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.

• Muhammad Amin Khan vs The Learned Ro and Another2024 SHC 68 · Sindh High Court · 2024-01-15Read full judgment →
• Muhammad Amin and others vs Haji Abdul Wahid and others2024 CLC 340 · Balochistan High Court · 2022-04-28Read full judgment →
• Muhammad Ameen and others vs Munawar Ali and others2024 CLC 2094 · Balochistan High Court · 2024-04-30Read full judgment →
• Muhammad Altaf vs Rana Shakeel Ahmad2024 LHC 3518, 2024 CLD 1247, 2024 MLD 1761 · Lahore High Court · 2024-07-19Read full judgment →
• Muhammad Altaf Kiani vs Mudassar Iqbal and 7 others2024 PCRLJ 1939 · Supreme Court of Azad Jammu and Kashmir · 2024-05-09
  summoning of witnessesrecall of witnessessential evidencejust decision of the casecriminal trial procedureinquisitorial role of courtre-examination
  Summary & questions settled

  This criminal matter arises from a revision petition filed before the High Court, which set aside a trial court order allowing the prosecution to recall a medical witness, Dr. Yasin, to exhibit an Istaswabia report concerning weapon examination in a murder case. The core legal question was whether the trial court possesses the authority under Section 540 of the Criminal Procedure Code to summon or recall a witness at any stage to bring essential evidence on record, and whether doing so improperly fills gaps in the prosecution's case. The Supreme Court of Azad Jammu and Kashmir held that Section 540 vests wide, discretionary, and mandatory powers in the court to summon or recall any witness if their evidence is essential for the just decision of the case, operating on an inquisitorial basis to ascertain the truth. The court laid down the principle that procedural omissions or gaps should not hinder a trial court from admitting crucial evidence necessary for a fair adjudication, and that the power to recall witnesses under Section 540 is not restricted by concerns over rectifying case flaws provided it serves the ultimate pursuit of justice.

  Questions settled

  • Does Section 540 of the Criminal Procedure Code empower a trial court to recall a witness to bring essential evidence on record despite procedural omissions?
  • Can the power to summon or recall a witness under Section 540 of the Criminal Procedure Code be denied merely on the ground that it might rectify a gap in the prosecution's case?
  • What is the primary scope and purpose of re-examining a witness under Article 132 of the Qanun-e-Shahadat Order, 1984, following cross-examination?
  Read full judgment →
• Muhammad Alim vs The State2024 PCRLJ 1531 · Balochistan High Court · 2022-10-05
  narcotic substanceschain of custodybenefit of doubtchemical examiner reportcriminal appealacquittal
  Summary & questions settled

  This criminal appeal challenges the conviction of the appellant under section 9(c) of the Control of Narcotic Substances Act, 1997, for the possession of charas. The core legal question concerns whether the prosecution established the chain of custody for the recovered contraband and proved the guilt of the accused beyond reasonable doubt. The Court found that the prosecution failed to provide a satisfactory explanation for the delay in transmitting the sealed parcels to the laboratory, creating a break in the chain of custody. Furthermore, the Court noted an unexplained delay in recording the statement of a key prosecution witness. Holding that the prosecution must establish an unbroken and secure chain of custody to rely on a chemical examiner's report, the Court concluded that the integrity of the evidence was compromised. Consequently, the Court set aside the conviction, acquitted the appellant, and ordered his immediate release, reaffirming the principle that a single circumstance creating reasonable doubt entitles an accused to acquittal as a matter of right.

  Questions settled

  • Does a break in the chain of custody of recovered contraband vitiate the reliability of a chemical examiner's report?
  • Is the prosecution required to prove its case beyond reasonable doubt even when the burden of proof regarding innocence shifts to the accused?
  • Does a single circumstance creating reasonable doubt entitle an accused to acquittal?
  Read full judgment →
• Muhammad Ali vs The State2024 SHC 848 · Sindh High Court · 2024-08-02
  post-arrest bailelectricity theftnon-prohibitory clausefurther inquirycriminal procedurebail principles
  Summary & questions settled

  The applicant sought post-arrest bail under Section 497, Code of Criminal Procedure 1898, regarding an FIR registered for electricity theft under Sections 462-I and 109, Pakistan Penal Code 1860. The core legal question was whether the applicant was entitled to bail given the nature of the offense and the evidentiary gaps in the prosecution's case. The Court held that the offense under Section 462-I, Pakistan Penal Code 1860, carries a maximum punishment of three years, thus falling outside the prohibitory clause of Section 497, Code of Criminal Procedure 1898. Consequently, the Court emphasized that for non-prohibitory offenses, the grant of bail is the rule and refusal is the exception. Furthermore, the Court observed that the absence of independent witnesses and ambiguities regarding the date of the alleged occurrence necessitated further inquiry under Section 497(2), Code of Criminal Procedure 1898. Relying on the principle established in Muhammad Tanveer v. The State, the Court granted bail, noting that the prosecution failed to establish a prima facie case sufficient to justify continued incarceration at the pre-trial stage.

  Questions settled

  • Does an offense under Section 462-I of the Pakistan Penal Code 1860 fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  • Is the absence of independent witnesses in a theft case a ground for granting post-arrest bail under the rule of further inquiry?
  • Should bail be granted as a rule in cases where the alleged offense does not fall within the prohibitory clause of Section 497 of the Code of Criminal Procedure 1898?
  Read full judgment →
• Muhammad Ali vs IInd Additional District & Session Judge (Malir), Karachi2024 SHC 5 · Sindh High CourtRead full judgment →
• Muhammad Ali vs Iftikhar Hussain etc2024 LHC 5600, 2025 YLR 663 · Lahore High Court · 2024-11-04Read full judgment →
• Muhammad Ali vs Ali Gohar and others2024 MLD 1655 · Sindh High Court · 2024-05-13Read full judgment →
• Muhammad Ali Maitlo and others vs P.O Sindh and others2024 SHC 470, 2024 PLC (C.S.) 1318 · Sindh High Court · 2024-05-14
  deceased quotapublic employmentconstitutional petitioncivil servantslocal government departmentright to livelihoodservice law
  Summary & questions settled

  This matter concerns petitions filed by legal heirs of deceased or incapacitated public servants of the Government of Sindh, specifically within the Local Government Department, seeking appointment against reserved quotas. The core legal question was whether these heirs are entitled to such appointments under the prevailing policy and Rule 11-A of the Sindh Civil Servants (Appointment, Promotion, and Transfer) Rules, 1974, and whether the two-year limitation period for applications bars their claims. The Court held that the respondents are obligated to consider these applications in light of established policy and Supreme Court precedents. It observed that the 2014 notification removed the strict two-year limitation for candidates whose employment rights had already accrued. The Court emphasized that public employment is a constitutional right to livelihood, and the state is obligated to protect the families of deceased servants. Consequently, the Court directed the Chief Secretary to scrutinize and decide the petitioners' cases through speaking orders, ensuring that previously rejected cases are reconsidered in accordance with the law and relevant judicial dicta.

