District Judiciary KPK

20/07/2026

Promotion of 13 Civil Judges to the Post of Senior Civil Judges.

09/07/2026

Employment:
The Constitutional Status of Judges and the Imperative of Judicial Independence under Islamic Law and International Judicial Standards.
*******************************************

The judiciary is one of the three fundamental organs of the State. Unlike ordinary public servants, a judge does not serve the executive government or any superior administrative authority in the discharge of judicial functions. A judge serves only the Constitution, the law, and the dictates of an impartial conscience. Judicial office is therefore a constitutional trust rather than an employment relationship. This distinction is essential for preserving the rule of law, judicial independence, and public confidence in the administration of justice.

The concept that a judge is not an employee is deeply rooted in constitutional theory. An employee ordinarily works under the direction and control of an employer who may supervise, evaluate, and direct the manner in which duties are performed. A judge, however, exercises judicial power independently. Neither the executive, the legislature, nor even superior judges may dictate the outcome of a case. Judicial accountability exists, but it is exercised within the framework of the Constitution and the law, not through an employer-employee relationship.

Islamic jurisprudence has long recognized the distinctive character of judicial office. The institution of Qadha (judiciary) is regarded as a sacred trust (Amanah) entrusted to persons possessing integrity, knowledge, wisdom, and courage. The Holy Qur'an commands:
"Indeed, Allah commands you to render trusts to whom they are due, and when you judge between people, judge with justice." (Surah An-Nisa 4:58)

This verse establishes that judging is the discharge of a divine trust rather than the performance of ordinary employment. Likewise, Allah Almighty commands:
"O you who believe! Stand firmly for justice as witnesses for Allah, even if it be against yourselves or parents or relatives." (Surah An-Nisa 4:135)

The Qur'anic command emphasizes that the judge's loyalty is to justice alone. Personal interests, institutional pressures, political influence, or administrative preferences cannot lawfully influence judicial decision-making.
The Sunnah equally demonstrates the gravity of judicial office. The Prophet Muhammad (peace be upon him) warned that judging between people is an immense responsibility requiring knowledge, honesty, and fairness. Classical Muslim jurists consistently treated the office of the Qadi as an independent institution whose authority originated from the obligation to establish justice under Islamic law rather than from obedience to rulers. Although rulers appointed judges, they were not entitled to interfere with judicial decisions. Prominent jurists such as Imam Abu Hanifah, Imam Malik, Imam Al-Shafi'i, and Imam Ahmad ibn Hanbal emphasized that a judge must refuse any instruction inconsistent with justice and divine law.

The Islamic conception of judicial independence therefore predates modern constitutional theory. The Qadi was expected to resist pressure from rulers, influential persons, tribal leaders, and wealthy litigants alike. Numerous historical incidents from the era of the Rightly Guided Caliphs illustrate rulers themselves appearing before judges as ordinary litigants, thereby affirming that judicial authority stands above executive influence when administering justice.

Modern international law equally recognizes that judges are constitutional office-holders rather than employees of the executive. The United Nations Basic Principles on the Independence of the Judiciary (1985) provide that judicial independence shall be guaranteed by the State and that judges shall decide matters impartially on the basis of facts and law without restrictions, improper influences, inducements, pressures, threats, or interference from any quarter. These principles further require adequate security of tenure, remuneration, and conditions of service so that judges remain free from external pressures.

The Bangalore Principles of Judicial Conduct (2002) reinforce this understanding by identifying six universal judicial values:

Independence, Impartiality, Integrity, Propriety, Equality, and Competence with Diligence. The very first value independence declares that judicial independence is indispensable to the rule of law and to a fair trial. Independence belongs not merely to judges personally but exists for the benefit of society. Every litigant is entitled to have disputes decided by a judge who is free from influence, fear, favour, or administrative control concerning judicial outcomes.

The Bangalore Principles also recognize that judges may be subject to administrative arrangements relating to court management. However, administrative supervision must never compromise judicial independence or influence the exercise of judicial discretion. A judge may comply with lawful administrative requirements concerning attendance, case management, budgeting, or institutional discipline, yet no authority may interfere with judicial reasoning, assessment of evidence, interpretation of law, or the ultimate decision in any case.

