conflicts between expert medical evidence and direct ocular testimony are sufficient to discard the eyewitnesses' account if accepted by the court?
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• Palwasha Sherani and others vs Pakistan Medical and Dental Council2024 MLD 623 · Balochistan High Court · 2023-11-23Read full judgment →
• Pakistan Tobacco companu Limited through its general attorney vs Iftikhar2024 PHC 302, 2025 YLR 585 · Peshawar High Court · 2024-07-24Read full judgment →
• Pakistan Telecommunication Company Limited & Another vs Rasheed2024 SHC 900, 2024 PLC (C.S.) 1555 · Sindh High Court · 2024-09-05
  service regulationsdisciplinary proceedingscompetent authorityboard of directors resolutioncivil appealwrongful terminationmaster and servant
  Summary & questions settled

  This civil appeal arises from a judgment and decree passed by the Sindh High Court in a service dispute, wherein the trial court had ruled in favor of the Respondent employee and awarded damages for wrongful termination. The core legal question was whether the General Manager (HRA) of Pakistan Telecommunication Company Limited (PTCL) possessed the requisite jurisdiction and authorization to issue a show-cause notice and charge-sheet to an officer in Grade BPS-18, given an amendment to Paragraph 7.01 of the PTCL Service Regulations, 1996, enacted via a Board of Directors resolution. The High Court held that the Board resolution amending the service regulations came into force on the date it was passed rather than the date it was communicated internally, and that under the amended regulations, the General Manager (HRA) was duly competent to issue and communicate the disciplinary notices. Consequently, the High Court set aside the impugned judgment and decree, ruling on the competency issue in favor of PTCL and remanding the matter back to the trial court to decide the remaining settled issues afresh.

  Questions settled

  • Does a Board of Directors resolution amending service regulations come into effect from the date of its passage or the date of its internal communication?
  • Whether the General Manager (HRA) is competent to issue and communicate show-cause notices and charge-sheets under the amended Pakistan Telecommunication Limited Service Regulations, 1996?
  • Can an appellate court set aside a trial court judgment and remand the case for a fresh decision on remaining issues when the foundational finding on officer competency is reversed?
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• Pakistan Telecommunication Authority vs Pakistan Telecommunication2024 IHC 278 · Islamabad High Court · 2024-12-16Read full judgment →
• Pakistan Telecommunication Authority vs Federation of Pakistan & others2024 SHC 946 · Sindh High Court · 2024-09-18Read full judgment →
• Pakistan Telecommunication Authority through Chairman vs Pakistan2024 YLR 929 · Islamabad High Court · 2024-01-05Read full judgment →
• Pakistan Tehreek-i-Insaf, through its authorized person and others. vs Election Commission of Pakistan, through Special Secretary, Islamabad and others2024 SCP 356, 2025 SCMR 279 · Supreme Court of Pakistan · 2024-10-11
  adjournmentreview petitionlegal representationcase managementSupreme Court practice
  Summary & questions settled

  This matter concerns a review petition filed against the short order and detailed reasons of the Supreme Court of Pakistan issued in January 2024. The primary legal question addressed by the Court was whether a request for adjournment based on a counsel's personal family engagement, submitted by an Advocate-on-Record, constitutes sufficient grounds for delaying proceedings, particularly when multiple other counsel are available to represent the petitioners. The Court held that the mere filing of an adjournment application does not automatically entitle a party to a postponement. Emphasizing the availability of other counsel and the legislative change introduced by Section 6 of the Supreme Court (Practice and Procedure) Act, 2023, which now permits the engagement of different counsel in review petitions, the Court declined the request for adjournment. However, as an indulgence in the interest of justice, the Court granted a final adjournment, explicitly warning that no further requests would be entertained and mandating that the case proceed on the next scheduled date.

  Questions settled

  • Does the filing of an adjournment application by an Advocate-on-Record automatically entitle a party to a postponement of proceedings?
  • Does Section 6 of the Supreme Court (Practice and Procedure) Act, 2023 allow for the engagement of different counsel in a review petition?
  • Can a court deny an adjournment request when multiple other counsel are available to represent the petitioner?
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• Pakistan Tehreek-e-l nsaaf (PTl) Through its authorized person and others2024 PHC 1 · Peshawar High CourtRead full judgment →
• Pakistan Railway, etc vs Abdul Rasheed, etc2024 LHC 5745, 2025 PLC 106 · Lahore High Court · 2024-12-12
  regularization of serviceworkmandaily wagersPakistan RailwaysLabour Court jurisdictioncivil servantinterim injunctionStanding Orders Ordinanceconcurrent findings of factconstitutional petition
  Summary & questions settled

  This constitutional petition was filed by Pakistan Railways challenging the concurrent judgments of the Punjab Labour Court and the Punjab Labour Appellate Tribunal, which had accepted the grievance petition of respondents No. 1 and 2, directing their regularization in service. The petitioners primarily argued that the respondents were governed by service tribunal jurisdiction, worked on Ministry of Defence Lines, and were dis-entitled to regularization because their services had already been dispensed with prior to the final decision. Dismissing the petition, the Lahore High Court held that daily wage and work-charge employees of Pakistan Railways do not fall within the definition of 'civil servant' under the Civil Servants Act, 1973, and instead qualify as workmen in an industrial establishment, conferring valid jurisdiction upon the Labour Court. The Court further ruled that terminating the employees' services during the subsistence of interim injunctive orders and while working against permanent posts without following the procedure under Standing Order 12 was unlawful and could not obstruct their regularization. Concurrent findings of fact were maintained.

  Questions settled

  • Whether daily wage or work-charge employees of Pakistan Railways qualify as civil servants so as to oust the jurisdiction of the Labour Court under the Industrial Relations Ordinance?
  • Can an employer rely on the termination of an employee executed during the subsistence of an interim injunctive order to deny them the benefit of regularization?
  • Whether daily wage employees serving against permanent posts for an extended duration can have their services dispensed with without complying with Standing Order 12 of the Industrial and Commercial Employment (Standing Orders) Ordinance, 1968?
  • Can concurrent findings of fact recorded by labour fora be interfered with by the High Court under Article 199 of the Constitution in the absence of perversity or arbitrariness?
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• Pakistan Poverty Alleviation Fund vs Commissioner Company Law, SECP2024 CLD 1118 · Securities and Exchange Commission of Pakistan · 2024-01-22Read full judgment →
• Pakistan Poultry Association vs Regulator of Trade Organizations and another2024 IHC 60, 2024 CLD 1266 · Islamabad High Court · 2024-04-02Read full judgment →
• Pakistan Post office Employees Cooperative Housing Society vs Government of Sindh & others2024 SHC 612 · Sindh High Court · 2024-05-31Read full judgment →
• Pakistan Pharmaceutical Manufacturers' Association, Pakistan Chemists &2024 SHC 892, 2025 CLC 1 · Sindh High Court · 2024-08-22Read full judgment →
• Pakistan Medical Commission vs Province of Sindh and others2024 CLC 53 · Sindh High Court · 2022-03-24Read full judgment →
• Pakistan International Airlines Corporation Limited vs Full Bench, NIRC and others2024 PLC 253 · Islamabad High Court · 2024-06-10
  permanent workmancontractual employmentlabor lawreinstatementindustrial relationssham contracttermination of serviceburden of proof
  Summary & questions settled

  This writ petition challenged concurrent orders of the National Industrial Relations Commission (NIRC) reinstating a baggage attendant, originally hired through a contractor, as a permanent employee of Pakistan International Airlines Corporation (PIAC). The core legal question was whether a worker engaged through a third-party contractor at an establishment for over twelve years could be deemed a permanent employee of the principal employer and entitled to the protections of the West-Pakistan Industrial and Commercial (Standing Orders) Ordinance, 1968. The Court dismissed the petition, holding that the worker, having served continuously for over nine months in a role of a permanent nature, attained the status of a permanent workman. The Court affirmed that the "control" and "integration" tests determine employment status, not merely the existence of a contract with a third party. It held that outsourcing permanent functions to contractors to circumvent labor laws constitutes a sham. Consequently, the employer’s failure to follow mandatory inquiry procedures under the 1968 Ordinance before termination rendered the dismissal illegal, upholding the reinstatement order.

