Summary: (a) Criminal Procedure Code (V of 1898):----S. 265-K---Acquittal at preliminary stage---Scope and limitations---Trial Court acquitted accused before framing of charge under S. 265-K, Cr.P.C. on ground that PFSA report lacked mandatory protocols under Rule 6 of Government Analyst Rules, 2001---Held, premature acquittal without recording evidence or tendering analyst report was erroneous---Even if protocols in PFSA report were disputed, prosecution could invoke S. 510, Cr.P.C. to summon analyst or seek clarification under Ss. 11 & 12 of the Punjab Forensic Science Agency Act, 2007---Trial Court failed to grasp the statutory philosophy behind "probability of conviction", which requires deeper scrutiny beyond technicalities at pre-trial stage---Judgment of acquittal set aside and case remanded for trial.Cited Cases:• President National Bank of Pakistan v. Waqas Ahmed Khan 2023 SCMR 766• Model Customs Collectorate v. Aamir Mumtaz Qureshi 2022 SCMR 1861• State v. Raja Abdul Rehman 2005 SCMR 1544• Raja Muhammad Yasin v. Zaitoon Begum 1993 CLC 2448(b) Control of Narcotic Substances Act, 1997:----S. 9(c)---Charas recovery---PFSA report containing test protocols---Admissibility and sufficiency---PFSA Analysis Report showed full testing protocols including: (i) Analytical balance for weight, (ii) Chemical spot test, and (iii) Gas Chromatography–Mass Spectrometry---Such protocol, though not in suggested template of Qaiser Javed Khan case (PLD 2020 SC 57), was deemed sufficient in several Supreme Court rulings to satisfy Rule 6 of Government Analyst Rules, 2001---Trial Court erred in rejecting report solely for not following template format.Cited Cases:• Shazia Bibi v. The State 2020 SCMR 460• Mushtaq Ahmad v. The State 2020 SCMR 474• Asmat Ali v. The State 2020 SCMR 1000• Qaiser Javed Khan v. The State PLD 2020 SC 57(c) Control of Narcotic Substances (Govt. Analyst) Rules, 2001:----R. 6---Compliance with protocol requirement---Pending interpretation before Supreme Court---Question of mandatory protocol format under Rule 6 still sub judice before Larger Bench of the Supreme Court in Baz Khan case---Held, Trial Courts must exercise caution in rendering acquittals based on evolving jurisprudence when matter is undecided---Existing PFSA formats accepted in multiple SC cases as compliant for narcotic drug identification.Cited Cases:• The State through ANF v. Imam Bakhsh 2018 SCMR 2039• Khair-ul-Bashar v. The State 2019 SCMR 930• Minhaj Khan v. The State 2019 SCMR 326(d) Criminal Procedure Code (V of 1898):----S. 423---Appeal against acquittal---Hearing in absence of accused---Maintainability---Accused/respondent remained absent despite notice---Held, appeal against acquittal can be decided in his absence under S. 423, Cr.P.C.---Trial cannot be indefinitely delayed due to abscondence---Court justified in deciding matter without presence of respondent.Cited Case:• Hayat Bakhsh v. The State 1981 SCMR 1 = PLD 1981 SC 265----Disposition:Appeal allowed; acquittal judgment dated 06.01.2020 set aside; case remanded for trial on merits.

Summary: Khyber Pakhtunkhwa Consumers Protection Act (VI of 1997)--- ----Ss.13(2), 11B & 17(2)---Consumer---Filing of complaint regarding exaggerated amount in electricity bill---Limitation---Application for rejection of complaint being time barred filed by the respondent (Electricity Supply Company) was accepted by the Consumer Court---Validity---Khyber Pakhtunkhwa Consumers Protection Act, 1997 (Act) was promulgated to provide for healthy growth of fair commercial practices, the promotion and protection of legitimate interest of consumers and speedy redressal of their complaints and matters arising out of or connected therewith, which purpose and object clearly envisages that the enactment is consumer beneficial and as such, it requires to be treated in the same manner in order to provide and extend the consumers a fair chance qua protection of their legitimate rights---Section 13(2) of the Act provides that a complaint shall be submitted before the Consumer Court within 10 days of the sale, delivery or rendering of the service---Appellant had filed the complaint against the respondent-PESCO before the Consumer Court on 03.08.2022, while the disputed electricity bill was payable till 05.08.2022, thus, in the attending circumstances of the case, the question of limitation would at best be seen at the time of final determination of the matter by the Consumer Court; particularly, in the circumstances, when the first proviso to S.13(2) has conferred discretion upon the court to entertain a complaint filed beyond ten days within such time as it may allow if it is satisfied that there is sufficient cause for not filing the same within the specified time subject to the provision of second proviso---Consumer Court was held to have committed gross illegality and jurisdictional error in rejecting the complaint of the appellant---Appeal was accepted, in circumstances. Muhammad Umar Saeed for Appellant. Hamid Ali for Respondents.