  Questions settled

  • Are legal heirs of deceased or incapacitated employees of the Local Government Department entitled to appointment under the deceased quota policy?
  • Does the two-year limitation period for applying under the deceased quota apply to candidates whose right of employment accrued prior to the 2014 notification?
  • Is the government obligated to reconsider previously rejected applications for appointment under the deceased quota in light of Supreme Court precedents?
  Read full judgment →
• Muhammad Ali Mahar and another vs The State2024 SCP 228, 2024 SCMR 1584, PLJ 2025 SC (Cr.C.) 87 · Supreme Court of Pakistan · 2024-06-11
  pre-arrest bailhonour killingkaro-karifasad-fil-arzconstructive liabilitycommon intentionsui jurisextraordinary remedymala fide
  Summary & questions settled

  This criminal petition for leave to appeal was directed against the order of the High Court of Sindh dismissing the petitioners' pre-arrest bail application in a case registered under Sections 302, 34, 201, and 109 of the Pakistan Penal Code, 1860, concerning the murder of a 26-year-old woman portrayed by her family as suicide but alleged by her husband to be an honour killing. The core legal question was whether the petitioners, who were family members seeking pre-arrest bail, satisfied the extraordinary legal thresholds and demonstrated mala fide on the part of the complainant or prosecution. The Supreme Court of Pakistan held that pre-arrest bail is an extraordinary remedy requiring clear proof of mala fide or victimization, which the petitioners failed to establish, especially given the medical evidence, the suspicious conduct of the family in failing to report the death promptly, and retrieved digital communications contradicting the suicide theory. The Court dismissed the petition, recalled the interim pre-arrest bail, and laid down principles regarding the strict parameters for pre-arrest bail and the grave societal menace of honour killing amounting to fasad-fil-arz.

  Questions settled

  • Whether pre-arrest bail can be granted without demonstrating clear mala fide or ulterior motives on the part of the complainant or the prosecution?
  • Does the defense of suicide in a firearm death case override medical and circumstantial evidence pointing towards murder on the pretext of honour at the pre-arrest bail stage?
  • What are the statutory parameters governing pre-arrest bail under criminal jurisprudence in Pakistan?
  • Whether an offence committed in the name or on the pretext of honour constitutes fasad-fil-arz under the criminal law framework?
  Read full judgment →
• Muhammad Ali and another vs The State and another2024 YLR 2445 · Balochistan High Court · 2023-06-19
  criminal appealmurderbenefit of doubtcontradictory evidenceocular accountmedical evidenceacquittal
  Summary & questions settled

  This criminal appeal challenges the judgment of the trial court convicting the appellants under Section 302 of the Pakistan Penal Code 1860 and sentencing them to life imprisonment. The core legal question was whether the prosecution had established the guilt of the appellants beyond a reasonable doubt through consistent ocular and corroboratory evidence. The Balochistan High Court held that the prosecution witnesses contradicted each other on material aspects, including their presence at the scene and the timing of recording statements, and that the ocular account was unreliable. The Court reiterated that once the ocular account is ruled out, supporting circumstances like recovery and medical evidence collapse, and any reasonable doubt must be resolved in favor of the accused. Consequently, the High Court accepted the appeals, set aside the convictions, and acquitted the appellants.

  Questions settled

  • Whether medical evidence can serve as a substitute for direct ocular testimony in a murder trial?
  • What is the legal effect on the prosecution's case when the primary eye-witnesses make material contradictions and dishonest improvements?
  • Does the collapse of the ocular account automatically weaken the corroboratory evidence such as recoveries?
  • To what extent is an accused entitled to the benefit of doubt when reasonable doubts are created in the prosecution story?
  Read full judgment →
• Muhammad Ali (Haider), Zulfiqar Ali & others vs Province of Sindh through Chief Secretary Govt. of Sindh & others2024 SCP 411 · Supreme Court of Pakistan · 2024-12-17
  doctoral programPh.D. in lawHigher Education Commissionfaculty requirementseducational standardsuniversity administrationcivil petitions
  Summary & questions settled

  This civil petition arises from a judgment of the High Court of Sindh concerning a doctoral program in law introduced by the University of Karachi, which allegedly failed to comply with the basic criteria prescribed by the Higher Education Commission of Pakistan (HEC). An inquiry report submitted by the HEC highlighted critical shortcomings, including the absence of full-time, permanent Ph.D. faculty members. Enrolled students sought permission to challenge the High Court's adverse judgment. The Supreme Court of Pakistan observed that the doctoral program cannot continue in violation of HEC rules, as non-compliance would ultimately invalidate the degrees awarded to students. With the consent of the parties, the Supreme Court disposed of the petitions by directing the Vice Chancellor of the University and the HEC to each constitute a three-member committee to resolve the pending issues, rectify defaults, and explore solutions regarding faculty requirements within two months, allowing the HEC to independently decide the matter.

  Questions settled

  • Can a university conduct a Ph.D. program in law without complying with the criteria prescribed by the Higher Education Commission of Pakistan?
  • Whether third-party students affected by a High Court judgment can be granted leave to appeal before the Supreme Court?
  • How can committees from a university and the Higher Education Commission resolve compliance issues regarding a doctoral degree program?
  Read full judgment →
• Muhammad Aleem Gohar, Faisalabad vs The Cir (Corporate Zone), Rto, FaisalabadPTCL 2024 CL. 687 · Appellate Tribunal Inland Revenue · 2024-03-21Read full judgment →
• Muhammad Alamgir Khan vs Election Commission of Pakistan & others2024 SHC 1308 · Sindh High Court · 2024-12-03Read full judgment →
• Muhammad Akram, Mir Muhammad vs The Additional Chief Secretary &2024 SHC 1228, 2025 CLC 896 · Sindh High Court · 2024-10-21Read full judgment →
• Muhammad Akram vs The State and another2024 YLR 2469 · Lahore High Court · 2022-01-25
  criminal appealmurderbenefit of doubtdelay in FIRnocturnal identificationdishonest improvementsmotivecorroborative evidenceacquittal
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of the appellant under section 302(b) of the Pakistan Penal Code 1860, arising from a murder case registered at Police Station Kameer, District Sahiwal. The core legal questions involved whether the prosecution successfully established its case beyond a reasonable doubt given the gross unexplained delay in lodging the FIR, the absence of a specified light source at the time of the nocturnal occurrence, material improvements in ocular testimony, and an unproven motive. The Lahore High Court held that the prosecution failed to prove its case due to suspicious delays in reporting, lack of credible identification in the dark, dishonest improvements by eyewitnesses, and a weak, contradictory motive where the actual party to the land dispute remained unharmed while another was killed. Consequently, the court set aside the conviction and sentence, extending the benefit of the doubt to the appellant and acquitting him of the charges. The key principle laid down is that a single reasonable circumstance creating doubt in a prudent mind entitles the accused to acquittal as a matter of right, and corroborative pieces of evidence like recoveries cannot sustain a conviction in the absence of reliable substantive evidence.

  Questions settled

  • Whether a gross, unexplained delay in lodging the First Information Report creates a fatal doubt regarding the truthfulness of the prosecution story?
  • Does the failure to mention a source of light in the FIR render the identification of the accused in the darkness of night doubtful?
  • Can an accused be convicted solely on the basis of a corroborative piece of evidence like a weapon recovery when the substantive ocular and motive evidence has been disbelieved?
  • Whether material and dishonest improvements made by eyewitnesses during trial destroy their credibility?
  Read full judgment →
• Muhammad Akram vs Province of Sindh and others2024 SHC 1332 · Sindh High Court · 2024-12-13Read full judgment →
• Muhammad Akram vs Province of Punjab through Collector and others2024 LHC 551 · Lahore High Court · 2024-01-26Read full judgment →
• Muhammad Akram vs Liaqat Ali Khan and another2024 CLC 638 · Islamabad High Court · 2021-03-10Read full judgment →
• Muhammad Akram vs Haji Ilam Din (deceased) through L.Rs and others2024 LHC 850, 2024 PLJ Lahore 302 · Lahore High Court · 2024-03-01Read full judgment →
• Muhammad Akram vs Additional Sessions Judge and another2024 LHC 2375 · Lahore High Court · 2024-03-06
  narcotics traffickingconfiscation of vehicledisposal of propertySection 520 CrPCrestoration of propertyacquittal consequencesspecial jurisdictionControl of Narcotic Substances Act
  Summary & questions settled

  This matter concerns an appeal against an order of the Additional Sessions Judge, which dismissed an application for the restoration of a vehicle confiscated during a narcotics trial. The appellant, previously convicted under the Control of Narcotic Substances Act, 1997, was subsequently acquitted by the High Court. The core legal question was whether the High Court, or a subordinate court, retains jurisdiction to order the disposal or restoration of seized property under Section 520 of the Code of Criminal Procedure 1898 after the main criminal proceedings have concluded. The Court held that Section 520 of the Code of Criminal Procedure 1898 confers a unique, independent, and supervisory jurisdiction upon designated courts to pass necessary orders regarding property disposal, regardless of the pendency of an appeal or revision. Consequently, the Court treated the appeal as an application under Section 520 of the Code of Criminal Procedure 1898 and ordered the restoration of the vehicle to the appellant, finding no evidence of his involvement in the offence. The judgment establishes that acquittal generally entitles an accused to the return of seized property, provided no competing claims of title exist.