  Questions settled

  • Can a worker engaged through a third-party contractor be deemed a permanent employee of the principal establishment?
  • Does the nature of work performed, rather than the appointment letter, determine the status of a permanent workman under the West-Pakistan Industrial and Commercial (Standing Orders) Ordinance, 1968?
  • Is an employer required to follow the inquiry procedure under Standing Order 15 of the West-Pakistan Industrial and Commercial (Standing Orders) Ordinance, 1968, when terminating a contract worker who has attained permanent status?
  • Does the outsourcing of permanent functions to contractors constitute a sham if used to deprive employees of their legal rights?
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• Pakistan International Airlines Corporation Limited through its Managing2024 IHC 172, 2025 PLD Islamabad 116 · Islamabad High Court · 2024-09-11Read full judgment →
• Pakistan International Airlines Corporat vs Collector of Customs2024 SHC 1036 · Sindh High Court · 2024-10-07Read full judgment →
• Pakistan Housing Authority Foundation through Managing Director vs Federation of Pakistan through President and 2 others2024 CLC 1407 · Islamabad High Court · 2022-09-16Read full judgment →
• Pakistan Engineering Council through its Registrar vs Higher Education2024 IHC 230, 2025 CLC 589 · Islamabad High Court · 2024-11-19
  Higher Education CommissionPakistan Engineering Councildegree equivalencepromotion criteriaemployment policyB.Sc. EngineeringB-Tech (Honors)statutory authority
  Summary & questions settled

  The petitioner challenged a notification issued by the Higher Education Commission ("HEC") declaring B.Sc. Engineering and B-Tech (Honors) degrees at par for grade determination and promotion. The core legal question concerned the statutory authority of HEC and the Pakistan Engineering Council ("PEC") regarding the determination of criteria for employment and promotion. The Islamabad High Court held that neither HEC nor PEC possesses the statutory mandate to dictate employment or promotion criteria to employers, as recruitment and promotion policies fall exclusively within the domain of the relevant employer. While HEC may determine academic equivalence and PEC regulates the engineering profession and professional engineering work, neither regulator can mandate interchangeability of degrees for employment purposes. The court laid down the principle that academic equivalence does not imply interchangeability of skills for recruitment, and employers retain full autonomy to determine qualification criteria for jobs and promotions.

  Questions settled

  • Does the Higher Education Commission have the statutory authority to dictate qualification criteria for recruitment and promotion to employers?
  • Can the Pakistan Engineering Council determine whether a particular post in public or private employment must be filled by a professional engineer?
  • Does academic equivalence of degrees granted by the Higher Education Commission render those qualifications automatically interchangeable for employment and promotion?
  • Is the determination of criteria for employment and promotion a policy matter falling exclusively within the domain of the employer?
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• Pakistan Engineering Council through its Chairman & others vs Taj2024 SCP 130, 2024 SCMR 956, 2024 PLC (C.S.) 746, 2024 PLJ SC 659 · Supreme Court of Pakistan · 2024-02-15
  engineering equivalencePakistan Engineering CouncilHigher Education Commissionacademic autonomyjudicial reviewB.Tech degreeprofessional registrationrecruitment criteria
  Summary & questions settled

  These civil appeals concern the equivalence of B.Tech. (Hons.) degrees with B.Sc. Engineering degrees and the respective jurisdictions of the Pakistan Engineering Council (PEC) and the Higher Education Commission (HEC). The core legal question was whether B.Tech. (Hons.) is equivalent to B.Sc. Engineering and whether courts possess the authority to interfere in university admission policies or employer-prescribed recruitment criteria. The Supreme Court held that B.Tech. (Hons.) and B.Sc. Engineering are distinct disciplines—the former being skill-oriented and the latter research-oriented—and are not equivalent. The Court affirmed that the PEC holds the exclusive mandate to determine engineering qualification equivalence for professional registration, while the HEC oversees general higher education. Furthermore, the Court ruled that educational institutions maintain autonomy over admission policies, and employers retain the discretion to set specific qualification requirements for recruitment and promotion. Consequently, judicial interference in these administrative and academic domains is unwarranted absent a clear violation of law. The Court emphasized that the establishment of the National Technology Council further confirms the separation of these two distinct professional streams.

  Questions settled

  • Is a B.Tech. (Hons.) degree equivalent to a B.Sc. Engineering degree for the purposes of professional engineering registration?
  • Does the Pakistan Engineering Council have the exclusive authority to determine the equivalence of engineering qualifications?
  • Can courts interfere in the admission policies of educational institutions or the recruitment criteria set by employers?
  • Does the Higher Education Commission have the power to override the Pakistan Engineering Council regarding the accreditation of engineering degrees?
  Read full judgment →
• Pakistan Broadcasters Association through Executive Director vs Federation of Pakistan through Secretary, Ministry of Information, Islamabad and others2024 CLC 871 · Islamabad High Court · 2023-12-05Read full judgment →
• Pakistan B. Tech Honors Engineers Association, Islamabad vs Federation of Pakistan through Secretary M_O. Law of Justice and others2024 PLJ Islamabad 117 · Islamabad High CourtRead full judgment →
• Pakistan B. Tech Honors Engineers Association through Muhammad2024 CLC 857 · Islamabad High Court · 2024-01-19Read full judgment →
• Pak-Telecom Mobile Limited through Head of Legal Affairs vs Messrs2024 CLC 1340 · Islamabad High Court · 2024-04-16Read full judgment →
• Pak Gulf Construction (Private) Limited vs Govt. of Punjab etc2024 LHC 3253, 2025 PTD 255 · Lahore High Court · 2024-06-13Read full judgment →
• Pak Gulf Construction (Private) Limited vs Godwin Austen Johnson2024 IHC 200, 2024 CLD 1451 · Islamabad High Court · 2024-04-25Read full judgment →
• Packages Limited vs Punjab Labour Appellate Tribunal & another2024 LHC 4875, 2025 PLC 1, 2025 PLJ Lahore 289 · Lahore High Court · 2024-09-30
  workmanmisconductdismissal from serviceindustrial relationsproportionality of penaltygrievance petitionlabour appellate tribunal
  Summary & questions settled

  This constitutional petition arises from a service dispute wherein the petitioner-company challenged the judgment of the Punjab Labour Appellate Tribunal, which had set aside the dismissal of respondent No.2 and accepted his grievance petition. The core legal questions involved were whether an employee performing manual duties holding the designation of Operator qualifies as a 'workman' under relevant labour laws, and whether raising legitimate operational grievances during a management meeting constitutes 'misconduct' under the law. The Lahore High Court held that respondent No.2 was indeed a workman, both by virtue of his actual duties and the employer's own admissions during the proceedings, and that voicing operational difficulties does not amount to wilful insubordination or misconduct. The court affirmed that the penalty of dismissal was disproportionate and unjustified given his unblemished service record of twenty-three years and the discriminatory nature of the disciplinary action. The key principles laid down include that the nature of duties performed determines a worker's status regardless of designation, that disciplinary penalties must strictly commensurate with the gravity of established allegations, and that an employer cannot approbate and reprobate regarding a worker's statutory status.