The distinction between an employee and a judge is therefore both legal and functional. An employee carries out assigned duties under managerial supervision and may receive instructions regarding the manner in which work is to be performed. A judge, by contrast, cannot lawfully receive directions concerning how a dispute should be decided. Judicial reasoning is governed exclusively by the Constitution, legislation, precedent, evidence, and conscience informed by law.

Judicial accountability should never be confused with executive control. Judges remain accountable through transparent judicial proceedings, appellate review, constitutional mechanisms, ethical codes, and lawful disciplinary procedures for misconduct. Accountability strengthens judicial legitimacy, whereas subordination to executive authority destroys judicial independence. Thus, independence and accountability are complementary rather than contradictory principles.

Constitutional democracies around the world consistently recognize that judges occupy an independent constitutional office. Their salaries, tenure, transfer mechanisms, disciplinary safeguards, and retirement arrangements are structured to preserve independence from political and administrative influence. International standards reject any system that permits evaluation of judges in a manner that pressures them to decide cases according to numerical targets, political expectations, or institutional preferences instead of legal merit.

This principle assumes particular significance in systems employing performance evaluation. Disposal statistics, efficiency indicators, and administrative performance may legitimately form part of institutional management. However, they must never become instruments capable of influencing judicial decision-making or encouraging judges to sacrifice quality, fairness, or legal correctness merely to satisfy performance indicators. Judicial excellence depends not only upon the quantity of cases disposed of but also upon the quality, integrity, independence, and legality of judicial decisions.

The public's confidence in the judiciary depends upon the visible independence of judges. Citizens approach courts believing that disputes will be decided solely according to law. If judges are perceived as employees answerable to executive authorities or administrative superiors regarding judicial decisions, public confidence in the justice system is inevitably weakened. Judicial independence therefore protects not the personal privilege of judges but the fundamental right of every citizen to receive a fair and impartial hearing.

In conclusion, both Islamic jurisprudence and modern international legal standards affirm the same enduring principle: a judge is not an employee in the ordinary legal sense. Judicial office is a constitutional, legal, and moral trust. The judge owes allegiance to justice, the Constitution, and the rule of law not to administrative convenience, political authority, or institutional pressure. The Qur'anic conception of Amanah, the classical institution of Qadha, the United Nations Basic Principles on the Independence of the Judiciary, and the Bangalore Principles of Judicial Conduct collectively establish that judicial independence is indispensable for safeguarding justice. A judiciary that is independent in both appearance and reality remains the strongest guarantee of liberty, equality, constitutional governance, and public confidence in the rule of law.

09/07/2026

Doctrine of Lis Pendens: Effect of Transfer of Property During the Pendency of Litigation



The doctrine of Lis Pendens is one of the fundamental principles governing the law relating to transfer of immovable property. The doctrine is founded upon the principle that the subject matter of litigation should remain unaffected by any transfer or alienation made during the pendency of judicial proceedings. Its primary objective is to preserve the authority of the Court, protect the rights of litigating parties, and prevent the defeat of justice through transfers made while a dispute is awaiting adjudication.

In Pakistan, this equitable doctrine has been codified in Section 52 of the Transfer of Property Act, 1882, which provides that where a suit or proceeding concerning rights in immovable property is pending before a competent Court, the property cannot be transferred or otherwise dealt with so as to affect the rights of any party under the decree or order ultimately passed by the Court, except with the permission of the Court.

Historical Origin and Jurisprudential Basis

The doctrine of Lis Pendens is derived from the Latin maxim "Pendente lite nihil innovetur," meaning "During litigation, nothing new should be introduced." The rule was developed in the Courts of Equity to ensure that litigation is not rendered futile by successive transfers of the disputed property.

The doctrine does not invalidate the transfer itself; rather, it makes the transfer subordinate to the rights determined by the Court in the pending litigation. It is based upon considerations of public policy, judicial efficiency, and fairness, ensuring that judicial proceedings are not frustrated by private transactions.

Statutory Recognition under Section 52 of the Transfer of Property Act, 1882

Section 52 provides that where any suit or proceeding is pending in which any right to immovable property is directly and specifically in question, the property cannot be transferred or otherwise dealt with by any party so as to prejudice the rights of the other party under the decree that may ultimately be passed.
The provision does not prohibit transfer during litigation. Instead, it declares that such transfer remains subject to the final decision of the Court. Consequently, the transferee acquires no greater title than that possessed by the transferor and remains bound by the decree eventually passed.