  Questions settled

  • Does the High Court have jurisdiction under Section 520 of the Code of Criminal Procedure 1898 to order the restoration of property after the main appeal has been decided?
  • Is the power to order the disposal of property under Section 517 of the Code of Criminal Procedure 1898 contingent upon the pendency of the main criminal trial?
  • Does an acquittal in a criminal case automatically entitle the accused to the return of property seized during the investigation?
  • Can a trial court order the confiscation of a vehicle under the Control of Narcotic Substances Act 1997 if the owner is acquitted of the charges?
  Read full judgment →
• Muhammad Akram Sohail vs Govt. of the Punjab through Secretary Forest2024 LHC 1923 · Lahore High CourtRead full judgment →
• Muhammad Akram Rahi vs The Copyright Board and three others2024 LHC 3351, 2024 CLD 1277 · Lahore High Court · 2024-07-08Read full judgment →
• Muhammad Akram (Deceased) through Legal Heirs vs Allied Bank Limited2024 CLD 1444 · Lahore High Court · 2024-02-20Read full judgment →
• Muhammad Akhtar vs Commissioner Inland Revenue, Withholding Tax2024 PTD (Trib.) 1553 · Appellate Tribunal Inland Revenue · 2023-07-31Read full judgment →
• Muhammad Akhtar Shah vs Judge Family Court, Kot Addu & others2024 LHC 4377, 2025 MLD 114, 2025 PLJ Lahore 33 · Lahore High Court · 2024-10-03Read full judgment →
• Muhammad Akhtar and others, Muhammad Arshad vs The State &2024 SCP 324, 2025 SCMR 45 · Supreme Court of Pakistan · 2024-05-24
  murdereyewitness credibilityadverse inferencefirearm expertbenefit of doubtdishonest improvementscriminal appeal
  Summary & questions settled

  This criminal appeal arose from a judgment of the Lahore High Court which had maintained the conviction of the appellant under Section 302(b) of the Pakistan Penal Code 1860 but commuted his death sentence to life imprisonment, while acquitting several co-accused. The prosecution's case rested on ocular accounts of a multi-victim shooting, but the Supreme Court of Pakistan observed that the recovered firearms and crime empties were never sent to a firearm expert for analysis. Furthermore, the complainant, despite claiming to be an eyewitness from a close range, did not sustain any injuries during the indiscriminate firing, and his testimony was filled with precise attributions that cast doubt on his presence. The non-production of other key eyewitnesses led the Court to draw an adverse inference under Article 129(g) of the Qanun-e-Shahadat 1984. Finding material contradictions, dishonest improvements, and a lack of independent corroboration, the Supreme Court held that the prosecution failed to prove its case beyond a reasonable doubt. The Court accepted the appellant's appeal, ordered his acquittal, and dismissed the complainant's appeals against the co-accused's acquittals.

  Questions settled

  • What is the legal effect of failing to send recovered weapons and crime empties to a firearm expert for forensic analysis?
  • Can an adverse inference under Article 129(g) of the Qanun-e-Shahadat 1984 be drawn if the prosecution fails to produce material eyewitnesses at trial?
  • Does the absence of physical injuries on an alleged eyewitness during an indiscriminate firing incident cast doubt on their presence at the crime scene?
  Read full judgment →
• Muhammad Ajmal vs Ex-Officio Justice of Peace /Additional Sessions2024 PLJ Lahore 764 · Lahore High CourtRead full judgment →
• Muhammad Ajab (deceased) through LRs and others. vs Yousaf & others2024 PHC 330 · Peshawar High Court · 2024-10-10Read full judgment →
• Muhammad Ain-ul-Haq vs Abdul Ali and another2024 SCMR 1767 · Supreme Court of Pakistan · 2024-07-25
  execution proceedingseviction ordertenant evictionfair rentconstitutional petitionsupreme court
  Summary & questions settled

  This petition challenges an order passed by the High Court of Sindh, which disposed of the petitioner tenant's constitutional petition by directing him to hand over vacant possession of the demised premises to the respondent landlord. The core legal question involves the scope and limitations of execution proceedings when the underlying eviction order passed by the Rent Controller has attained finality and remains unchallenged. The Supreme Court held that in execution proceedings, courts are strictly confined to the implementation of judicial decisions and are legally precluded from deliberating on or revisiting the merits of the underlying case. The ratio established is that an unchallenged eviction order remains valid and enforceable, and executing courts cannot scrutinize its legality. The Court affirmed the impugned order, dismissed the petition, and refused leave to appeal.

  Questions settled

  • Can a court examine the merits of an underlying case during execution proceedings?
  • Whether an unchallenged eviction order passed by a Rent Controller remains legally valid and enforceable?
  • Does an executing court have the latitude to scrutinize or revisit the findings of an original eviction order?
  Read full judgment →
• Muhammad Ahmed vs Muhammad Ismail and others2024 MLD 594 · Sindh High Court · 2016-04-12Read full judgment →
• Muhammad Afzal vs Collector Land Acquisition Mangla Dam Raising2024 PLJ AJ&K 170 · High Court of Azad Jammu and KashmirRead full judgment →
• Muhammad Afzal vs Binyameen Sajid2024 LHC 2511, 2024 CLD 1184, 2024 CLC 1643 · Lahore High Court · 2024-05-16Read full judgment →
• Muhammad Afzal Khan vs Amreen Gul2024 SC AJK 1 · Supreme Court of Azad Jammu and Kashmir · 2024-01-08Read full judgment →
• Muhammad Afzal and others vs Abdul Hameed and others2024 LHC 2501, 2024 MLD 1810 · Lahore High Court · 2024-05-14Read full judgment →
• Muhammad Afsar and 6 others vs Collector Acquisition, Islamabad and another2024 PLJ Islamabad 344 · Islamabad High CourtRead full judgment →
• Muhammad Adil Nawaz Bhatti vs Chairman Union Council and others2024 LHC 538, 2024 PLJ Lahore 214, 2025 PLD Lahore 340 · Lahore High Court · 2024-01-30Read full judgment →
• Muhammad Adil and others vs Mst. Shamim Akhtar (deceased) through L.Rs2024 LHC 1258 · Lahore High Court · 2024-03-20Read full judgment →
• Muhammad Adeel Akhtar vs The State & Ors2024 SHC 744 · Sindh High Court · 2024-07-09
  B-Class reportcriminal intimidationpersona designataSection 173 CrPCdirect complaintpolice investigationinherent jurisdiction
  Summary & questions settled

  This Criminal Miscellaneous Application challenged an order passed by a Judicial Magistrate, which accepted a police report filed under "B-Class" (maliciously false) and directed the initiation of proceedings against the complainant under Section 182 of the Pakistan Penal Code 1860. The core legal question was whether the Magistrate's concurrence with the police report was legally sound and whether it warranted interference by the High Court. The Court held that when a Magistrate concurs with a police report submitted under Section 173 of the Code of Criminal Procedure 1898, they act in an administrative or ministerial capacity as a persona designata, rather than as a criminal court. Consequently, such orders are not subject to revision under Sections 435 or 439 of the Code of Criminal Procedure 1898, though they may be challenged under Section 561-A of the Code of Criminal Procedure 1898 if they constitute an abuse of process. Finding no such abuse, the Court upheld the impugned order, clarifying that the complainant’s appropriate remedy is to file a direct complaint before the competent forum.