Summary: (a) Constitutional Law: —Art. 199—Writ jurisdiction—Challenge to Ombudsperson’s order—Jurisdictional defect—Effect. The petitioners challenged the Ombudsperson’s order directing them to vacate the disputed property, pay rent for illegal possession, and register a criminal case. The Court held that the Ombudsperson failed to comply with S. 7 of the Punjab Enforcement of Women’s Property Rights Act, 2021, which mandates due consideration of pending civil litigation. Since no reference to the ongoing civil suit was made in the impugned order, the exercise of jurisdiction was unlawful. Relying on Ali Ahmad v. Ombudsperson Punjab (PLD 2023 Lahore 711), the Court reiterated that non-compliance with statutory prerequisites renders an order legally unsustainable. (b) Punjab Enforcement of Women's Property Rights Act, 2021: —S. 7—Pending civil litigation—Effect on Ombudsperson’s jurisdiction. Under S. 7 of the Act, the Ombudsperson must ascertain whether a civil suit regarding the disputed property is pending before a court and, if so, must defer adjudication. In the present case, the petitioners had already instituted a civil suit before the Ombudsperson was approached. The failure to consider the pending litigation vitiated the order. The Court emphasized that where property disputes are sub judice, the Ombudsperson cannot exercise parallel jurisdiction. (c) Statutory Interpretation: —S. 11 of the Act—Exclusion of writ jurisdiction—Scope and limitations. The respondents argued that S. 11 of the Act bars the High Court’s jurisdiction since the Ombudsperson’s order had been implemented. The Court rejected this argument, clarifying that where a jurisdictional defect exists, the High Court’s constitutional jurisdiction under Art. 199 remains available. If an order is passed in violation of statutory provisions, it is nullity in law and does not gain validity through implementation. (d) Judicial Restraint: —High Court’s approach in matters pending before Ombudsperson & Civil Court. The Court refrained from commenting on the merits of the case to avoid prejudicing concurrent proceedings before the Ombudsperson and the Civil Court. Instead, it focused on the procedural illegality of the impugned order, ensuring that the matter is decided in accordance with S. 7 of the Act. ----Disposition: Writ petition allowed. Ombudsperson’s order set aside. The complaint was remanded for fresh adjudication in compliance with S. 7 of the Act.

Summary: (a) Civil Procedure Code (V of 1908)----S. 115:Concurrent findings of fact---Scope of interference by revisional court---Perversity and misreading of evidence---Judgments and decrees of the trial and appellate courts decreeing plaintiffs' suit for declaration, possession, and mandatory injunction were set aside by High Court in exercise of revisional jurisdiction under S. 115, C.P.C. on the ground of blatant misreading and non-reading of evidence and failure to consider binding legal principles---Respondents/plaintiffs failed to prove ownership of suit land allegedly mortgaged by non-Muslim evacuees prior to partition---Key documentary evidence, including notifications and revenue records, produced by Forest Department was not appreciated by courts below---High Court held that where judgments are perverse and contrary to record, revisional jurisdiction can be validly exercised to correct miscarriage of justice.Nazim-ud-Din v. Sheikh Zia-ul-Qamar 2016 SCMR 24 relied upon.(b) Constitution of Pakistan----Art. 24 & Public Interest Doctrine:Public property---Judicial obligation to safeguard state assets---Suit land, admittedly a public asset owned by the Forest Department, could not be allotted or transferred without adherence to legal provisions---High Court reiterated that courts are custodians of public interest and state property, and must exercise extraordinary caution in such matters---Any decree adversely affecting public land must be supported by lawful entitlement and proven claim---Civil courts cannot ignore material legal developments merely on the basis of pleadings.Provincial Government v. Shabbir Hussain PLD 2005 SC 337 and Multiline Associates v. Ardeshir Cowasjee PLD 1995 SC 423 discussed.