  Questions settled

  • Does an employee designated as an operator who performs manual duties qualify as a workman under the Punjab Industrial Relations Act, 2010?
  • Whether raising operational problems or grievances during a meeting called by management constitutes misconduct under Standing Order 15 of the Industrial and Commercial Employment (Standing Orders) Ordinance, 1968?
  • Can an employer approbate and reprobate by treating an employee as a workman during disciplinary proceedings while denying such status in subsequent judicial forums?
  • Is the quantum of penalty imposed by a competent authority open to judicial review if it is disproportionate to the gravity of the established allegations?
  Read full judgment →
• P&T Coop Housing Society vs Sect: Coop Department and Others2024 SHC 296 · Sindh High Court · 2024-04-08Read full judgment →
• Orient Energy System Pvt Ltd. vs Asst: Commissioner Ir and Others2024 SHC 382, 2025 PTD 431 · Sindh High Court · 2024-05-02Read full judgment →
• Oracle Systems Pakistan (Private) Limited. vs Pakistan Through The Secretary Revenue & Exofficio Chairman Federal Board Of Revenue, Islamabad, Etc2024 IHC 78, 2024 PTD 105 · Islamabad High Court · 2023-08-16
  coercive tax recoveryFederal Excise Dutyattachment of bank accountsAppellate Tribunal Inland Revenuestay order violationnatural justiceconstitutional petition
  Summary & questions settled

  This constitutional petition was filed by Oracle Systems Pakistan (Private) Limited challenging a recovery notice issued under Section 14 of the Federal Excise Act, 2005 and Rule 60 of the Federal Excise Rules, 2005, through which a substantial sum was forcibly recovered from the petitioner's bank account while its appeal was pending before the Appellate Tribunal Inland Revenue. The core legal questions involved whether the recovery notice violated a subsisting stay order of the High Court, whether prior notice and thirty days are mandatory before initiating recovery under Rule 71 of the Sales Tax Rules, 2006, and whether coercive tax recovery should be restrained until adjudication by an independent forum. The Islamabad High Court held that the recovery was executed in violation of the Court's stay order, that prior notice and a thirty-day window are mandatory before initiating coercive recovery, and that tax authorities must ordinarily await the decision of the Appellate Tribunal Inland Revenue before resorting to coercive recovery of disputed liability. Consequently, the petition was allowed, the recovery was declared unlawful, and respondents were directed to refund the recovered amount.

  Questions settled

  • Whether the initiation of coercive tax recovery before the adjudication of an appeal by an independent forum such as the Appellate Tribunal Inland Revenue is lawful?
  • Is it mandatory for tax authorities to serve a prior notice and allow thirty days for payment after the adjudication of government dues before attaching bank accounts under Rule 71 of the Sales Tax Rules, 2006?
  • Does the availability of an alternate remedy like a tax refund preclude the High Court from exercising writ jurisdiction under Article 199 of the Constitution when property is taken without due process?
  • When does the computation of time for a stay order granted by the High Court pending an administrative appeal legally commence?
  Read full judgment →
• Omer Khalid Ali vs Federation of Pakistan through President of Pakistan2024 PLC (C.S.) 995 · Sindh High Court · 2024-02-13
  quo warrantoState Owned Enterprisesconflict of interestcaretaker governmentjudicial reviewpublic officedisqualification
  Summary & questions settled

  This petition sought a writ of quo warranto challenging the appointment of the respondent as Chairperson of Sui Southern Gas Company Limited (SSGCL) while simultaneously holding the office of Caretaker Finance Minister. The petitioner contended that this dual role constituted a conflict of interest and violated the State Owned Enterprises (Governance and Operations) Act, 2023, and the Companies Act, 2017, alleging the respondent was ineligible and held the position without lawful authority. The core legal question was whether the respondent suffered from any statutory disqualification or conflict of interest warranting judicial intervention. The Court dismissed the petition in limine, holding that the petitioner failed to establish any inherent disqualification under the governing Act. The Court clarified that a Caretaker Minister is not a member of the Majlis-e-Shoora and that the petitioner provided only unsubstantiated allegations rather than evidence of illegality or cronyism. The principle laid down is that judicial review of administrative appointments is confined to determining the legality of the decision-making process, and courts will not interfere absent proof of specific statutory disqualification or abuse of power.

  Questions settled

  • Can a writ of quo warranto be maintained by a person who is not an aggrieved person?
  • Does the appointment of a Caretaker Finance Minister as a Chairperson of a State Owned Enterprise violate the State Owned Enterprises (Governance and Operations) Act, 2023?
  • Is a Caretaker Minister considered a member of the Majlis-e-Shoora for the purpose of disqualification from holding public office?
  • On what grounds can a court exercise judicial review over administrative appointments in State Owned Enterprises?
  Read full judgment →
• Oil and Gas Development Company Limited vs Ex-parte2024 CLC 988 · Islamabad High Court · 2024-03-21Read full judgment →
• Oil & Gas Development Company Ltd vs M/s. Shah Latif CNG and others2024 SHC 626, 2024 CLC 1846 · Sindh High Court · 2024-05-31Read full judgment →
• Nuaman Tarique Jat vs The State & others2024 SHC 452 · Sindh High Court · 2024-05-10
  registration of FIRJustice of Peacecognizable offencequashing of orderduty of SHO
  Summary & questions settled

  This criminal miscellaneous application under section 561-A of the Code of Criminal Procedure 1898 was filed by the applicant assailing the order of the Additional Sessions Judge/Ex-Officio Justice of Peace, whereby his application seeking a direction for the registration of an FIR was dismissed on the ground that no robbery was committed and a civil suit filed by the applicant's father had been rejected. The core legal question was whether the Justice of Peace and the SHO could refuse to record an FIR for a cognizable offence based on the rejection of a civil plaint or the perceived falsity of the allegations. The Sindh High Court held that the SHO has no authority to refuse to record the statement of a complainant under section 154 of the Code of Criminal Procedure 1898 regarding a cognizable offence irrespective of its authenticity, and that the remedy against false information is penal action under section 182 of the Pakistan Penal Code 1860. The court disposed of the application by directing the Senior Superintendent of Police to ascertain the factual position and take appropriate action.