Essential Ingredients of the Doctrine

For the application of the doctrine of Lis Pendens, the following conditions must ordinarily exist:
A suit or judicial proceeding must be pending before a Court of competent jurisdiction.
The litigation must directly and specifically involve rights in immovable property.
The transfer must be made during the pendency of the litigation.
The transfer must be effected by one of the parties to the litigation.
The transfer must be capable of affecting the rights of the opposing party under the decree.
Once these conditions are fulfilled, Section 52 automatically becomes operative.

Status of a Transferee Pendente Lite

A person who purchases property during the pendency of litigation is known as a Transferee Pendente Lite. Such a purchaser merely steps into the shoes of the vendor and acquires only those rights that the vendor lawfully possesses.
The transferee cannot claim any superior or independent title. If the vendor ultimately loses the case, the purchaser is equally bound by the decree. The transferee cannot avoid the legal consequences merely because he was not originally impleaded as a party to the suit.
This principle is also consistent with the maxim "Nemo dat quod non habet," meaning that no one can transfer a better title than he himself possesses.

Transfers Made in Violation of Injunction Orders

Where the Court has already granted an injunction restraining alienation of the disputed property, any transfer made in violation of such order receives no legal protection against the decree ultimately passed.
A purchaser who knowingly or unknowingly acquires property in breach of a subsisting injunction cannot claim immunity from the judicial determination. Such transfer remains subject to the authority of the Court and cannot prejudice the rights already under adjudication.
Bona Fide Purchaser and the Doctrine of Lis Pendens
Ordinarily, the law protects a bona fide purchaser acting in good faith and for valuable consideration. However, the doctrine of Lis Pendens constitutes an exception to this principle.
Even a purchaser acting honestly, without actual knowledge of the pending litigation, cannot escape the operation of Section 52. The doctrine is based upon constructive notice arising from the pendency of litigation itself. Consequently, every purchaser is deemed to purchase subject to the outcome of pending proceedings.

Relationship with Section 12(2) of the Code of Civil Procedure

A purchaser during litigation sometimes seeks to challenge the decree under Section 12(2) of the Code of Civil Procedure, alleging that he was not impleaded in the original suit.
Such an objection is generally unsustainable unless it is established that the decree itself was obtained through fraud, misrepresentation, or deception practised upon the Court. Fraud merely between the parties, without misleading the Court, does not ordinarily attract Section 12(2).
Therefore, a transferee pendente lite cannot simply seek annulment of the decree on the ground that he was not impleaded as a party.
Judicial Interpretation
The superior Courts of Pakistan have consistently interpreted Section 52 as protecting the sanctity of judicial proceedings. The Courts have repeatedly held that a transfer made during the pendency of litigation neither defeats the pending suit nor diminishes the jurisdiction of the Court. Rather, the transferee remains bound by the ultimate decree in the same manner as the transferor.
The Courts have further emphasized that the doctrine serves public policy by discouraging fraudulent transfers, preventing multiplicity of litigation, and safeguarding the administration of justice.

Practical Importance

The doctrine of Lis Pendens has immense practical significance in property litigation. It prevents litigants from frustrating judicial proceedings by transferring disputed property during the pendency of the suit. It also protects successful litigants from being compelled to initiate fresh proceedings against every subsequent purchaser.
For prospective purchasers, the doctrine underscores the importance of conducting comprehensive due diligence before purchasing immovable property. A prudent purchaser should verify not only the title documents and revenue records but also whether any civil litigation concerning the property is pending before a competent Court.

Conclusion

The doctrine of Lis Pendens represents a cornerstone of property jurisprudence and civil procedure. Codified in Section 52 of the Transfer of Property Act, 1882, it ensures that the jurisdiction of the Courts and the rights of litigating parties are not undermined by transfers made during the pendency of litigation. A transferee pendente lite acquires no better title than that of the transferor and remains fully bound by the decree eventually passed by the Court. Likewise, the mere fact that such purchaser was not impleaded in the original proceedings does not entitle him to challenge the decree under Section 12(2) of the Code of Civil Procedure, unless fraud practised upon the Court is clearly established. The doctrine therefore promotes certainty, judicial efficiency, and the effective administration of justice .

