Summary: Testimony of a child witness and its admissibility after conducting vior dire; Explanation of Locard's Principle of Exchange and importance of Deoxyribonucleic Asset ("DNA"); Effects of non-submission of buccal swabs of suspect with the PFSA for subsequent DNA comparison with the samples of the victim/deceased as well as non-conducting of DNA comparison of the crime weapon with buccal swabs of the victim/deceased to connect the same with the crime;

Summary: Government Delay Is No Excuse, Limitation Binds the State Equally. Ratio Decidendi: In litigation, the statutory period of limitation is binding upon all litigants alike, including public functionaries. Courts are not empowered to condone delay merely because the appellant is a government department. The rationale behind limitation laws, as affirmed by the superior courts, is to ensure procedural discipline, avoid stale claims, and uphold the finality of judicial decisions. In this case, the government?s application under Section 5 of the Limitation Act, 1908, seeking condonation of a 50-day delay in filing a Regular First Appeal, failed to furnish any specific or sufficient cause justifying the lapse. The plea that delay occurred due to internal administrative procedures and departmental approvals was found to be vague, stereotypical, and unsupported by any documentary record showing when the necessary approvals were initiated or obtained. The Lahore High Court emphasized that public departments, despite having legal officers and established mechanisms, routinely take shelter behind generalized claims of bureaucratic delays?an approach explicitly condemned by the Hon?ble Supreme Court in Regional Police Officer, D.G. Khan vs. Riaz Hussain Bukhari (2024 SCMR 1021). The Apex Court categorically held that ?mechanical and unpersuasive justification of administrative delays? cannot be treated as sufficient cause, and that each day?s delay must be properly explained. In the absence of such explanation, especially where no date of copy issuance or sanction approval was provided, the Court cannot afford leniency solely because the appellant is a state entity. Reliance placed on previous precedents like Muhammad Bashir vs. Province of Punjab (2003 SCMR 83) and Government of Balochistan vs. Muhammad Ali (2007 SCMR 1574) was found misplaced, as those cases reiterate rather than relax the strict requirement to observe limitation. Consequently, the Court dismissed both the application for condonation of delay and the appeal itself in limine. The judgment reinforces that the government must act with the same diligence and legal accountability as private citizens, and cannot seek special indulgence in derogation of the law?s express timelines.

Summary: Writ Petition under Article 199 of Constitution of Islamic Republic of Pakistan, 1973?section 17 and 25 of the Guardian and Wards Act, 1890--- Mutual voluntarily handing over custody of minor to adoptive parents--- After six years real parents seek restoration of the custody--- Held that in the presence of biological real parents of the minor, the custody of the minor girl cannot be handed over to adopted parents as the welfare of the minor best lies with the real parents. Writ Petition of adoptive parents for custody of minor is dismissed.

Summary: Pakistan Rangers can exercise powers under sections 21, 22, 23, 37(2) & 38 of CNSA, 1997 within the areas of their jurisdiction. 716Murder Reference 23-23 THE STATE VS ATIF PERVAIZ Mr. Justice Muhammad Tariq Nadeem 19- 02- 2025 2025 LHC 639

Summary: "Cruelty to child" does include forcing for begging or vagrancy. 715Crl. Misc. 3952/25 Maqbool Ali Vs The State etc. Mr. Justice Muhammad Amjad Rafiq 20- 02- 2025 2025 LHC 376 2025 YLR 2801 (Lahore)