  Questions settled

  • Does an SHO have the authority to refuse to record the statement of a complainant under section 154 of the Code of Criminal Procedure 1898 on the ground of authenticity or falsity?
  • Can the rejection of a civil plaint serve as a valid ground for a Justice of Peace to refuse a direction for the registration of an FIR for a cognizable offence?
  • What is the statutory check against the lodging of false First Information Reports under criminal law?
  Read full judgment →
• Nooruddin Feerasta & others vs Lahore Development Authority (LDA) &2024 LHC 812, 2024 PLJ Lahore 284, 2025 CLC 121, 2025 CLD 184 · Lahore High Court · 2024-02-29Read full judgment →
• Nooruddin & others vs M/s Sindh Industrial Trading Estate & others2024 SHC 12 · Sindh High Court · 2024-01-11Read full judgment →
• Noora (deceased) through L.Rs vs Province of Punjab, etc2024 LHC 5203, 2025 PLJ Lahore 177, 2025 YLR 566 · Lahore High Court · 2024-10-30Read full judgment →
• Noor ul Haq vs Government of Balochistan through Chief Secretary Civil2024 MLD 105 · Balochistan High Court · 2023-05-26Read full judgment →
• Noor Muhammad, Faiz Muhammad vs The State2024 SHC 320 · Sindh High Court · 2024-04-01
  narcotics possessionconscious possessionchain of custodycriminal appealreasonable doubtacquittalControl of Narcotic Substances Act
  Summary & questions settled

  This criminal appeal challenges the conviction of two appellants for the possession of narcotic drugs under the Control of Narcotic Substances Act 1997. The appellants were sentenced to ten years of imprisonment after narcotics were allegedly recovered from a vehicle they occupied. The core legal questions addressed were whether the appellants had conscious possession of the narcotics and whether the prosecution successfully established an unbroken chain of custody for the recovered evidence. The court held that the prosecution failed to prove conscious possession, particularly regarding the passenger, as the narcotics were concealed in an opaque container, and no evidence established the appellants' knowledge of the contraband. Additionally, the court found the chain of custody fatally flawed due to the failure to examine the malkhana in-charge and the lack of documentation regarding the transit of the narcotics. Consequently, the court acquitted the appellants, emphasizing that criminal cases must be proven beyond reasonable doubt and that the benefit of any doubt must accrue to the accused. The judgment reinforces the principle that conscious knowledge is a prerequisite for convicting vehicle occupants of narcotics possession.

  Questions settled

  • Is conscious knowledge of the presence of narcotics a prerequisite for convicting a passenger in a vehicle?
  • Does a failure to examine the malkhana in-charge regarding the transit of recovered narcotics break the chain of custody?
  • Can a conviction for narcotics possession be sustained when the prosecution fails to establish the chain of custody?
  Read full judgment →
• Noor Muhammad vs The State2024 MLD 472 · Peshawar High Court · 2022-11-14Read full judgment →
• Noor Muhammad through attorney and others vs Allah Warayo and others2024 MLD 617 · Sindh High Court · 2018-03-16Read full judgment →
• Noor Muhammad and others vs Jamal Khan and others2024 PLJ Quetta 73 · Balochistan High Court · 2023-10-13Read full judgment →
• Noor Khan vs The State, etc2024 LHC 3500, PLJ 2024 Cr.C. 1202, 2025 YLR 62 · Lahore High Court · 2024-06-27
  Illegal Dispossession Actpreliminary inquirypolice investigationnon-cognizable offenceproperty grabbingcriminal revisionlocal inquiry
  Summary & questions settled

  This revision petition challenged the dismissal of a complaint filed under the Illegal Dispossession Act, 2005, by the Additional Sessions Judge, Chiniot. The core legal question concerned the procedural requirements for courts when handling complaints of illegal dispossession. The High Court held that the lower court erred by dismissing the complaint based solely on a revenue report without conducting a proper inquiry or investigation as mandated by the Act. The court clarified that under Section 5 of the Illegal Dispossession Act, 2005, courts are empowered to direct police investigations or local inquiries by revenue officers or magistrates to ascertain the truth of allegations. The ratio established is that trial courts must not rely merely on cursory statements or uncertified documents but must actively utilize the statutory mechanisms for inquiry and investigation to determine the validity of a complaint. Consequently, the impugned order was set aside, and the complaint was remanded for proceedings in accordance with the law, emphasizing that inquiry and investigation are not mutually exclusive and may be employed sequentially to ensure justice.

  Questions settled

  • Are inquiry and investigation mutually exclusive proceedings under the Illegal Dispossession Act, 2005?
  • Can a court direct a police investigation for a non-cognizable offence under the Illegal Dispossession Act, 2005?
  • Is a trial court required to conduct an inquiry or investigation before dismissing a complaint under the Illegal Dispossession Act, 2005?
  • Does the report of a revenue officer or magistrate in a local inquiry constitute evidence in proceedings under the Illegal Dispossession Act, 2005?
  Read full judgment →
• Noor Khan & 11 others vs Babar Akbar & 04 others2024 PHC 78, 2024 PLJ Peshawar 86 · Peshawar High Court · 2024-02-02Read full judgment →
• Noor Jan and 5 others vs The State2024 MLD 858 · Balochistan High Court · 2021-12-13
  post-arrest bailtwo versions casefurther inquirycommon intentionvicarious liabilitydelay in FIR
  Summary & questions settled

  This is a post-arrest bail application filed by the applicants seeking bail in FIR No. 28 of 2021 registered under sections 302, 337-H(2), 147, 148, and 149 of the Pakistan Penal Code 1860 at Levies Station Daman Bhaghao District Barkhan. The core legal question revolves around whether the applicants are entitled to post-arrest bail given the existence of cross-versions of the incident, a single firearm injury on the deceased despite generalized allegations against multiple accused, delay in lodging the FIR, and lack of recoveries. The Balochistan High Court accepted the application and granted post-arrest bail to the applicants, holding that the case falls within the ambit of further inquiry under Section 497(2) of the Code of Criminal Procedure 1898. The key principle laid down is that where a criminal case involves cross-versions, generalized allegations of firing resulting in a single injury, and unexplained delays in reporting, reasonable grounds exist for further inquiry into the guilt of the accused, warranting the grant of bail.

  Questions settled

  • Whether post-arrest bail can be granted under Section 497(2) of the Code of Criminal Procedure 1898 in a case involving cross-versions of the same incident?
  • Does a single injury on the deceased, attributed generally to multiple accused persons, attract the provisions of further inquiry for the purpose of bail?
  • Does an inordinate delay in reporting the crime to the authorities create a doubt warranting the concession of post-arrest bail?
  Read full judgment →
• Noor Hussain and 3 others vs Muhammad Latif and 5 others2024 PLJ AJ&K 13 · High Court of Azad Jammu and Kashmir · 2023-08-01Read full judgment →
• Noor Ahmed vs The State2024 SHC 1230 · Sindh High Court · 2024-05-31
  Section 342 statementfair trialremandprosecution lacunaeacquittalbenefit of doubtneutral umpire
  Summary & questions settled

  The appellant challenged his conviction and life sentence for murder under Section 302 of the Pakistan Penal Code 1860, arguing that the trial court failed to put material incriminating evidence to him during his examination under Section 342 of the Code of Criminal Procedure 1898. The core legal question was whether a conviction can be sustained when material evidence is not confronted to the accused during his statement, and whether the appellate court should remand the case to cure this defect. The Court held that evidence not put to an accused during their Section 342 examination cannot be used to sustain a conviction and must be excluded. Furthermore, the Court ruled that remanding the case to re-record the statement would improperly allow the prosecution to fill evidentiary lacunae, violating the accused's right to a fair trial under Article 10-A of the Constitution of Pakistan 1973. Consequently, the conviction was set aside, and the appellant was acquitted, establishing that courts must act as neutral umpires and cannot assist the prosecution in improving its case at the expense of the accused's fundamental rights.