07/07/2026

07/07/2026

Foreign Public Documents, Certified Copies and Their Admissibility in Evidence under the Qanun-e-Shahadat Order, 1984

With the growth of international migration, foreign investment, overseas employment, cross-border commercial transactions, and international family relations, Pakistani courts increasingly encounter documents issued by foreign authorities. These include birth and death certificates, marriage certificates, divorce decrees, educational credentials, company records, land records, powers of attorney, wills, and judgments of foreign courts. The admissibility and evidentiary value of such documents are governed primarily by the Qanun-e-Shahadat Order, 1984 (QSO), read with the Code of Civil Procedure, 1908, where applicable. The QSO provides a complete framework regulating the proof of documentary evidence, including foreign public documents and certified copies thereof.

Under Articles 75 to 79 of the QSO, documents must ordinarily be proved by primary evidence, namely the original document itself. However, recognizing the practical impossibility of producing originals maintained abroad, the law permits secondary evidence in specified circumstances. Certified copies of public documents constitute one of the recognized forms of secondary evidence, provided the statutory requirements are strictly fulfilled. Thus, while the original document remains the best evidence, the law makes an exception for certified copies of public documents maintained by competent public authorities.

The distinction between public and private documents assumes considerable importance in determining the mode of proof. Article 85 of the QSO defines public documents to include the acts or records of the acts of sovereign authorities, official bodies, tribunals, and public officers, whether legislative, judicial, or executive, of Pakistan or of a foreign country. Consequently, official records prepared by foreign governments or foreign courts are public documents within the meaning of the QSO. Article 86 further clarifies that every document which does not fall within the definition of a public document is deemed to be a private document.

Since public documents remain in the custody of public authorities, the law does not ordinarily require production of the original in court. Article 87 entitles every person having a right to inspect a public document to obtain a certified copy from the officer having lawful custody thereof. Such certification must bear the signature, designation, date, and official seal of the certifying officer, thereby assuring the Court that the copy faithfully reproduces the original record.

Article 88 expressly provides that certified copies may be produced in proof of the contents of public documents of which they purport to be copies. This provision is of immense practical significance because it dispenses with the necessity of summoning original public records from foreign jurisdictions. Nevertheless, Article 88 merely renders the certified copy admissible; it does not make the contents conclusive. The Court must still determine the evidentiary weight of the document in light of the entire evidence available on the record.

The principal provision governing proof of foreign public documents is Article 89 of the QSO. This Article prescribes different modes of proving various classes of official documents. In relation to foreign public documents, Article 89 provides that such documents may be proved by producing the original or by producing a copy certified by the lawful keeper of the original, accompanied by a certificate under the seal of a Notary Public, or a Pakistani Consul, or a Pakistani diplomatic agent, certifying that the copy has been duly certified by the officer having legal custody of the original. Additionally, the Court must be satisfied that the document is a public document according to the law of the foreign country from which it originates. This additional safeguard reflects the legislative intent to ensure authenticity before foreign official records are acted upon by Pakistani courts.

Where the document sought to be produced is a certified copy of a foreign judicial record, Article 94 assumes special significance. It authorizes the Court to presume the genuineness of a document purporting to be a certified copy of a judicial record of a foreign country, provided it is certified in the manner commonly in use under the law of that country. The presumption created by Article 94 is limited to the authenticity of the copy and the official character of the certifying officer. It does not amount to a presumption regarding the truth of the facts recorded in the document or the correctness of the foreign court's findings.

A clear distinction must always be maintained between admissibility and proof. Admissibility merely determines whether the document can be received in evidence. Proof concerns whether the document has been established to the satisfaction of the Court as genuine and reliable. Likewise, even a duly proved document may not necessarily be accepted as truthful if the surrounding circumstances cast doubt upon its credibility. Admission of a certified copy, therefore, neither concludes the controversy nor dispenses with the burden of proving the facts contained therein.

The burden initially rests upon the party relying on the foreign public document to establish its public character, lawful certification, proper authentication, relevance, and compliance with the requirements of the QSO. Once these foundational facts have been established, the statutory presumptions under Articles 88, 89, or 94 may operate, shifting the evidentiary burden to the opposing party to rebut the authenticity or reliability of the document.

Where the foreign public document is not written in English or Urdu, it should be accompanied by a true and accurate translation prepared by a competent translator. If the correctness of the translation is disputed, the translator may be required to appear before the Court to verify its accuracy. Without an authenticated translation, the Court cannot properly appreciate the contents of the document.