Summary: The pivotal issues for determination before this Court are as under: i. Whether the respondents who are employees of the petitioner-Parks & Horticulture Authority ("PHA"), on daily wages mostly for more than 10 years, fall under the definition of ?workman'? ii. If the answer to the above question is in affirmative, what is the distinction between the regularization of service and the declaration as a permanent workman and whether the Labour Appellate Tribunal was justified in directing the regularization of services of the respondents? Held that based on the legislative definitions under the Punjab Industrial Relations Act, 2010 ("PIRA"), the Industrial and Commercial Employment (Standing Orders) Ordinance, 1968 ("Ordinance") and the judicial pronouncement of Supreme Court of Pakistan in case of Province of Punjab through Secretary Communication and Works Department and others v. Ahmad Hussain (2013 SCMR 1547), I am of the opinion that for the purposes of the Ordinance, the petitioner-PHA is a commercial establishment and the respondents are workmen. Further held that as permanent workmen, the employees of Petitioner-PHA are entitled to certain statutory rights, as held in case of Ahmad Hussain, supra. These rights include job security, fair wages, gratuity and the ability to form or join trade unions whereas Labour Courts do not have the authority to introduce the regularization, which applies to the contractual, ad-hoc, or daily wage employees in public authorities under the civil service rules and/or a specific government policy. Courts cannot lose sight of the fact that the workmen engaged in non-administrative roles, are covered by the Ordinance and the PIRA. 714Crl. Misc. 78626/24 Jannat Gull Vs The State etc. Mr. Justice Muhammad Amjad Rafiq 20-02- 2025 2025 LHC 368

Summary: If it is claim of the prosecution that first information report (FIR) was recorded earlier and thereafter inquest report was prepared, then number of the first information report (FIR) must have been mentioned at the first page of inquest report and absence of the same reflects that FIR was not recorded earlier, rather with the delay, however, ante-time was mentioned in the record which minimizes evidentiary value of first information report and said fact is ultimately fatal for the prosecution. 713Labor 78987/23 Parks & Horticulture Authority through its D.G Vs Punjab Labour Appellate Tribunal etc Mr. Justice Anwaar Hussain 20- 02- 2025 2025 LHC 463

Summary: The prosecution case is hinges upon the circumstantial evidence and DNA report. It is well settled by now that in such like cases, prosecution is required to link each circumstance to the other in a manner that it must form a complete, continuous and unbroken chain of circumstances, firmly connecting the accused with the alleged offence and if any link is missing then obviously benefit is to be given to the accused. DNA report is not reliable if safe transmission of sealed parcels in the office of the Punjab Forensic Science Agency has not been proved. Accused acquitted of the charge. 712Jail Appeal 27878/22 Zafar Iqbal Ilam Din Vs The State The Chief Justice 20- 02- 2025 2025 LHC

Summary: Scope of Section 34 of the Civil Procedure Code, 1908. 711Crl. Appeal- Against Conviction- PPC 175-21 MUHAMMAD ARIF VS THE STATE ETC. Mr. Justice Muhammad Tariq Nadeem 20- 02- 2025 2025 LHC 762

Summary: The fundamental issue for consideration before this Court is to determine whether some of the legal heirs of a deceased donor are clothed with locus standi for filing of an application under Section 12(2), CPC against the judgment, determining the validity of gift, passed in a suit instituted by another legal heir?donee (respondent No.5) against the donor, during the lifetime (of the donor), on the ground that the applicants were deprived of inheritance by not being made party to the suit. Held that mere non-mentioning of certain family members (the applicants and proforma respondent No.6), does not amount to fraud unless it demonstrably alters the fundamental basis of a judicial decision, which is not the position in the present case inasmuch as the dispute was between the respondent/petitioner and respondents No.2 to 4, to whom the property was given away as gift although part thereof (64-Kanal) was earlier given to the respondent/petitioner and the deceased Muhammad Aameen?the donor, actively participated in the legal proceedings. Moreover, once the order dated 19.05.2014, in C.R. No.1593 of 2005 was passed in favour of the respondent/petitioner, the same was never challenged by him before the Supreme Court of Pakistan as admittedly, it was only respondents No. 2 to 4 who filed CPLA No. 1733-L of 2014. Meaning thereby that predecessor of the applicants conceded to the impugned decree dated 19.05.2014 and the applicants can only step into his (their predecessor/donor) shoes. In short, the donor having actively participated in the prior legal proceedings and conceded the validity of the gift transaction, estops his legal heirs from raising belated claims under the pretext of fraud. 710Civil Revision 69585/23 Shaheen Baig Vs Zaheer Ahmed Loan Mr. Justice Anwaar Hussain 20-02- 2025 2025 LHC 906