  Questions settled

  • Does a Magistrate act as a criminal court when concurring with a police report submitted under Section 173 of the Code of Criminal Procedure 1898?
  • Are orders passed by a Magistrate concurring with a B-Class police report subject to revision under Sections 435 and 439 of the Code of Criminal Procedure 1898?
  • What is the appropriate remedy for a complainant when a Magistrate accepts a B-Class police report and discharges the accused?
  • Does the definition of criminal intimidation under Section 503 of the Pakistan Penal Code 1860 apply when the alleged act has already been materialized?
  Read full judgment →
• Muhammad Abdullah Abrar Syed, etc. vs Pakistan Medical and Dental2024 LHC 1424 · Lahore High CourtRead full judgment →
• Muhammad Aamir Karim vs The State, etc2024 LHC 4485 · Lahore High Court · 2024-10-08
  benefit of doubtchance witnessidentification parademurder trialappreciation of evidencecriminal appealwithholding evidence
  Summary & questions settled

  This criminal appeal challenges the conviction and sentence of life imprisonment imposed by the Additional Sessions Judge/MCTC, Ahmadpur East, for an offence under section 302(b) of the Pakistan Penal Code 1860. The core legal question is whether the prosecution successfully established the appellant's guilt beyond reasonable doubt, given the reliance on chance witnesses, a delayed identification parade, and inconsistencies in the medical evidence. The Lahore High Court held that the prosecution failed to prove its case. The court found that the eye-witnesses were 'chance witnesses' who failed to justify their presence at the scene, and that the identification parade was unreliable due to significant delays and procedural flaws. Furthermore, the court noted that the prosecution withheld the best evidence by failing to produce a key witness, and that the medical evidence contradicted the prosecution's timeline. Consequently, the court set aside the conviction, acquitting the appellant by extending the benefit of doubt. The judgment reaffirms the principle that any single loophole or lacuna in the prosecution's case must be resolved in favour of the accused.

  Questions settled

  • Can the testimony of witnesses who fail to justify their presence at the scene of a crime be relied upon for conviction?
  • Does a significant delay in conducting an identification parade render it unreliable?
  • What is the legal consequence of the prosecution withholding the best available evidence in a criminal trial?
  • Does a noticeable delay in the post-mortem examination of a deceased create a reasonable doubt regarding the prosecution's timeline?
  Read full judgment →
• Muhamamd Naeem Khanand others vs Mst. Alia and another2024 PHC 92 · Peshawar High Court · 2024-01-10Read full judgment →
• Muhamamd Farooq vs The State2024 SHC 1324 · Sindh High Court · 2024-12-05
  post-arrest bailembezzlementprohibitory clausecriminal conspiracyfraud and forgeryjudicial discretionwhite-collar crime
  Summary & questions settled

  This post-arrest bail application arose from the trial court's refusal to grant bail to the applicant, who was accused of misappropriating funds designated for the construction of a Social Security Hospital. The core legal question concerned whether the applicant was entitled to bail despite allegations of fraud, forgery, and criminal conspiracy, and whether the offenses fell within the prohibitory clause of Section 497, Code of Criminal Procedure 1898. The High Court dismissed the application, holding that the prosecution established a strong prima facie case, supported by evidence that the applicant was a direct beneficiary of the embezzled funds, which he failed to explain. The court affirmed that bail is not a punitive measure but a preventive one, intended to secure the accused's presence at trial and protect prosecution evidence from tampering. Emphasizing that appellate courts should not interfere with trial court discretion unless exercised arbitrarily or perversely, the court concluded that the trial court's decision was consistent with the incriminating material on record. The application was dismissed, with liberty granted to reapply after the examination of the complainant.

  Questions settled

  • Does the refusal of bail for offenses falling within the prohibitory clause of Section 497, Code of Criminal Procedure 1898 constitute a punitive measure?
  • Under what circumstances should a High Court interfere with the trial court's exercise of discretion in bail matters?
  • Is an accused entitled to bail when there is prima facie evidence of being a beneficiary of embezzled funds?
  Read full judgment →
• Muhamad Umer vs The State2024 SHC 1156 · Sindh High Court · 2024-10-09
  FIR registrationharassmentpersonal bondJustice of Peacecompliance reportcontempt application
  Summary & questions settled

  The applicant, Muhammad Umer Kunbhar, challenged an order passed by the Additional Sessions Judge-I/Ex-Officio Justice of Peace, Mirpurkhas, which had dismissed his application seeking the registration of an FIR. During the proceedings before the High Court, previous directions were issued to the DIG Mirpurkhas to conduct an inquiry and submit a compliance report. Upon the submission of the compliance report by the DIGP Mirpurkhas, the parties reached a consensus regarding the disposal of the matter. The Court held that the application should be disposed of based on the mutual agreement of the parties. The key principle established is that where parties reach a consensus to resolve a dispute regarding alleged harassment, the Court may dispose of the matter by directing the Station House Officer (SHO) to obtain personal bonds from the respondents to ensure no harassment is caused to the applicant, with specific instructions for the DIGP to take action in the event of non-compliance.

  Questions settled

  • Can a court dispose of an application for FIR registration based on a mutual agreement between parties regarding harassment?
  • What is the procedure for ensuring no harassment is caused to an applicant when parties agree to a settlement in a criminal miscellaneous application?
  Read full judgment →
• Mufti Muhammad Rafi & others vs M/s. Works Cooperative Housing Society,2024 SHC 1356 · Sindh High CourtRead full judgment →
• Mudassir Ahmed Soomro vs Province of Sindh & others2024 SHC 492 · Sindh High Court · 2024-05-14Read full judgment →
• Mudassar Iqbal s/o Muhammad Iqbal Mughal & 06 others vs The State of2024 SC AJK 32, 2024 PCRLJ 1863 · Supreme Court of Azad Jammu and Kashmir · 2024-05-14
  fair trialdue processsupply of statementsSection 265-C CrPCcase diariesprivileged documentscross-examinationinvestigation officer
  Summary & questions settled

  This matter arises from a criminal trial where the petitioners, facing murder charges, sought copies of additional statements of prosecution witnesses that the Investigation Officer revealed during cross-examination were recorded alongside statements under Section 161 of the Code of Criminal Procedure. The trial court and the Shariat Appellate Bench of the High Court dismissed the petitioners' request. The Supreme Court of Azad Jammu and Kashmir examined whether the accused are entitled to copies of such witness statements and police records. Holding that the fundamental right to a fair trial and due process under Article 19 of the Azad Jammu and Kashmir Interim Constitution, 1974, along with the provisions of Section 265-C of the Code of Criminal Procedure, mandates that the accused be provided with copies of all witness statements and records relied upon or gathered during investigation to ensure a just defense, the court accepted the revision petition, set aside the lower courts' orders, and directed the trial court to supply the requested statement copies to the petitioners.