(c) Evacuee Property Laws----Nature of ownership---Jurisdiction of civil court---Evacuee property---Vesting with government---Limitations on challenge---Land originally owned by non-Muslim evacuees at partition was validly transferred to the Forest Department by the Custodian of Evacuee Property vide notification dated 10.02.1948---Payment of consideration by Forest Department acknowledged by Board of Revenue in 1970s---Such land formed part of compensation pool and could not be reclaimed through civil suits---Civil courts lack jurisdiction to question treatment of property as evacuee land or transactions concluded under evacuee laws---Any claim regarding such properties must be routed through the Custodian or Notified Officer under relevant evacuee laws.Member BOR v. Mst. Siddiqan 2015 SCMR 1721, PLD 2003 Lahore 441, and Azizuddin v. Muhammad Ismail 1985 SCMR 666 relied upon.(d) Forest Act, 1927----S. 38 & Protected Forest Land:Allotment embargo---Binding effect of departmental notifications---Notification dated 27.02.1965 issued by the Chief Settlement Commissioner placed a complete bar on allotment of evacuee land in possession of the Forest Department under the West Pakistan Rehabilitation Settlement Scheme---Such embargo applied to both notified and unnotified forest land---Any order or allotment made in violation of said notification was declared illegal and void---Respondents' claim based on possession and decrees obtained without impleading Forest Department was found to be ineffective and non-binding.Province of Punjab v. Muhammad Mahmood Shah 1991 SCMR 1426, Masooda Begum v. Govt. of Punjab PLD 2003 SC 90, and Syed Ghazanfar Ali Shah's case 2017 SCMR 172 discussed.(e) Evidence Act (I of 1872)----Admissibility of documents---Requirement of proper proof---Documents (Exh.P.1 to Exh.P.12) relied upon by respondents/plaintiffs were tendered by counsel rather than by the witnesses themselves---Held, such documents lacked probative value and were liable to be excluded from consideration---It is a mandatory requirement that party producing documents must do so in their own statement to allow opportunity of cross-examination by adverse party.Mst. Akhtar Sultana v. Major (R) Muzaffar Khan Malik PLD 2021 SC 715 and Rustam v. Jehangir (deceased) 2023 SCMR 730 followed.----Disposition: Civil Revision Allowed---Judgments and Decrees of Courts Below Set Aside---Suit Dismissed.

Summary: Background:Sara Akhtar, formerly Sara Ghouri, filed a suit in 2009 seeking declaration and cancellation of six sale mutations dated January 16, 1989, pertaining to 977 kanals and 19 marlas of land. These mutations were in favor of Mehmood Khan and others, including Mansoor Ahmed Khan's sons and other relatives. The suit was decreed on June 28, 2019, and subsequent appeals by the petitioners were dismissed, culminating in the judgment of the Lahore High Court, Multan Bench, on March 10, 2021.---Issues:Whether the suit was filed within the prescribed time limit and if the possession of the subject land was sought.Whether the burden of proof lay upon the petitioner-respondent and if fraud was established.Whether factual errors were committed by the courts in their decisions.---Holding/Reasoning/Outcome:The burden of establishing the validity of the sale mutations rested with the petitioners, who failed to discharge it. The High Court found that their failure amounted to fraud. The respondent, Sara Akhtar, denied knowledge of the sale mutations and argued that the burden of proof lay with the petitioners, in line with Article 115 of the Qanun-e-Shahadat, 1984. Additionally, constructive possession of the land was claimed by the respondent through her maternal uncle. Only one beneficiary of the purported sale testified, and his credibility was questioned due to his age at the time of the sale. The High Court found no illegality in its judgment and dismissed the petition, directing the revenue authorities to ensure the immediate delivery of land possession to the respondent.---Citations/Precedents:Article 115 of the Qanun-e-Shahadat, 1984.Article 129(g) of the Qanun-e-Shahadat, 1984.----Quote:Substantial costs imposed, as frivolous litigation deprived a woman of her land for 14 years.