  Questions settled

  • Can a conviction be sustained if material evidence is not put to the accused during their examination under Section 342 of the Code of Criminal Procedure 1898?
  • Should an appellate court remand a case to the trial court to re-record an accused's statement under Section 342 of the Code of Criminal Procedure 1898 to cure evidentiary defects?
  • Does remanding a criminal case to fill prosecution lacunae violate the right to a fair trial under Article 10-A of the Constitution of Pakistan 1973?
  Read full judgment →
• Noman Shahzad vs Ayaz Khadim and 3 others2024 MLD 1793 · High Court of Azad Jammu and Kashmir · 2024-01-29
  pre-arrest bailbail confirmationcancellation of bailprohibitory clausetentative assessmentrevision petition
  Summary & questions settled

  This revision petition is directed against the order dated 20.03.2023 passed by the Additional District Court of Criminal Jurisdiction, Rawalakot, whereby the interim pre-arrest bail of the accused-respondents was confirmed in a case registered under FIR No.306/22. The core legal question concerns the propriety of confirming pre-arrest bail and whether strong grounds exist to interfere with the lower court's discretion. The High Court held that bail matters must be decided on tentative assessment of material collected during investigation, and since the accused were not required for further investigation and their case did not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure, the lower court's order was in accordance with law. The Court laid down the principle that once bail is granted by a competent court, very strong grounds and reasons are required to cancel it, and courts remain slow to undo bail orders at random without establishing illegality, irregularity, or perversity.

  Questions settled

  • Whether pre-arrest bail once confirmed by a competent court can be interfered with in revision without showing any illegality, irregularity, or perversity?
  • Does the case of the accused not falling within the prohibitory clause of Section 497 of the Code of Criminal Procedure justify the confirmation of bail?
  • What grounds are required to cancel a bail already granted to an accused by a court of competent jurisdiction?
  Read full judgment →
• Noman Mansoor alias Nomi and others vs The State and others2024 SCP 194, 2024 PLD Supreme Court 805 · Supreme Court of Pakistan · 2024-05-22
  criminal revisionenhancement of sentenceright to fair trialrevisional jurisdictionmandatory noticeconversion of proceedingsdue process
  Summary & questions settled

  This matter concerns a criminal petition challenging a High Court judgment that converted a complainant's appeal against acquittal into a criminal revision petition, subsequently enhancing the petitioner's sentence from 14 years rigorous imprisonment to life imprisonment. The core legal questions were whether the High Court possesses the authority to convert an appeal against acquittal into a criminal revision, and whether such conversion requires a mandatory notice to the accused under the Code of Criminal Procedure, 1898. The Supreme Court held that while the High Court has the inherent power to convert proceedings to advance justice, it cannot enhance a sentence in revisional jurisdiction without strictly complying with the mandatory notice requirement under Section 439(2) of the Code of Criminal Procedure, 1898. The Court affirmed that the right to be heard is a fundamental constitutional guarantee. Consequently, the High Court's judgment was set aside for failing to issue the required notice, and the matter was remanded for a fresh decision after ensuring the petitioner is afforded the opportunity to defend himself, thereby upholding the principles of fair trial and due process.

  Questions settled

  • Can the High Court convert an appeal against acquittal into a criminal revision petition?
  • Is it mandatory for the High Court to issue a notice to the accused under Section 439(2) of the Code of Criminal Procedure, 1898, before enhancing a sentence in revisional jurisdiction?
  • Does the fact that an accused is already before the court in their own appeal dispense with the requirement of a separate notice under Section 439(2) of the Code of Criminal Procedure, 1898, when the court exercises revisional power to enhance a sentence?
  Read full judgment →
• Noman Ahmed vs The State2024 SHC 950 · Sindh High Court · 2024-09-18
  foreign exchange regulationhundi hawalaquashing of proceedingsacquittal under section 265-Kcognizance of offenceunauthorized foreign exchange dealersearch warrant
  Summary & questions settled

  This criminal miscellaneous application under Section 561-A of the Code of Criminal Procedure 1898 was filed to assail an order passed by the District and Sessions Judge, Karachi South, dismissing the applicant's acquittal application under Section 265-K of the Code of Criminal Procedure 1898 in a case registered under Section 23 of the Foreign Exchange Regulation (Amendment) Act, 2020 read with Section 109 of the Pakistan Penal Code 1860. The core legal questions involved whether the Federal Investigation Agency required a written complaint by an authorized person to initiate cognizance against an unauthorized foreign exchange dealer, and whether the trial court erred in dismissing the Section 265-K acquittal application prior to recording evidence. The Sindh High Court held that under the second proviso to Section 23(3) of the Foreign Exchange Regulation Act 1947 (as amended by the 2020 Act), the requirement of a written complaint by an authorized person is expressly exempted for persons not authorized to deal in foreign exchange. Furthermore, the court held that where there is a probability of conviction, an acquittal application under Section 265-K should not be entertained prematurely without recording evidence. The criminal miscellaneous application was accordingly dismissed.

  Questions settled

  • Whether a written complaint by an authorized person is required under Section 23(3) of the Foreign Exchange Regulation Act 1947 for prosecuting a person not authorized to deal in foreign exchange?
  • Can an application for acquittal under Section 265-K of the Code of Criminal Procedure 1898 be allowed before recording evidence when there is a probability of conviction?
  • Does the failure to obtain a search warrant under Section 19(3) of the Foreign Exchange Regulation Act 1947 vitiate trial proceedings prior to the recording of evidence?
  Read full judgment →
• Nisar Ullah vs Farman Ali2024 PHC 212, 2024 YLR 2779 · Peshawar High Court · 2024-06-05Read full judgment →
• Nisar Ahmed Ghori and others vs The State2024 SHC 656 · Sindh High Court
  qatl-i-amdeyewitness testimonyappreciation of evidencemedical evidencerecovery of weaponsminor discrepanciescriminal appeal
  Summary & questions settled

  This appeal challenged the conviction and life imprisonment of the appellants for the murder of the complainant's brother, arising from a dispute over a common street. The core legal questions concerned the reliability of eyewitness testimony, the impact of alleged medical evidence discrepancies, and the validity of recoveries of incriminating weapons. The appellants argued that the prosecution's case was inconsistent, that medical evidence contradicted the eyewitness accounts, and that the recovery of weapons was manipulated. The Court held that the eyewitness testimony, including that of an injured complainant, was consistent, confidence-inspiring, and withstood rigorous cross-examination. It further ruled that minor discrepancies in evidence, typical of the passage of time, do not undermine the prosecution's case. The Court dismissed the argument that the medical officer's belated, unsubstantiated opinion regarding 'self-suffered' injuries or the type of weapon used could impeach the otherwise credible eyewitness account. The principle laid down is that recovery of weapons serves as supporting evidence and cannot override credible eyewitness testimony, and minor inconsistencies in evidence do not warrant acquittal when the core prosecution narrative remains intact.

  Questions settled

  • Can minor discrepancies in witness testimony undermine the prosecution's case if the core narrative remains consistent?
  • Does the recovery of incriminating weapons serve as primary or supporting evidence in a murder trial?
  • Can a medical officer's unsubstantiated opinion in cross-examination, contradicting the initial medical report, impeach the credibility of an injured witness?
  • Is it permissible to convert a conviction under Section 302(b) to Section 302(c) of the Pakistan Penal Code 1860 based on alleged minor discrepancies in evidence?
  Read full judgment →
• Nisar Ahmad vs Inspector General of Police, etc2024 LHC 4861, 2025 PLC (C.S.) 450, 2025 PLJ Lahore 316 · Lahore High Court · 2024-11-05
  regularization of contract employeesdirect recruitmentHead Constablepolice service rulesconstitutional petitionscrutiny committee
  Summary & questions settled

  The petitioner, an ex-Army man, challenged the rejection of his request for reinstatement and regularization of his service as a Head Constable in the Punjab Constabulary, which followed the termination of his contract and subsequent litigation. The core legal question was whether a contract employee directly appointed as a Head Constable is eligible for regularization under the government policy and relevant police laws, particularly when direct recruitment to that rank is not sanctioned. The Lahore High Court dismissed the petition, holding that under the Police Order, 2002 and the Police Rules, 1934, direct recruitment is not permissible for the post of Head Constable, which is filled solely by promotion. The Court established that executive appointments made contrary to statutory recruitment rules confer no vested right to regularization, and a Scrutiny Committee is fully competent to verify whether initial contract appointments complied with service rules.