  Questions settled

  • Whether an accused is entitled to receive copies of witness statements recorded during police investigation under the Code of Criminal Procedure?
  • Are statements recorded by an Investigating Officer under Section 161 of the Code of Criminal Procedure privileged documents like case diaries under Section 172?
  • Does the right to a fair trial and due process under the Constitution guarantee the supply of all investigative statements to the accused?
  Read full judgment →
• Mubassir Ali Khan vs Government of Khyber Pakhtunkhwa and others2024 YLR 2762 · Peshawar High Court · 2023-07-26Read full judgment →
• Mubashar Ali Shah vs Muhammad Sharif and others2024 LHC 2492, 2024 MLD 1508 · Lahore High Court · 2024-05-13Read full judgment →
• Mubarik Ahmad Sani vs The State and another2024 SCP 60, PLJ 2024 SC (Cr.C.) 111, 2024 SCMR 1303 · Supreme Court of Pakistan · 2024-02-06
  retrospective criminal liabilitypost-arrest bailfreedom of religioncharge alterationfundamental rightsproscribed literature
  Summary & questions settled

  This matter concerns a criminal petition seeking the deletion of charges and a separate petition for post-arrest bail arising from FIR No. 661/22. The petitioner was charged under the Punjab Holy Quran (Printing and Recording) Act, 2011, and sections 298-C and 295-B of the Pakistan Penal Code, 1860, for allegedly distributing a proscribed book in 2019. The core legal questions were whether the petitioner could be charged for an act that was not an offence at the time of commission and whether the evidence supported the framed charges. The Supreme Court held that the distribution of the book was not an offence in 2019, as the relevant amendment was enacted in 2021, rendering the charge violative of Article 12 of the Constitution. Furthermore, the Court found the FIR and police report lacked evidence to sustain the charges under sections 298-C and 295-B of the Pakistan Penal Code, 1860. The Court emphasized that religious compulsion violates fundamental rights and constitutional mandates. Consequently, the Court deleted the charges and granted bail, noting the petitioner had already served double the maximum potential sentence.

  Questions settled

  • Can a person be prosecuted for an act that was not an offence at the time of its commission?
  • Does the continued incarceration of an accused beyond the maximum potential sentence for an offence violate fundamental rights?
  • Can a court delete charges from a case if the FIR and police report fail to disclose the necessary ingredients of the alleged offences?
  • Does the principle of no compulsion in religion constitute a fundamental right under the Constitution of Pakistan?
  Read full judgment →
• Mst. Zumarad Siddique and others vs Province of Punjab through Chief2024 PTD 644 · Lahore High Court · 2024-01-12Read full judgment →
• Muhammad Ali Khan vs Additional District Judge etc.2024 LHC 795 · Lahore High Court · 2024-02-06Read full judgment →
• Mst. Zulekha Bibi and others vs Mst. Hafeeza Ahmed and others2024 SHC 930 · Sindh High CourtRead full judgment →
• Mst. Zubaida Bibi vs Addl. District Judge, etc2024 LHC 2104 · Lahore High Court · 2024-04-25Read full judgment →
• Mst. Zebun Nisa through legal heirs and another vs Ismail and others2024 PHC 52 · Peshawar High Court · 2024-02-01Read full judgment →
• Mst. Zarmina Bibi vs Government of Balochistan through Secretary, Local2024 MLD 71, 2024 PLJ Quetta 64 · Balochistan High Court · 2023-06-01Read full judgment →
• Mst. Zaibi vs Zahid Ali and others2024 PHC 196, 2024 PLD Peshawar 197, 2024 PLJ Peshawar 152 · Peshawar High Court · 2024-03-21Read full judgment →
• Mst. Zaib un Nisa, etc vs Additional District Judge, etc2024 LHC 5824 · Lahore High Court · 2024-11-20Read full judgment →
• Mst. Zahida Ashraf & Two Others vs The Bank of Punjab Limited2024 SHC 1218 · Sindh High Court · 2024-11-06Read full judgment →
• Mst. Yasmeen W/o Zulfiqar Ali vs The State2024 SHC 836 · Sindh High Court · 2024-07-23
  post-arrest bailnarcotics controlwoman accusedprohibitory clausefurther inquiryrecovery of narcotics
  Summary & questions settled

  This is a post-arrest bail application filed under Section 497 of the Code of Criminal Procedure 1898 on behalf of a female applicant accused of possessing 560 grams of heroin, an offense falling under Section 9(c) of the Control of Narcotic Substances Act 1997. The core legal questions involve the entitlement of a female accused to post-arrest bail under the first and second provisos of Section 497 Cr.P.C. in narcotics cases, and the effect of the police's failure to use modern devices for recording searches as mandated by superior courts. The Sindh High Court held that bail is a rule and refusal an exception for women under the law, and that the failure of the police to record searches using modern techniques warrants further inquiry into the prosecution's case under Section 497(2) Cr.P.C. The court laid down the principle that the heinousness of an offense alone is no ground to deny bail, and that female accused and cases requiring further probe into search procedures are fit for the concession of post-arrest bail.

  Questions settled

  • Whether a female accused is entitled to the concession of post-arrest bail under the provisos of Section 497 Cr.P.C. even in offenses falling within the prohibitory clause?
  • Does the failure of police to record or photograph a search using modern devices under Article 164 of the Qanoon-e-Shahadat 1984 create grounds for further inquiry into the guilt of the accused?
  • Can bail be refused to an accused solely on the ground that the offense charged is heinous in nature?
  • Do Sessions Courts and High Courts retain the power to grant bail in narcotics cases despite the bar contained in Section 51 of the Control of Narcotic Substances Act 1997?
  Read full judgment →
• Mst. Yasmeen vs Dr. Fahad Ahmad and others2024 PCRLJ 1881 · Lahore High Court · 2024-05-10
  Anti-Rape ActSpecial Sexual Offences Investigation UnitSSOIUcriminal investigationsexual offencesconstitutional petitionpolice investigation
  Summary & questions settled

  The petitioner challenged an order transferring the investigation of an FIR involving offences under sections 376(1), 384, and 341 of the Pakistan Penal Code 1860 to a single female sub-inspector. She contended that under section 9 of the Anti-Rape (Investigation and Trial) Act 2021, cases must be investigated collectively by the entire Special Sexual Offences Investigation Unit (SSOIU) rather than an individual officer. The core legal question was whether section 9 mandates collective investigation by the entire SSOIU or permits an individual trained member of the unit to investigate independently. The Lahore High Court held that individual police officers who are members of the SSOIU can conduct investigations autonomously, as mandating the entire unit to investigate every case collectively would be impracticable and frustrate the Act's objective of speedy trials. The court laid down the principle that while the Anti-Rape Act establishes SSOIUs for specialized handling of sexual violence cases, a single qualified officer—preferably a female officer in cases involving women or children—is legally competent to independently investigate scheduled offences.

  Questions settled

  • Whether section 9 of the Anti-Rape (Investigation and Trial) Act 2021 requires an entire Special Sexual Offences Investigation Unit to collectively investigate a scheduled offence or permits an individual member of the unit to conduct the investigation independently?
  • Can a single trained police officer who is a member of the Special Sexual Offences Investigation Unit lawfully investigate sexual and gender-based violence offences under the Anti-Rape (Investigation and Trial) Act 2021?
  • What is the distinction between an investigation unit and a joint investigation team in the context of criminal jurisprudence under Pakistani law?
  Read full judgment →
• Mst. Uzma Mukhtar vs The State thr. Deputy Attorney General and another2024 SCP 214, 2024 SCMR 1520 · Supreme Court of Pakistan · 2024-06-11
  cybercrimeretrospective punishmentalteration of chargeblackmailinginformation systemconstitutional protection
  Summary & questions settled

  This criminal petition for leave to appeal arose from a cybercrime case where the complainant (petitioner) alleged that the accused (respondent No. 2) harassed, blackmailed, and threatened her using her personal pictures. The FIR was registered under Sections 36 and 37 of the Electronic Transactions Ordinance 2002 (ETO) along with Sections 500, 506, and 509 of the Pakistan Penal Code 1860 (PPC). During trial, the trial court deleted the ETO charges as inapplicable and transferred the case. The petitioner sought to alter the charge to include Sections 20, 21, and 24 of the Prevention of Electronic Crimes Act 2016 (PECA). The trial court and High Court rejected this, noting PECA was enacted after the alleged offences. The Supreme Court of Pakistan upheld these findings, holding that PECA 2016 could not be applied retrospectively under Article 12 of the Constitution of Pakistan 1973. Furthermore, the Court ruled that Sections 36 and 37 of the ETO 2002 were not attracted as the accused did not unauthorizedly access, alter, or impair any information system.