Summary: The court meticulously addressed a property dispute concerning an inheritance claim over agricultural land. The dispute originated from Raj Bibi's allegation that her brother, Khushi Muhammad, fraudulently transferred inherited property to his name. The judgment, delivered by Justice Tariq Saleem Sheikh, provided a comprehensive analysis of the legal and factual issues involved, overturning the lower court's decision which had dismissed Raj Bibi's claim.The court first tackled procedural issues, notably the suit's maintainability and the statute of limitations. It established that as a co-sharer in undivided property, Raj Bibi was not restricted by a limitation period in challenging the mutation, aligning with the principle that no limitation runs against a co-sharer, as seen in precedents like "Khalid Hussain and others v. Nazir Ahmad and others" (2021 SCMR 1986). The court also determined that Raj Bibi's action was timely and not barred by limitation, drawing from the principle that fraud affects the start of the limitation period, a notion supported by "Mst. Rabia Gula and others v. Muhammad Janan and others" (2022 SCMR 1009).The judgment then delved into the substantive legal issues surrounding the contested mutation. It emphasized the procedural requirements under Section 42 of the Punjab Land Revenue Act, 1967, for mutation attestation, noting that mutations serve fiscal purposes and are designed to prevent fraud, without conferring title. The court cited "Gharib Shah and others v. Zarmar Gul" (PLD 1984 SC 188) and "Hakim Khan v. Nazeer Ahmad Lughmani and others" (1992 SCMR 1832) to underscore the mandatory nature of these procedures and their role in protecting proprietary rights.The court scrutinized the evidence, particularly the contested Roznamcha Waqiati entry and the lack of corroborative witness testimony. It found the mutation process flawed, as it did not comply with the legal requirements, particularly the need for the presence and identification of Raj Bibi during the mutation attestation.Moreover, the court addressed the heightened burden of proof in transactions involving illiterate or pardahnashin women, requiring clear evidence of their understanding and voluntary participation in transactions. This principle, reinforced in "Phul Peer Shah v. Hafeez Fatima" (2016 SCMR 1225) and "Abdul Aziz v. Mst. Zaib-un-Nissa and others" (PLD 2022 SC 504), was pivotal in the court's reasoning, leading to the conclusion that the mutation in favor of Khushi Muhammad was not legally substantiated.

Summary: Background: The appellants filed a suit for declaration, perpetual injunction, and possession of land against the respondents. They claimed ownership of the land through inheritance and alleged that the respondents had illegally occupied it and established a "Wagon Adda" (bus stand) on it. The respondents countered with a claim that the land was rented to the appellants' predecessor and that a "Jirga" (council of elders) had settled the matter, agreeing that the land would be returned to the respondents after a payment was made to the appellants. The District Judge dismissed the appellants' suit and decreed in favor of the respondents. The appellants appealed against this decision. ----Issues: 1- Whether the decision of the "Jirga" constitutes a valid and enforceable contract under the Specific Relief Act and the Contract Act. 2- Whether the alleged agreement by the "Jirga" required registration under the Registration Act, 1908. 3- Whether the presence of only three persons can constitute a valid "Jirga." 4- Whether a court decree can be nullified based on the decision of a "Jirga." 5- Whether the suits were filed within the prescribed period of limitation under the Limitation Act. 6- Whether the decree of 1983 in favor of the respondents was validly passed. ----Holding/Reasoning/Outcome: --Validity of "Jirga" Decision as a Contract: The court questioned whether the "Jirga" decision could be considered a concluded contract under Section 12 of the Specific Relief Act and the Contract Act. The court emphasized that for a contract to be enforceable, it must involve offer and acceptance, and be legally binding. --Registration Requirement: The court noted that if the "Jirga" decision involved a significant amount of money and the transfer of immovable property, it should have been registered under Section 17 of the Registration Act, 1908. --Constitution of "Jirga": The court expressed doubt about the validity of the "Jirga" with only three members, especially since the head of the "Jirga" was not produced as a witness. --Nullification of Court Decree by "Jirga": The court held that a decree passed by a competent court cannot be nullified by a "Jirga" decision unless it is challenged and set aside through proper legal channels. --Limitation Period: The court considered whether the suits were filed within the prescribed limitation period as per Article 3 of the Limitation Act. --Validity of 1983 Decree: The court directed a review of whether the 1983 decree was validly passed. ----Citations/Precedents: Specific Relief Act Contract Act, 1872 Registration Act, 1908 Limitation Act Sauki Sah & others vs. Mohamaya Parsad Singh & others, AIR 1934 Patra 518 Ghulam Rasool vs. Muhammad Hussain, PLJ 2000 SC 331 Phillips vs. Parnaby, (1934) 2 KB 299 Board of Trustees of the Port of Bombay vs. Sriyanesh Knitters, AIR 1999 SC 2947 IGP Punjab vs. Mushtaq Ahmed, PLD 1985 SC 159 Seaford Court Estates vs. Asher, [1949] 2 KB 481 State of Kerala vs. Malayalam Plantations Ltd., (1980) Kerl 976 Syed Abu Ala Maududi vs. Govt. of West Pakistan, PLD 1964 SC 673 Outcome The appeal was accepted, the judgment and decree of the District Judge dated 29.07.2019 were set aside, and the case was remanded to the trial court for de novo trial.