  Questions settled

  • Whether direct recruitment is permissible against the post of Head Constable under the Police Order, 2002 and the Police Rules, 1934?
  • Can a contract employee directly appointed against a post not meant for direct recruitment claim regularization under the Government's contract regularization policy?
  • Whether the extraordinary constitutional jurisdiction under Article 199 of the Constitution of Pakistan, 1973 can be invoked to regularize an appointment made in violation of applicable service rules?
  • Does a Scrutiny Committee have the authority to verify whether initial contract appointments were made in accordance with prescribed service rules regarding age limit, qualification, and experience?
  Read full judgment →
• Nina Industries Limited vs Bhanero Textile Mills2024 SHC 42, 2024 PLJ Karachi 50 · Sindh High Court · 2024-01-24Read full judgment →
• Nihal Khan and others vs Province of Sindh and others2024 SHC 1380 · Sindh High Court · 2024-12-20Read full judgment →
• Niaz Muhammad vs Muhammad Naveed Khan & others2024 PHC 244, 2025 PLD Peshawar 21, 2025 PLJ Peshawar 25 · Peshawar High Court · 2024-06-12Read full judgment →
• Niaz Hussain vs StatePLJ 2024 Cr.C. 306 · Lahore High Court · 2023-09-11
  criminal appealmurderchance witnessesunnatural conductnocturnal identificationrecovery of weaponbenefit of doubtacquittal
  Summary & questions settled

  This criminal appeal was filed by the appellant challenging his conviction and sentence of life imprisonment under Section 302(b) of the Pakistan Penal Code 1860, along with compensation under Section 544-A of the Code of Criminal Procedure 1898, awarded by the trial court for committing murder. The primary legal questions before the High Court were whether the prosecution established the guilt of the appellant beyond reasonable doubt on the basis of chance eye-witnesses, uncorroborated nocturnal identification, delayed recovery of the crime weapon, and an unsubstantiated motive. The High Court accepted the appeal and acquitted the appellant, holding that the prosecution witnesses were chance witnesses who failed to provide plausible reasons for their presence at a deserted crime spot at night. Furthermore, their unnatural conduct in failing to intervene or apprehend a single assailant armed only with a knife rendered their testimony unreliable. The Court additionally found the identification in darkness doubtful, the recovery of the blood-stained knife suspect due to unexplained delay, and the alleged motive unproven.

  Questions settled

  • Whether the testimony of a chance witness can be relied upon without independent proof establishing a valid reason for their presence at the crime scene?
  • Does the failure of multiple adult witnesses to intervene or apprehend a single assailant armed with a non-firearm weapon render their conduct unnatural and their presence doubtful?
  • Can identification of an accused in nocturnal darkness based on motorcycle lights be accepted when the motorcycle is neither described in the FIR nor seized by the police?
  • Whether recovery of a blood-stained weapon from the house of an accused several days after the incident is reliable where ample opportunity existed to clean it?
  Read full judgment →
• Niaz and others vs The State2024 PCRLJ 1473 · Balochistan High Court · 2023-10-23
  free fightcriminal appealbenefit of doubtcross-FIRvicarious liabilitycommon objectacquittalocular evidence
  Summary & questions settled

  This matter concerns two consolidated criminal appeals against convictions recorded by the Trial Court in cross-FIR cases arising from a single occurrence at Manjhoo Shori Bazar, involving a violent altercation between two groups. The core legal question was whether the accused could be convicted for murder and rioting in a 'free fight' scenario where neither party established the specific role of the accused, and where both sides presented conflicting versions while concealing their own culpability. The Court held that in a case of a free fight, there is no common object, and individual liability must be established based on specific acts. Finding that the prosecution failed to attribute specific fatal injuries to any individual accused and that the evidence was heavily mixed with falsehoods from both sides, the Court determined that the prosecution failed to prove its case beyond reasonable doubt. The key principle laid down is that in a free fight, every accused is liable only for the specific part played by them, and where the truth cannot be discerned from a heap of falsehoods, the benefit of the doubt must be extended to the accused.

  Questions settled

  • Can an accused be convicted for rioting under Section 148 read with Section 149 of the Pakistan Penal Code 1860 in a case of a free fight?
  • Is medical evidence sufficient to identify an accused or establish their specific role in a criminal occurrence?
  • Does a free fight scenario negate the existence of a common object among the accused?
  • Should an accused be acquitted when both parties to a conflict have attempted to hide the truth and minimize their own roles?
  Read full judgment →
• Niaz Ahmed S/O Sher Jang & Ors vs Muhammad Aijaz & Ors2024 SHC 160 · Sindh High Court · 2024-02-23
  Illegal Dispossession Actrestoration of possessioncivil litigationland grabbersregistered gift deedcriminal revisionquashing of proceedings
  Summary & questions settled

  This common order disposes of two criminal revision applications challenging orders passed by the Additional Sessions Judge, Karachi (East) in an illegal dispossession complaint. The core legal questions involved the maintainability of proceedings under the Illegal Dispossession Act, 2005 against family members and co-heirs, the effect of pending civil litigation on such criminal proceedings, and the legality of interim orders restoring possession under Sections 7 and 8 of the Act. The Sindh High Court held that the Illegal Dispossession Act applies to anyone who illegally dispossesses a lawful owner or occupier, regardless of whether the offender belongs to a professional land-grabbing group or is a family member. The court further held that the pendency of civil litigation does not bar criminal proceedings under the Act. The revision applications were accordingly dismissed, upholding the trial court's orders for the restoration of possession and the dismissal of the acquittal application.

  Questions settled

  • Can proceedings under the Illegal Dispossession Act, 2005 be initiated against family members or co-heirs, or are they restricted to professional land grabbers?
  • Does the pendency of civil litigation between the parties bar criminal proceedings under the Illegal Dispossession Act, 2005?
  • Whether a trial court can order the interim restoration of possession under the Illegal Dispossession Act, 2005 pending trial?
  • Is an accused entitled to acquittal under Section 265-K Cr.P.C. merely on the assertion that the disputed property is inherited?
  Read full judgment →
• Niaz Ahmed Mirani vs The State2024 YLR 726 · Sindh High Court · 2022-10-16Read full judgment →
• Niaz Ahmed & another vs Aijaz Ahmed & Others2024 SCP 243, 2024 PLD Supreme Court 1152 · Supreme Court of Pakistan · 2024-07-15
  illegal dispossessioninterim reliefeviction and mode of recoverypower of court to acquit at any stagecivil disputeland grabbers
  Summary & questions settled

  The petitioners challenged a judgment of the Sindh High Court dismissing their criminal revision applications against orders passed under the Illegal Dispossession Act, 2005 and the dismissal of their acquittal application under Section 265-K of the Code of Criminal Procedure, 1898. The core legal questions involved the scope and applicability of the Illegal Dispossession Act, 2005 to family members and pending civil disputes, the conditions for granting interim relief under Section 7 of the said Act, and the proper exercise of powers for acquittal under Section 265-K of the Code of Criminal Procedure, 1898. The Supreme Court of Pakistan held that the Illegal Dispossession Act, 2005 applies broadly to any illegal occupant and is not restricted to land grabbers or Qabza groups, that pending civil litigation does not bar criminal proceedings under the Act, that interim restitution under Section 7 requires a prima facie finding of unlawful possession during trial after charges are framed, and that acquittal under Section 265-K is unwarranted where a prima facie case exists. The petitions were consequently dismissed.