  Questions settled

  • Can the provisions of the Prevention of Electronic Crimes Act 2016 be applied retrospectively to offences committed prior to its enactment?
  • Does Article 12 of the Constitution of Pakistan 1973 bar the prosecution of an accused under a penal statute that was not in field at the time of the alleged commission of the offence?
  • What constitutes unauthorized access or damage to an information system under Sections 36 and 37 of the Electronic Transactions Ordinance 2002?
  Read full judgment →
• Mst. Tahira Samina and others vs Javed Saeed Tariq and others2024 SCMR 24 · Supreme Court of Pakistan · 2023-10-19
  gift deedMahomedan Lawdelivery of possessionlimitation periodcause of actioncancellation of deedproperty dispute
  Summary & questions settled

  This matter concerns a property dispute between brothers regarding the validity of a registered gift deed executed in 1991. The predecessor of the petitioners (plaintiff) challenged the gift deed twenty years later, after the respondent (defendant) attempted to mutate the property in his name in the cantonment records. The core legal question was whether the gift deed was validly executed under Islamic law, specifically regarding the essential ingredients of offer, acceptance, and delivery of possession, and whether the suit was barred by limitation. The Supreme Court held that the gift deed was invalid because the essential ingredients of a valid gift under Islamic law were not fulfilled, as the defendant was not present in Pakistan at the time of registration, and no evidence of acceptance or delivery of possession existed. Furthermore, the Court ruled that the limitation period for challenging the deed commenced when the defendant first asserted his rights through the mutation attempt. Consequently, the Court set aside the lower courts' judgments, decreed the plaintiff's suit for cancellation of the gift deed, and dismissed the defendant's suit for possession.

  Questions settled

  • What are the essential ingredients for the completion of a valid gift under Islamic law?
  • Does the registration of a gift deed alone satisfy the requirements for a valid gift if the essential ingredients of offer, acceptance, and delivery of possession are missing?
  • When does the limitation period commence for a suit challenging a registered gift deed?
  • Can a gift deed be upheld if the donor remains in possession of the property and the donee fails to prove acceptance and delivery of possession?
  Read full judgment →
• Mst. Sidra and another vs State & others2024 SHC 1298 · Sindh High Court · 2024-11-25Read full judgment →
• Mst. Shumaila Sharif vs The Secretary, Union Council and 5 others2024 PLD Lahore 443 · Lahore High Court · 2023-01-18Read full judgment →
• Mst. Sharif Zadgai and others vs Provincial Government through Secretary, Khyber Pakhtunkhwa and others2024 YLR 2303 · Peshawar High Court · 2022-11-16Read full judgment →
• Mst. Sharafat Bibi vs Ministry of Interior, lslamabad2024 PHC 118 · Peshawar High Court · 2024-03-26Read full judgment →
• Mst. Shamim Bibi alias Seema Bibi and 6 others vs Zakir Hussain and others2024 LHC 3718 · Lahore High Court · 2024-09-02Read full judgment →
• Mst. Shamim Akhtar vs Federation Of Pakistan Through Secretary Ministry2024 LHC 5593, 2025 PLC (C.S.) 738 · Lahore High Court · 2024-11-27
  special family pensionarmed forces pension regulationsdependent pensionmartyred officerreasonable classificationconstitutional equalitylaw reforms appeal
  Summary & questions settled

  This intra-court appeal arises from the dismissal of a writ petition filed by the mother of a martyred military officer seeking full special family pension after the death of the officer's widow, who was the initial recipient. The core legal question concerns the interpretation of the Pension Regulations, Volume-I (Armed Forces) 2010 regarding whether the mother of a commissioned officer is entitled to the full special family pension previously received by the deceased widow or a second life dependent pension under different provisions. The Lahore High Court held that where a widow is the first recipient at the time of the casualty, the mother's claim is governed by Clause b(1) of Regulation 49, restricting her to a second life dependent pension, whereas Clause b(2) applies only when parents are the first recipients in the absence of a widow. The court laid down the principle that the regulatory framework creates a valid classification between initial recipients and subsequent dependents, and that equality under Article 25 of the Constitution of Pakistan does not prohibit reasonable classifications based on distinct service structures and rules governing commissioned versus junior commissioned officers.

  Questions settled

  • Whether the mother of a martyred army officer is entitled to the full special family pension after the death of the officer's widow under the Pension Regulations, Volume-I (Armed Forces) 2010?
  • Does the distinction in pension entitlements between commissioned officers and junior commissioned officers violate the right to equality under Article 25 of the Constitution of Pakistan 1973?
  • Whether Regulation 63 of the Pension Regulations, Volume-I (Armed Forces) 2010 applies to special family pensions or is restricted to normal pensions?
  Read full judgment →
• Mst. Shamim Akhtar vs Additional District Judge Rawalpindi & others2024 LHC 4494, 2024 PLJ Lahore 891, 2025 MLD 523 · Lahore High Court · 2024-10-23Read full judgment →
• Mst. Shamim Akhtar (deceased) through Legal Heirs and others vs Abdul2024 LHC 5313 · Lahore High CourtRead full judgment →
• Mst. Shaiza and another vs SHO PS Tharushah & others2024 SHC 838 · Sindh High Court · 2024-07-30Read full judgment →
• Mst. Shahnaz Bibi and others vs Ombudsperson (Mohtasib) Punjab and others2024 YLR 716 · Lahore High Court · 2023-11-06Read full judgment →
• Mst. Shahira Bibi vs The State2024 PHC 322 · Peshawar High Court · 2024-10-08Read full judgment →
• Mst. Shahina vs The State2024 SHC 1024 · Sindh High Court · 2024-10-03
  pre-arrest baildishonestly issuing a chequefurther inquiryanticipatory bailcriminal breach
  Summary & questions settled

  This matter arises from a pre-arrest bail application filed by the applicant, Mst. Shahina, seeking pre-arrest bail in Crime No.312/2024 registered under Section 489-F of the Pakistan Penal Code 1860 at Police Station Pakistan Bazar, Karachi, after her bail was refused by the Court of Sessions. The core legal question is whether the applicant is entitled to pre-arrest bail in a case involving a meager amount where she is a lady, has joined the trial, and documentary evidence has been collected. The Sindh High Court allowed the bail application and confirmed the interim pre-arrest bail, holding that the case against the applicant requires further inquiry as the accusation is yet to be established through evidence at trial. The key principle laid down is that where the financial amount involved is meager, the accused is a lady who has regularly appeared before the trial court, and further inquiry is warranted, pre-arrest bail should be granted.