Summary: (a) Limitation Act (IX of 1908)--- ---- Art. 113---Specific performance of contract---Time limitation---Effect of delay---Petitioner sought specific performance of an agreement to sell dated 07.05.1991 but filed suit on 08.07.2009, after a delay of 18 years---Court held that under Article 113 of the Limitation Act, 1908, a suit for specific performance must be filed within three years from the date fixed for performance or, if no date is fixed, when the plaintiff has notice that performance is refused---Since the suit was filed well beyond the prescribed period, it was barred by limitation---Court reaffirmed that limitation is not a mere technicality but a substantive defense that accrues in favor of the opposite party upon expiration of the statutory period---Reliance placed on Haji Abdul Karim v. Florida Builders (Pvt.) Ltd. (PLD 2012 SC 247) and Atta Muhammad v. Maula Bakhsh (2007 SCMR 1446). (b) Civil Procedure Code (V of 1908)--- ---- S. 115---Revisional jurisdiction---Scope---Findings of fact recorded by lower courts---Revisional jurisdiction under S. 115, C.P.C., is confined to cases where findings suffer from misreading, non-reading, or perverse appreciation of evidence---Concurrent findings of fact by the trial and appellate courts, based on proper evaluation of evidence, cannot be disturbed merely because an alternative view is possible---Court held that both courts below had correctly applied the law of limitation and assessed the evidence in true perspective, warranting no interference in revisional jurisdiction---Reliance placed on Muhammad Farid Khan v. Muhammad Ibrahim (2017 SCMR 679) and Mst. Zaitoon Begum v. Nazar Hussain (2014 SCMR 1469). (c) Civil Procedure Code (V of 1908)--- ---- O. VII, R. 11---Rejection of plaint---Barred by limitation---Effect---Court reaffirmed that where a suit is barred by limitation, the plaint must be rejected without proceeding to trial or framing issues---Limitation is a matter of public policy, and courts are obligated to dismiss time-barred claims even if no objection is raised by the opposite party---In the present case, the agreement to sell was allegedly executed even before the seller had acquired ownership of the property, further invalidating the claim for specific performance---Reliance placed on Hakim Muhammad Buta v. Habib Ahmed (PLD 1985 SC 153). (d) Law of limitation--- ---- Public policy and mandatory application---Court emphasized that the law of limitation is not a procedural technicality but a fundamental legal principle designed to ensure certainty in legal claims---Limitation periods promote orderly administration of justice and prevent frivolous, delayed claims that could disrupt settled legal relationships---Even if a party does not raise a limitation defense, courts must consider it independently at any stage of proceedings---Reliance placed on Asad Ali v. The Bank of Punjab (PLD 2020 SC 736) and Dr. Muhammad Javaid Shafi v. Syed Rashid Arshad (PLD 2015 SC 212). ----Disposition: Revision dismissed---Findings of trial and appellate courts affirmed---Suit barred by limitation, and no case for interference in revisional jurisdiction made out. ----Cited Cases: Haji Abdul Karim v. Florida Builders (Pvt.) Ltd. (PLD 2012 SC 247) Atta Muhammad v. Maula Bakhsh (2007 SCMR 1446) Muhammad Farid Khan v. Muhammad Ibrahim (2017 SCMR 679) Mst. Zaitoon Begum v. Nazar Hussain (2014 SCMR 1469) Hakim Muhammad Buta v. Habib Ahmed (PLD 1985 SC 153) Asad Ali v. The Bank of Punjab (PLD 2020 SC 736) Dr. Muhammad Javaid Shafi v. Syed Rashid Arshad (PLD 2015 SC 212)

Summary: Background:This case, addressed by the Supreme Court of Pakistan, involves Civil Petitions Nos. 723 and 724 of 2021, which challenge the judgment dated January 26, 2021, by the Lahore High Court, Rawalpindi Bench. The dispute centers on a gift deed registered on July 18, 1991, concerning a house purchased on June 3, 1991. The plaintiff (predecessor of the petitioners) filed a suit for declaration, cancellation, and permanent and mandatory injunction on May 12, 2011, claiming that the gift deed was executed at the request of his younger brother (defendant) who was residing in the United Kingdom at the time, purportedly to show financial and monetary strength.----Issues:Whether the gift deed meets the legal requirements under Mahomedan Law and the Specific Relief Act for it to be considered valid.Whether the plaintiff?s challenge to the gift deed was within the limitation period, given the deed was registered 20 years prior to the suit.