When the foreign document is a judgment of a foreign court, its admissibility under the QSO does not automatically render it enforceable in Pakistan. The Court must further examine whether the judgment satisfies the conditions laid down in Sections 13 and 14 of the Code of Civil Procedure, 1908, relating to the conclusiveness and presumptions attached to foreign judgments. Thus, compliance with the QSO and compliance with the CPC are complementary rather than mutually exclusive requirements.

In deciding objections to foreign public documents, the Court should carefully distinguish between objections relating to admissibility and objections relating to evidentiary value. Defects in authentication, certification, or compliance with Article 89 may affect admissibility itself, whereas challenges relating to the truth, correctness, or probative force of the document ordinarily concern its evidentiary weight. This distinction prevents unnecessary exclusion of relevant evidence while preserving the right of the opposite party to challenge its credibility during trial.

The cumulative reading of Articles 75 to 79, 85, 87, 88, 89 and 94 demonstrates that the Qanun-e-Shahadat Order establishes a coherent statutory scheme balancing practical necessity with judicial caution. It facilitates the reception of official foreign records through certified copies while insisting upon adequate safeguards against fraud, fabrication, and unauthorized certification. Pakistani courts are therefore required not only to determine whether the statutory conditions for admissibility have been fulfilled but also to assess, after considering the entire evidence, the weight that should ultimately be attached to the foreign public document.

In conclusion, a certified copy of a foreign public document is not inadmissible merely because it originates outside Pakistan. If it is duly certified by the lawful custodian, authenticated in accordance with Article 89 where required, supported by the statutory presumptions available under the QSO, and otherwise relevant to the issues in controversy, it is admissible in evidence. Nevertheless, admissibility does not dispense with proof, nor does it make the contents conclusive. The Court must independently evaluate the authenticity, reliability, and probative value of the document in accordance with the principles embodied in the Qanun-e-Shahadat Order, 1984, and other applicable laws.

05/07/2026

“Section 12(2) of CPC”

It is a very important section in the Code of Civil procedure, (C.P.C) which is usually filed an application by an aggrieved person for setting aside a final judgment, decree or order, which is passed by a court due to fraud, misrepresentation or want of jurisdiction.

▶️ When did it insert in C.P.C?
It was inserted in the C.P.C. through the Ordinance X of 1980.

▶️Grounds of Application:
Fraud, misrepresentation or want of jurisdiction are grounds for filing of application under this section, but if these grounds are missing in an application, then it is not maintainable. However, the superior courts of Pakistan had held decision on this issue as follows: “12(2) C.P.C. Where the material on record failed to indicate that there was any element of fraud or misrepresentation in the matter or there was any want of jurisdiction of the court, provision of S 12 (2) of C.P.C would not attract”. (1)

▶️Forum of an Application:
Application under section 12 (2) C.P.C can be filed before a court which passed a final judgment, decree or order.
However, the Superior Courts of Pakistan had held decision on this issue as follows:
“Application under section 12(2), C.P.C. was to be filed before the court, which was last in series except where an appeal revision or leave to appeal was dismissed on any ground except merit”.(2)
“Where the decree/order of a forum below has been affirmed by the higher forum on merits, both on points of fact and law, it should be such decree/order ( of higher forum) which attained the status of final decree/order within purview of section 12(2) C.P.C.”(2)
“Where a decree-order has been modified or reserved by the Appellate or Revisional Court, it shall be such decree-order (of Appellate or Revisional Court), which will be final in nature for the purpose of section 12(2) C.P.C. and accordingly application could only be initiated before such forum which had altered the verdict”.(3)
“Judgment and decree of a court can only be assailed before that court, when aggrieved party seeks to have it set aside on the ground that either the party was not served or that the same was obtained through misrepresentation, fraud etc”.(4)
“If Supreme Court merely affirms judgment or order of High Court by refusing leave the final judgment in terms of section 12(2) C.P.C. will be of the High Court and not of the Supreme Court, and if however, Supreme Court reverses a judgment of a High Court and records finding on question of fact or law contrary to what was held by the High Court, in that event the final judgment or order would be of the Supreme Court for the purposes of section 12(2) C.P.C.”.(5)
“Court having finally adjudicated matter could entertain application under section 12 (2) C.P.C.” (6)