  Questions settled

  • Whether pre-arrest bail can be granted when the financial amount involved in an offence under Section 489-F PPC is meager?
  • Is an accused lady entitled to pre-arrest bail when she has regularly joined the trial proceedings?
  • Can bail be confirmed where documentary evidence has been collected and the accusation is yet to be established through trial evidence?
  Read full judgment →
• Mst. Shahidah Bibi vs The State, etc2024 LHC 5214, PLJ 2025 Cr.C. 35, 2025 YLR 867 · Lahore High Court · 2024-11-13
  control of narcotic substancessafe custody of case propertychain of custodyforensic analysisstatement of accusedbenefit of doubtcriminal appealacquittal
  Summary & questions settled

  This criminal appeal challenges the judgment of the trial court convicting the appellant under Section 9(1)(3)(c) of the Control of Narcotic Substances Act, 1997, and sentencing her to nine years of rigorous imprisonment with a fine. The core legal question revolves around whether the prosecution successfully established the unbroken chain of safe custody and safe transmission of the recovered contraband and its sample to the forensic laboratory. The Lahore High Court held that discrepancies in the testimonies of prosecution witnesses regarding the recovery, handling, and transmission of the sample parcels, coupled with the failure to put vital incriminating material to the accused under Section 342 of the Code of Criminal Procedure, 1898, rendered the prosecution's case doubtful. Consequently, the court set aside the conviction and acquitted the appellant. The key principle laid down is that an unbroken, unsuspicious, and indubitable chain of safe custody and safe transmission of the recovered narcotics and its representative sample is mandatory to sustain a conviction under narcotics laws, and any failure therein entitles the accused to the benefit of the doubt.

  Questions settled

  • Whether an unbroken chain of safe custody and safe transmission of narcotics and sample parcels is mandatory for proving an offense under the Control of Narcotic Substances Act, 1997?
  • Does a failure by the prosecution to prove the safe transmission of a sample parcel to the forensic laboratory vitiate the chemical examiner's report and lead to acquittal?
  • What is the legal effect of omitting material incriminating evidence from the examination of the accused under Section 342 of the Code of Criminal Procedure, 1898?
  • Can a conviction be sustained when material contradictions exist between the statements of the complainant and recovery witnesses regarding the apprehension and seizure?
  Read full judgment →
• Mst. Shabana Kausar vs The State2024 SHC 410 · Sindh High Court · 2024-05-09Read full judgment →
• Mst. Sehat Bibi d/o late Daulat Khan vs Bahar Khan s/o late Daulat Khan &2024 SCP 124, 2024 SCMR 938 · Supreme Court of Pakistan · 2023-12-01
  inheritanceoral giftfraudulent mutationfemale legal heirco-sharerproperty disputethird-party interest
  Summary & questions settled

  This civil appeal arises from a judgment and decree of the High Court of Balochistan which decreed the appellant's suit for a share in sale proceeds rather than land. The core legal question was whether a female legal heir, wrongfully deprived of her inheritance through a fraudulent oral gift mutation, is entitled to a physical share in the estate's property or merely a portion of the sale proceeds where third-party rights have been created. The Supreme Court held that legal heirs inherit property immediately upon the predecessor's death, and an illegal mutation procured by fraud cannot divest an heir of their absolute statutory share. The Court ruled that the appellant is entitled to her full one-third share out of the entire property left by her late father, rather than the sale price, and that the fraudulent mutation and subsequent transfers based upon it stand cancelled, with adjustments made from the brother's share for any land already sold to third parties.

  Questions settled

  • Whether a legal heir is entitled to receive their actual share from the legacy of their predecessor instead of receiving a share in the sale proceeds when an illegal mutation has been set aside?
  • Can an oral gift mutation executed to the total exclusion of a female legal heir be sustained without the production of best evidence?
  • Does a legal heir inherit property the very moment their predecessor passes away?
  • What is the effect of an illegal and fraudulent inheritance mutation on subsequent property transactions?
  Read full judgment →
• Mst. Sarriya Bibi vs Rpo Sheikhupura, etc.2024 LHC 2550, 2024 PLJ Lahore 789 · Lahore High Court · 2024-04-09Read full judgment →
• Mst. Sara & Another vs Province of Sindh & Others2024 SHC 1198 · Sindh High Court · 2024-10-29Read full judgment →
• Mst. Samrana Nawaz, etc. vs MCB Bank Ltd., etc2024 SCP 166, 2024 CLD 1186, 2024 PLD Supreme Court 873, 2025 PLJ SC 77 · Supreme Court of Pakistan · 2024-05-10
  execution of decreeobjection to salematerial irregularityfinancial institutionsbanking courtstatutory interpretationdeposit of security
  Summary & questions settled

  This matter came before a larger Bench of the Supreme Court of Pakistan to resolve a conflict regarding the interpretation of the second proviso to Rule 90 of Order XXI of the Code of Civil Procedure 1908. The core legal questions were whether an applicant challenging an auction sale must deposit up to twenty percent of the sale amount at the time of filing the application, and how this provision interacts with Section 19(7) of the Financial Institutions (Recovery of Finances) Ordinance 2001. The Court held that the deposit or security is not required at the time of filing; rather, it is a condition precedent that the court must first determine the specific amount or security and direct the applicant to deposit it. The word "entertain" means to adjudicate or consider on merits, not the mere receipt of the application. Furthermore, the Court determined that Section 19(7) of the Ordinance of 2001 is complementary to, and does not exclude, Rule 90 of Order XXI of the Code. The Court overruled contrary precedents, establishing that executing courts must first direct the deposit before dismissing applications for non-compliance.

  Questions settled

  • Whether the second proviso to Rule 90 of Order XXI of the Code of Civil Procedure 1908 requires an applicant to deposit the sale amount at the time of filing the objection petition or only upon the direction of the court?
  • What is the legal meaning of the word 'entertained' in the context of the second proviso to Rule 90 of Order XXI of the Code of Civil Procedure 1908?
  • Does Section 19(7) of the Financial Institutions (Recovery of Finances) Ordinance 2001 exclude the application of Rule 90 of Order XXI of the Code of Civil Procedure 1908 in banking execution proceedings?
  Read full judgment →
• Mst. Samina & others vs Imtiaz and others2024 PHC 378, 2025 PLJ Peshawar 53 · Peshawar High Court · 2024-07-30Read full judgment →
• Mst. Salma Parveen & others vs Muhammad Aslam & others2024 SHC 570 · Sindh High Court · 2024-05-27Read full judgment →
• Mst. Sakina vs Noor Muhammad and 2 others2024 CLC 1353, 2025 PLJ Quetta 28 · Balochistan High Court · 2023-04-12Read full judgment →
• Mst. Sakina Anwar vs The Learned Ro and Another2024 SHC 66 · Sindh High Court · 2024-01-15Read full judgment →
• Mst. Sajida Parveen vs Saqib Mushtaq & others2024 PHC 368 · Peshawar High Court · 2024-11-18Read full judgment →
• Mst. Saima Noreen and others vs The State2024 SCP 171, 2024 SCMR 1310, PLJ 2024 SC (Cr.C.) 319 · Supreme Court of Pakistan · 2024-05-14
  murderstrangulationdishonest improvementsadverse inferenceunnatural conductmedical evidencetranquillizeracquittal
  Summary & questions settled

  This criminal appeal arose from the conviction and death sentences awarded to Mst. Saima Noreen and Muhammad Shafique under Section 302(b)/34 PPC for the strangulation murder of Muhammad Akmal. The High Court had previously converted their death sentences to life imprisonment. The Supreme Court, upon reappraisal of the evidence, identified significant material contradictions between the testimonies of the alleged eyewitnesses (PW-3 and PW-4) and the medical evidence. Key discrepancies included the unexplained presence of tranquilizers in the deceased's system, the failure to produce natural witnesses like the deceased's daughter, and the lack of explanation regarding how a computer-typed FIR application was prepared in the middle of the night. The Court held that the prosecution failed to prove the charge beyond reasonable doubt, noting that the occurrence appeared unwitnessed and the eyewitnesses' conduct was unnatural. Consequently, the Court set aside the convictions, drawing an adverse inference under Article 129(g) of the Qanoon-e-Shahadat Order, 1984, for the non-production of material witnesses.