----Holding/Reasoning/Outcome:The Supreme Court found that the gift deed did not satisfy the essential elements of a valid gift under Mahomedan Law, specifically:The defendant was not present in Pakistan at the time the deed was prepared and registered, making the acceptance and delivery of possession questionable.The plaintiff and his legal heirs remained in possession of the property since the deed's registration.Furthermore, the Court held that the cause of action for challenging the gift deed arose when the defendant attempted to transfer the property into his name, which prompted the filing of the suit. The initial courts failed to adequately consider these points.The petitions were converted into appeals and allowed. The plaintiff?s suit was decreed, the gift deed was cancelled, and the decrees by the first appellate court and the High Court, which favored the defendant, were overturned.----Citations/Precedents:Specific Relief Act (I of 1877): Sections 39, 42, 54, and 55.Limitation Act (IX of 1908), Section 3: Discusses the timing of the cause of action.Section 149 of Mahomedan Law by D.F. Mulla: Outlines the prerequisites for a valid gift under Islamic law, including offer and acceptance, and delivery of possession.

Summary: (a) Civil Procedure Code (V of 1908): ----O. XLI, R. 24 and O. XIII, R. 2 Appellate Court's power to decide cases based on sufficient evidence and admission of additional documents at the revision stage---Maintainability---Petitioner challenged appellate court’s judgment dismissing his suit for declaration and injunction regarding ownership of land purchased through an agreement in 1990---Appellate court relied on O. XLI, R. 24, C.P.C., and found sufficient evidence on record to determine the matter without remanding it for retrial, observing that the petitioner failed to prove ownership. Petitioner’s application under O. XIII, R. 2, C.P.C., for placing additional documents related to demarcation of land during pendency of revision was rejected---Court held that documents not pleaded in the plaint or introduced in subordinate courts cannot be considered at a later stage, as per established legal principles---Reliance placed on Muhammad Iqbal's Case (2015 SCMR 21) and Moiz Abbas v. Mrs. Latifa (2019 SCMR 74). (b) Qanun-e-Shahadat Order (1984): ----Arts. 79 & 117 Proof of attested documents---Petitioner produced an agreement of sale (Iqrar Nama) without producing attesting witnesses as required by Art. 79 of the Qanun-e-Shahadat Order, 1984---Court emphasized that a document mandatorily requiring attestation cannot be relied upon unless two attesting witnesses are produced and prove its execution---Failure to comply rendered the document inadmissible---Reliance placed on Sheikh Muhammad Muneer v. Mst. Feezan (PLD 2021 SC 538). (c) Limitation Act (IX of 1908): ----Art. 120 Suit for correction of revenue entries---Bar of limitation---Petitioner’s suit filed after 15 years of alleged transaction was hopelessly time-barred under Art. 120 of the Limitation Act, which prescribes a six-year limitation for correction of entries---Court held that litigants must act vigilantly within the prescribed period, and failure to do so disentitles them from relief---Reliance placed on Azam Ali (Late) v. Alam Sher (2019 YLR 401). (d) Presumption of correctness of mutation entries: Revenue record entries---Presumption of correctness---Petitioner failed to rebut the presumption of truth attached to revenue entries showing the property in the name of a third party (Patel) prior to the alleged transaction---Court observed that neither the petitioner nor the alleged seller held title to the property, and no effort was made to verify ownership in the revenue record at the time of purchase---Reliance placed on Bakhtiar v. Nasrullah (2015 CLC 395) and Mazloom Hussain v. Abid Hussain (PLD 2008 SC 571). (e) Burden of proof: ----Art. 117, Qanun-e-Shahadat Order (1984) Burden on plaintiff to establish ownership with credible evidence---Petitioner failed to discharge the initial burden of proof to substantiate his claim and could not benefit from weaknesses in the respondent’s case---Court reiterated that plaintiffs must prove their case on their own strength---Reliance placed on Mushtaq-ul-Haq Aarifin (2022 SCMR 55). ----Disposition: Revision petition dismissed---Judgment and decree of the appellate court dated 22nd November 2011 upheld---Petitioner failed to establish ownership or point out any illegality or irregularity in the appellate court's findings.