  Questions settled

  • Whether the scope of the Illegal Dispossession Act, 2005 is restricted solely to professional land grabbers and Qabza groups or extends to family members and other illegal occupants?
  • Does the pendency of civil litigation between the parties bar the initiation or continuation of criminal proceedings under the Illegal Dispossession Act, 2005?
  • What are the precise conditions and legal thresholds required for granting interim relief under Section 7 of the Illegal Dispossession Act, 2005 during the course of a trial?
  • At what stage of a criminal proceeding does a trial legally commence for the purposes of invoking Section 7 of the Illegal Dispossession Act, 2005?
  • What constitutes extraordinary circumstances warranting the acquittal of an accused under Section 265-K of the Code of Criminal Procedure, 1898?
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• Niagara Mills (Pvt) Limited and others vs Punjab Cooperative Board for Liquidation (PCBL) and others2024 LHC 3953, 2025 PLD Lahore 79, 2025 PLJ Lahore 371 · Lahore High Court · 2024-09-20Read full judgment →
• New Metallurgy Hi-Tech Group Co. Ltd. vs Siddiqsons Tin Plate Limited2024 SHC 44, 2024 PLJ Karachi 59 · Sindh High Court · 2024-01-26Read full judgment →
• Netherlands Financierings Maatschappij Voor Ontwikkelinglanden N. V.2024 PLD Lahore 315, 2024 CLD 685 · Lahore High Court · 2022-12-20
  company winding upcorporate mediationalternative dispute resolutionEarly Neutral Evaluationforeign investment protectionsettlement agreementCompanies Act 2017
  Summary & questions settled

  This matter arose from a winding-up petition filed in 1989 by a Dutch bilateral financial institution against a domestic company following the non-payment of a foreign currency loan executed in 1982. A winding-up order was passed in 2003, but execution stalled for decades without repayment. The core legal issue before the Lahore High Court was whether the court could initiate and facilitate Early Neutral Evaluation and mediation under company laws to resolve long-standing corporate debt disputes instead of proceeding with liquidating the company. The High Court disposed of the petition in terms of a mutually executed settlement agreement after the parties successfully resolved their debt claims through court-directed mediation supervised by the Securities and Exchange Commission of Pakistan. The court held that winding up is a remedy of last resort and established that Company Judges possess the authority under Sections 6, 276, and 277 of the Companies Act, 2017 to initiate mediation and alternate dispute resolution, thereby protecting corporate viability, safeguarding investor confidence, and ensuring expeditious resolution of commercial disputes.

  Questions settled

  • Whether the court may initiate mediation amongst parties to a lis for the resolution of a corporate dispute?
  • Is winding up a company considered a remedy of last resort when corporate debt disputes can be resolved through alternate dispute resolution?
  • Can the Company Judge invoke Sections 276 and 277 of the Companies Act, 2017 to initiate Early Neutral Evaluation and mediation?
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• Nestle Pakistan Limited etc vs The Province of Punjab etcPTCL 2024 CL. 67 · Lahore High Court · 2023-10-09Read full judgment →
• Nek Muhammad Brohi vs Election Commission of Pakistan & another2024 SHC 136 · Sindh High Court · 2024-01-25Read full judgment →
• Nazir Ahmed vs Honorable Chief Justice, High Court of Balochistan through Registrar and another2024 PLJ Quetta 92, 2024 PLC (C.S.) 1254 · Balochistan High Court · 2023-10-31
  Leave Preparatory to Retirementpremature retirementlocus poenitentiaeservice ruleswithdrawal of retirementHigh Court establishmentcivil service
  Summary & questions settled

  This appeal challenged the order of the Chief Justice of the High Court of Balochistan, which refused the appellant's request to withdraw his previously sanctioned Leave Preparatory to Retirement (LPR). The core legal question was whether a civil servant could withdraw an LPR option after it had been sanctioned and acted upon, and whether Rule 48 of the Balochistan Civil Servants Leave Rules, 2020, permitted such withdrawal for High Court employees. The Court held that once an LPR application is accepted and acted upon—evidenced by the employee proceeding on leave and receiving salary—the transaction becomes final and closed. The principle of locus poenitentiae does not apply once an effective retirement order is passed. Furthermore, the Court ruled that Rule 48 of the Leave Rules, 2020, was inapplicable because no authority exists superior to the Chief Justice within the High Court to grant the necessary approval, and the rule was not incorporated into the High Court's specific service rules. Consequently, the appeal was dismissed.

  Questions settled

  • Can a government servant withdraw an application for Leave Preparatory to Retirement after it has been sanctioned and acted upon?
  • Does the principle of locus poenitentiae allow for the withdrawal of a retirement option once an effective order has been passed?
  • Is Rule 48 of the Balochistan Civil Servants Leave Rules, 2020 applicable to employees of the High Court of Balochistan?
  • Does a higher authority exist above the Chief Justice of the High Court of Balochistan for the purpose of approving the withdrawal of Leave Preparatory to Retirement?
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• Nazir Ahmed Langah vs Lahore High Court, Lahore through its Registrar2024 LHC 1798, 2024 PLC (C.S.) 1566 · Lahore High Court · 2024-04-24
  proforma promotionpensionary benefitspending disciplinary proceedingscivil servantvested rightback benefits
  Summary & questions settled

  This is an appeal filed by the appellant assailing an order whereby his request for the grant of proforma promotion as District and Sessions Judge to the extent of pensionary benefits was declined. The core legal question was whether a civil servant whose disciplinary proceedings and adverse remarks were subsequently resolved or set aside is entitled to proforma promotion and consequential pensionary benefits after retirement. The court held that all hurdles and impediments that previously justified deferring the appellant's promotion had vanished, and a civil servant has a vested, inalienable right to be considered for promotion when fulfilling the criteria. The court further held that promotion cannot be deferred solely due to pending disciplinary proceedings that ultimately end in the employee's favor. The appeal was accordingly allowed and the impugned order was set aside.

  Questions settled

  • Whether a civil servant is entitled to proforma promotion after the removal of impediments such as pending disciplinary proceedings?
  • Can promotion be deferred solely on the ground of pending departmental proceedings if the employee ultimately fulfills the eligibility criteria?
  • Is a civil servant entitled to be considered for promotion along with his batchmates as an inalienable right?
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• Nazeer alias Leemon and others vs The State2024 YLR 2675 · Sindh High Court · 2022-09-12
  criminal appealpolice encounterbenefit of the doubtjoint recovery memodelayed FSL reportacquittalfirearm injury
  Summary & questions settled

  This criminal appeal arises from a judgment of the Additional Sessions Judge, Gambat, convicting the appellants under Sections 401, 324, 353, and 337-F(ii) of the Pakistan Penal Code 1860. The prosecution alleged that the appellants engaged in a police encounter, resulting in firearm injuries to a police constable and one of the accused. The core legal questions involve the credibility of a joint recovery memo, the failure of the injured witness to specifically implicate the appellants, the inordinate delay in sending FSL empties, and the benefit of the doubt. The Sindh High Court allowed the appeal for two appellants, holding that the prosecution failed to establish the charge beyond a reasonable doubt due to general allegations, lack of specific attribution of injuries by the injured witness, defective joint recovery, delayed FSL dispatch, and non-production of the recovered motorcycle. The court established that a single circumstance creating reasonable doubt entitles the accused to acquittal as a matter of right, and joint recovery memos without distinct attribution carry weak evidentiary value.