▶️New suit is barred:
A new suit is barred against a final judgment, decree or order, which is procured by fraud, misrepresentation or want of jurisdiction from a court.
Hence, it is the precedents of the Superior Courts of Pakistan on this point as follows:
“Section 12(2), C.P.C. had barred independent suit for challenging a decree or judgment on basis of fraud and it had provided a speedy remedy for cancellation of such a decree”.(7)

▶️It is similar to a New Suit:
Application under this section is equal to a new suit. Hence, it is the precedents of the superior courts of Pakistan on this point as follows:
“Under section 12 (2), C.P.C. was a substitute for a separate/ independent suit for setting aside of a decree”.(8)
“An application under section12(2), C.P.C., 1908 may be treated as a suit once such application is admitted for full hearing and when not dismissed summarily in accordance with prevailing facts and circumstances of the case, then the impugned decree loses its effectiveness or status”. (9)

▶️Who can file this application?
Any aggrieved person can be filed an application under section 12 (2) C.P.C for setting aside a final judgment, decree or order on basis of fraud, misrepresentation or want of jurisdiction. However, any person who is not aggrieved by a final judgment, decree or order of a court, he cannot file an application under section 12 (2) C.P.C. as according to precedents of the superior court of Pakistan as follows:
“Applicants thus were not a aggrieved by the impugned orders and they could not file the present applications under section 12(2)”. (10)

▶️It decides after recording of evidence:
“Application under section 12(2) C.P.C. containing serious allegations of forgery and fraud could not be decided without recording of evidence”.(11)
“Framing of issues or recording of evidence in proceedings under section 12(2), C.P.C. is not the rule of law….Court is not bound to undergo such exercise in every matter under section 12(2)”. (12)

▶️ Order 7, rule 11, C.P.C. is not applicable:
“12(2) C.P.C., such application could not be treated as plaint under Order 7, rule 11 C.P.C., thus court could not reject the same under order 7 rule C.P.C.
Order of trial court rejecting such application would nullity in the eyes of law, whereabouts revision petition, if filed would be maintainable”. (13)

▶️Revision:
“Order passed under section 12 (2) C.P.C. does not culminate in decree, but remains simply an order passed on a miscellaneous application, no appeal lies against such order, only remedy of revision under section 115 C.P.C. can be available of.
Such order is not appealable under section 104 C.P.C. or XLIII, rule 1 C.P.C.” (14)

▶️Limitation:
“Law having not provided any limitation for filing an application under section 12(2) C.P.C, residuary Article 181 of limitation Act, 1908 would govern it where under limitation three years from the date of knowledge from order under attack”.(15)
“No limitation provided for moving the court under section 12(2) for setting aside a decree obtained through fraud and deception however, it has been ruled that article 181 limitation Act, 1908 would be applicable which had provided 3 years limitation to an aggrieved person from the date when he got knowledge about such a decree or judgment”.(16) “When ground of fraud and misrepresentation were taken in such an application, then there would be no limitation for its filing”. (17)
“Application under section 12 (2) C.P.C…. Limitation imposed by law on filing of suit would apply to such application for being a substitute for a suit”.(18) “Limitation for filing an application under section 12 (2) C.P.C. was three years and present application was time barred…. No application for condonation of delay has been filed to justify the delay of each and every day…. Application under section 12 (2) C.P.C. was dismissed in circumstances”.(19)

▶️References:
1. PLD 2009Lahore 63; PLD 2010 Karachi 400;
2. PLD 2015 Peshawar 39
3. PLD 2013 SC 478
4. 2011 SCMR 1854
5. 1993 SCMR 1171, 1999 SCMR 1516, PLD 2009 Karachi 123,
6. PLD 2013 Lahore 51
7. PLD 2015 HC (AJ&K) 7
8. 2015 SCMR 615, 2015 CLC 594 (Sindh)
9. PLD 2014 Peshawar 1
10. 2015 CLD 390 (Sindh)
11. 2008 SCMR 236
12. PLJ 2008 Lahore 492
13. PLD 2013Lahore 51
14. 2004 YLR 1066, 1997 MLD 2003, PLD 2002 Peshawar 84,
15. 2007 CLC 1507, 2005 YLR 3030, 1993 SCMR 2096
16. PLD 2015 HC (AJ&K) 7, 2008 CLC 164 (Lahore)
17. PLD 2013 Lahore 51
18. 2011 SCMR 551
19. 2015 YLR 276 (Sindh)