  Read full judgment →
• Mst. Safia Bibi vs Ex-Officio Justice of Peace/ASJ, Narowal and 3 others2024 MLD 1780 · Lahore High Court · 2023-09-04Read full judgment →
• Mst. Sadia vs I.G Police Sindh and others2024 SHC 1146 · Sindh High Court · 2024-10-01
  habeas corpusillegal detentionsui jurisrecovery of detaineepolice protectioncriminal miscellaneous application
  Summary & questions settled

  Mst. Sadia filed a Criminal Miscellaneous Application under Section 491 of the Code of Criminal Procedure 1898 before the Sindh High Court, seeking the recovery and production of her adopted daughter, Mst. Noshaba, allegedly detained by private respondents. The core legal question concerned the alleged illegal detention and freedom of movement of the detainee. Upon production, the alleged detainee, being a sui juris, expressed her desire to live with the applicant and alleged torture and lack of consent regarding her stay with the respondents. The Court held that since the detainee is a sui juris, she is at liberty to go wherever she wants, and directed the concerned SHO to look into her allegations and ensure she receives due protection against harassment. The key principle laid down is that a sui juris individual possesses the absolute liberty to choose their place of residence and companionship, and the court under habeas corpus jurisdiction will protect such autonomy while directing local authorities to prevent harassment.

  Questions settled

  • Can a habeas corpus application under Section 491 of the Code of Criminal Procedure 1898 be maintained for the recovery of a person allegedly detained by private respondents?
  • Is a sui juris detainee at liberty to choose where to reside and whom to accompany when produced before the court?
  • What directions can the court issue to the police authorities regarding the protection of a sui juris person alleging harassment and illegal detention?
  Read full judgment →
• Mst. Sadia Ishfaq vs Chief Commissioner and 6 others2024 PTD 869 · Lahore High Court · 2024-03-28Read full judgment →
• Mst. Saba Gul etc vs StatePLJ 2024 Cr.C. 1091 · Islamabad High Court · 2024-03-11
  narcotics possessionbenefit of doubtsentencing guidelinesadverse inferencebest evidence rulemandatory minimum sentencecriminal appeal
  Summary & questions settled

  This criminal appeal challenged the conviction of the appellants under the Control of Narcotic Substances Act, 1997, for the possession of narcotics. The core legal question concerned whether the prosecution proved the recovery of narcotics beyond reasonable doubt, particularly given discrepancies regarding the mode of recovery and the failure to produce the clothing from which the drugs were allegedly seized. The Court held that the prosecution failed to establish its case, as the failure to seize and produce the appellants' shalwars—the alleged site of concealment—constituted the withholding of best evidence, warranting an adverse inference under Article 129(g) of the Qanun-e-Shahadat Order 1984. Consequently, the Court set aside the convictions and acquitted the appellants. The judgment emphasized that in narcotics cases, the prosecution must strictly adhere to procedural transparency, including the documentation of recovery proceedings via video evidence and proper chain of custody records. Furthermore, the Court highlighted the urgent need for legislative sentencing guidelines in Pakistan to mitigate the cliff effect of mandatory minimum sentences and ensure proportionality in judicial outcomes.

  Questions settled

  • Does the failure to seize and produce the clothing from which narcotics were allegedly recovered warrant an adverse inference against the prosecution?
  • Can a conviction be sustained in a narcotics case where there are material discrepancies between the recovery memo and the evidence presented in court?
  • Is the prosecution required to produce video evidence of recovery proceedings to ensure transparency in narcotics cases?
  • Does the absence of sentencing guidelines for narcotics offenses lead to disproportionate or arbitrary sentencing?
  Read full judgment →
• Mst. Rozeena Razzaq vs Mirza Moshin Ali Jah and 6 others2024 YLR 405 · Sindh High Court · 2022-10-05
  cognizance of offencepolice reportcheating and fraudforgerycancellation of FIRmagistrate powerscriminal miscellaneous application
  Summary & questions settled

  This criminal miscellaneous application challenges orders passed by Magistrates who declined to take cognizance on a police report under section 173 of the Code of Criminal Procedure 1898, erroneously cancelling the FIR under 'C' class by solely focusing on section 177 of the Pakistan Penal Code 1860 and section 195 of the Code of Criminal Procedure 1898, while ignoring other serious charges. The core legal question was whether the Magistrates erred in refusing to take cognizance and cancelling the FIR without examining the substantive material collected during investigation regarding offences of cheating, fraud, and forgery. The Sindh High Court held that the Magistrates failed to examine the material on record and improperly issued pre-trial judgments ignoring sections 415, 420, 463, and 469 of the Pakistan Penal Code 1860. The Court set aside the impugned orders and directed that the respondent be sent up for trial before the competent court, laying down the principle that a Magistrate cannot ignore substantive penal provisions and investigative material when evaluating a police report.

  Questions settled

  • Whether a Magistrate can decline to take cognizance of an FIR by solely considering a minor provision while ignoring other substantive offences applied in the police report?
  • Does the concealment of a prior marriage and misrepresentation of religious faith during the solemnization of a nikah constitute prima facie cheating and forgery under the Pakistan Penal Code 1860?
  • Is a Magistrate competent to pass a pre-trial judgment instead of examining the material and evidence collected during police investigation under section 173 of the Code of Criminal Procedure 1898?
  Read full judgment →
• Mst. Robina Iqbal vs Additional District Judge etc2024 LHC 5708 · Lahore High Court · 2024-12-11Read full judgment →
• Mst. Rehmat Bibi (through L.Rs.) etc. vs Additional District Judge, Gujranwala etc2024 LHC 1273, 2025 PLJ Lahore 232 · Lahore High CourtRead full judgment →
• Mst. Rehmat Begum vs Mehfooz Ahmed and others2024 SCP 376, 2024 CLD 1254, 2024 PLD Supreme Court 1108 · Supreme Court of Pakistan · 2024-08-09
  rejection of plaintspecific performancepartnership firmOrder VII Rule 11 CPCCompanies Act 2017civil procedurecontractual dispute
  Summary & questions settled

  This civil petition challenged a High Court judgment that set aside the rejection of a plaint in a suit for specific performance of a contract regarding the sale of a 50% partnership share. The petitioner argued that the suit was barred by the Companies Act, 2017, and that the proper remedy was a suit for dissolution of partnership. The Supreme Court dismissed the petition, holding that the plaint cannot be rejected under Order VII Rule 11, Code of Civil Procedure 1908, in a piecemeal fashion or based on the defendant's contentions. The Court affirmed that the Companies Act, 2017, does not apply to non-corporate partnership firms. Furthermore, the Court established that a suit for specific performance is not limited to immovable property and is maintainable for movable property, including partnership shares. Where a suit involves mixed questions of law and fact, the proper approach is to proceed to trial rather than summarily rejecting the plaint. The Court emphasized that the plaint must be read as a whole to determine if a cause of action exists.

  Questions settled

  • Can a plaint be rejected in part or piecemeal under Order VII Rule 11 of the Code of Civil Procedure 1908?
  • Does the Companies Act 2017 apply to a partnership firm that is not a corporate entity?
  • Is a suit for specific performance of a contract to sell a partnership share maintainable without seeking dissolution of the partnership?
  • Should a court reject a plaint under Order VII Rule 11 of the Code of Civil Procedure 1908 when the case involves mixed questions of law and fact?
  Read full judgment →
• Mst. Razia Begum vs Public at Large, etc2024 LHC 4198, 2025 PLD Lahore 40, 2025 PLJ Lahore 42, 2025 CLD 122 · Lahore High Court · 2024-10-01Read full judgment →
• Mst. Rasheeda Bano and another vs Mst. Khursheed Begum and others2024 SHC 258 · Sindh High Court · 2024-03-22Read full judgment →
• Mst. Rani and another vs Province of Sindh & others2024 SHC 1122 · Sindh High Court · 2024-09-26Read full judgment →