  Questions settled

  • Whether a joint recovery memo of arrest and weapons has evidentiary value without distinct attribution to individual accused?
  • Does an inordinate delay in dispatching weapon empties to the forensic laboratory vitiate a positive FSL report?
  • Is an accused entitled to the benefit of the doubt as a matter of right based on a single reasonable circumstance?
  • Does the failure of an injured prosecution witness to specifically name the assailant warrant an acquittal?
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• Nazeer Ahmed vs Province of Sindh & others2024 SHC 1204 · Sindh High Court · 2024-10-31Read full judgment →
• Nazeer Ahmed alias Nazro and another vs The State2024 YLR 189 · Sindh High Court · 2022-09-27
  abduction for ransombenefit of doubtmaterial contradictionsdelayed FIRAnti-Terrorism Actcriminal appealacquittal
  Summary & questions settled

  This criminal appeal challenges the judgment of the Anti-Terrorism Court convicting the appellants under Section 365-A read with Section 149 of the Pakistan Penal Code 1860 and Section 7 of the Anti-Terrorism Act 1997, sentencing them to rigorous imprisonment for life. The core legal questions involved the credibility of evidence regarding alleged abduction for ransom, significant delays in lodging the FIR, material contradictions among prosecution witnesses, and non-compliance with mandatory procedural requirements. The Sindh High Court held that the prosecution failed to establish the charge beyond a reasonable doubt, noting that the abductee and complainant admitted the abductee boarded the vehicle voluntarily, there were major discrepancies regarding the payment of ransom and identification of witnesses, and no recovery was effected from the appellants. Consequently, the court set aside the conviction and acquitted the appellants by extending them the benefit of the doubt. The key principle laid down is that material contradictions, delayed FIRs, and unimpeachable gaps in proof entitle an accused to the benefit of the doubt as a matter of right.

  Questions settled

  • Does a voluntary boarding of a vehicle by an alleged abductee negate the charge of abduction under Section 365-A of the Pakistan Penal Code 1860?
  • What is the legal effect of an unexplained delay in lodging an FIR in kidnapping and ransom cases?
  • Whether material contradictions between the testimony of the complainant and prosecution witnesses are fatal to the prosecution's case?
  • Is an accused entitled to the benefit of the doubt when the prosecution fails to provide unimpeachable evidence of guilt?
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• Nazeer Ahmed & Gul Sher vs Province of Sindh2024 SHC 324, 2024 CLC 2044 · Sindh High Court · 2024-04-24Read full judgment →
• Nazar Mohammad Bozdar and others vs Muhammad Ishrat & others2024 SHC 1282 · Sindh High Court · 2024-11-22Read full judgment →
• Nazar Bhayo vs The State2024 SHC 516 · Sindh High Court · 2024-05-21
  pre-arrest bailmurderabsconderdirect complaintcriminal investigationfirearm injuries
  Summary & questions settled

  This matter concerns an application for pre-arrest bail filed by the accused, Nazar, who is charged with the murder of Mst. Azeema. The complainant alleged that the deceased was murdered by the applicant and co-accused due to her second marriage. The defense argued for bail, citing a direct complaint filed by the deceased's mother against the complainant as evidence of a two-version case requiring further inquiry. The Court examined the material, noting that the FIR assigned a direct role of firing to the applicant, which was corroborated by the postmortem report showing two firearm injuries and statements under Section 161 of the Code of Criminal Procedure 1898. The Court held that pre-arrest bail is an extraordinary remedy not meant for every case and that the direct complaint appeared to be a pressure tactic. Finding the applicant's involvement prima facie supported by evidence and noting his status as an absconder in the challan, the Court dismissed the bail application and ordered the applicant to be taken into custody to face trial.

  Questions settled

  • Is a direct complaint filed after a significant delay against a complainant sufficient grounds to grant pre-arrest bail in a murder case?
  • Can an accused who is shown as an absconder in the challan be taken into custody upon the dismissal of a pre-arrest bail application?
  • Does the existence of a two-version case automatically entitle an accused to the concession of pre-arrest bail?
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• Nazar Ali vs State2024 SHC 1278 · Sindh High Court · 2024-11-19Read full judgment →
• Naz Tahir vs Kafayat Ullah, etc2024 SCP 43, 2024 SCMR 508 · Supreme Court of Pakistan · 2024-01-26
  nomination paperselection appealproclaimed offenderqualification of candidateselectoral processNational Assembly
  Summary & questions settled

  This matter arises from a petition challenging the rejection of the petitioner's nomination papers for a seat as a Member of the National Assembly from NA-49, Attock-I. The Returning Officer initially rejected the papers because the petitioner was the wife of a proclaimed offender, but the Appellate Tribunal accepted them. Subsequently, the Lahore High Court set aside the Tribunal's decision and rejected the nomination papers on the same ground. The core legal question is whether a candidate can be disqualified from contesting elections merely for being the wife of a proclaimed offender under the applicable legal framework. The Supreme Court held that there is no provision under the Constitution or the Elections Act, 2017 that deprives a person of the right to contest elections on such a ground, noting also that certain constitutional provisions regarding qualifications are not self-executory. The Court suspended the impugned High Court order and directed the provisional acceptance of the petitioner's nomination papers.

  Questions settled

  • Whether being the wife of a proclaimed offender is a valid ground under the law to reject nomination papers for contesting elections?
  • Are Articles 62(1)(d), (e), (f) and (g) of the Constitution of Pakistan self-executory?
  • Can a High Court set aside the acceptance of nomination papers on grounds not provided in the Constitution or the Elections Act, 2017?
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• Nayyar Abbas vs The State etc2024 LHC 3449, 2025 YLR 75, PLJ 2025 Cr.C. 207 · Lahore High Court · 2024-02-13
  recovery memocontrol of narcotic substancesbenefit of the doubtcriminal appealsearch and seizurefair trialpolice rulesnarcotics possession
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of the appellant under Section 9(c) of the Control of Narcotic Substances Act, 1997, for the alleged possession of 2250 grams of charas. The core legal question revolved around the authenticity and evidentiary value of the recovery memo when vital particulars such as the FIR number, date, and police station name were missing from it, and whether its preparation post-dated the registration of the FIR. The Lahore High Court held that serious doubts were cast on the recovery proceedings because the testimonies and record confirmed the recovery memo lacked essential details and was prepared after the FIR was registered, thereby depriving it of legal sanctity. Consequently, the Court laid down that a foundational recovery memo lacking contemporaneous preparation and essential particulars creates a reasonable doubt in the prosecution's case, entitling the accused to an acquittal on the basis of the benefit of the doubt.

  Questions settled

  • Does the omission of the FIR number, date, and police station name on a recovery memo destroy its authenticity?
  • Is a recovery memo prepared after the registration of the FIR considered a tainted document lacking legal sanctity?
  • Does a single reasonable doubt arising from flaws in the prosecution's recovery proceedings entitle the accused to an acquittal as a matter of right?
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