Summary: (a) Control of Narcotic Substances Act (XXV of 1997) ---- S. 9(c) --- Safe custody and safe transmission of recovered narcotics --- Chain of custody --- Benefit of doubt --- Petitioners were convicted and sentenced for alleged recovery of 26 kilograms of charas concealed in a secret cavity of a truck intercepted on 23.06.2021 at Shikarpur Road, Jacobabad, which conviction was maintained by the High Court --- Held, that in narcotics cases the prosecution is required to affirmatively establish safe custody and safe transmission of the recovered substance, and even a single missing link in the chain of custody creates doubt sufficient to entitle the accused to benefit thereof --- Prosecution is under legal obligation to prove that from the moment of alleged recovery till receipt by the office of chemical examiner, the case property remained protected from every possibility of tampering or substitution --- Prosecution failed to produce the Moharrar/Malkhana incharge in whose custody the case property allegedly remained during the intervening period, and relevant register entries establishing safe custody were withheld --- Such omission cannot be brushed aside lightly where the prosecution is under strict obligation to establish an unbroken chain of custody from recovery till receipt by the chemical examiner --- Failure in this regard strikes at the root of the prosecution case. (b) Control of Narcotic Substances Act (XXV of 1997) ---- S. 9(c) --- Recovery from a vehicle --- Non-production of registered owner --- Contradictory description of vehicle --- Official witnesses --- Vehicle from which alleged recovery was effected stood registered in the name of one Ghulam Muhammad Pathan, who was neither associated during investigation nor produced before the trial Court to explain the nature of possession, custody or use of the vehicle by the petitioners --- Entire prosecution case was built upon testimony of official witnesses only; no independent witness from the locality or nearby check-post was associated despite alleged recovery at a public place --- Although non-association of a private witness by itself may not always be fatal, yet where material infirmities regarding safe custody and transmission exist, such circumstance assumes considerable importance --- Description of the vehicle in the F.I.R. was a Mazda truck bearing registration No.NAE-900, whereas the verification report by the Excise and Taxation Officer stated the vehicle to be an Isuzu truck; contradictory details of the vehicle made it apparent that the prosecution gave inconsistent particulars --- Prosecution also failed to produce or satisfactorily account for the vehicle as case property. (c) Criminal trial ---- Benefit of doubt --- Even a single circumstance creating reasonable doubt in a prudent mind regarding guilt of accused is sufficient to extend benefit of doubt, not as a matter of grace but as a matter of right --- Held, that non-production of Moharrar, withholding of relevant malkhana record, unexplained deficiencies regarding safe custody, non-production of registered owner of the vehicle, failure to produce or account for the vehicle as case property, and contradictory description of the vehicle, created serious doubt about the veracity of the prosecution case --- Petitioners entitled to benefit of doubt --- Seriousness of the narcotics offence does not dilute the standard of proof; because the statute provides harsh punishments, Courts must insist upon strict proof of recovery, custody, sampling, transmission and conscious possession. (d) Control of Narcotic Substances Act (XXV of 1997) ---- S. 33(4) --- Criminal Procedure Code (V of 1898) ---- Ss. 516-A & 517 --- Disposal, sampling and destruction of narcotic case property --- Lex specialis --- Section 33(4) of the Act mandates that a seized narcotic substance shall be disposed of under S. 516-A, Cr.P.C., which governs interim custody and destruction during pendency of proceedings and authorizes the Court to obtain and prepare samples under its supervision and control and cause destruction of the remaining portion under a certificate; S. 517, Cr.P.C. regulates final disposal of case property upon conclusion of inquiry or trial --- Expression "shall" in S. 33(4) being lex specialis prevails over "may" in S. 516-A, Cr.P.C., which dictates the manner of disposal --- Expression "may" in S. 517, Cr.P.C. does not authorize judicial inaction; the powers are judicial in character and must be exercised through reasoned orders, after preserving representative samples, preparing inventory, ensuring certification, and protecting the rights of the accused and prosecution --- Directions issued: trial Courts, including special courts for narcotics cases, shall exercise powers under S. 33(4) in the manner provided in S. 516-A, subject to stated criteria, and upon conclusion of inquiry or trial promptly consider orders under S. 517, Cr.P.C., with due regard to environmentally sound methods of destruction; no destruction under S. 516-A shall be ordered during inquiry or trial unless notice is issued to the accused and prosecution, representative samples are prepared under judicial supervision, and proper certification is made part of the record; representative samples sufficient for production before the Court, appeal, revision, identification and forensic verification shall be preserved; Inspectors General of Police and District Police Officers shall extend lawful assistance; Ministry of Interior and Narcotics Control to consider framing or updating a comprehensive regulatory framework for periodic destruction of confiscated narcotic substances, subject to public health, occupational safety and environmental safeguards. Disposition: Leave granted; criminal petition converted into appeal and allowed; conviction and sentences set aside; petitioners acquitted of the charge and directed to be released forthwith if not required to be detained in any other case. (Crl.P. No.1544 of 2025, Supreme Court of Pakistan, judgment by Salahuddin Panhwar, J. (Muhammad Hashim Khan Kakar and Ishtiaq Ibrahim, JJ. on the Bench), Islamabad, 11.05.2026; Approved for reporting.)

Summary: (a) Penal Code (XLV of 1860)----S. 302---Parricide---Two counts of imprisonment for life---Consecutive sentences---Held, atrocious act of parricide is aggravating and warrants severe penalty; sentences of imprisonment for life on two counts shall run consecutively---No legitimate ground to interfere with well-reasoned High Court judgment; no non-reading or misreading of evidence. Disposition: Petition dismissed; leave refused; life sentences on two counts to run consecutively. Dated 11.05.2026.

Summary: Summary pending

Summary: Summary pending

Summary: Summary pending

Summary: Summary pending

Summary: Summary pending

Summary: When the complainant during her statement before the court deposed that she alongwith other private cited witnesses took the deceased in injured condition to the hospital for medical examination, where he succumbed to the injuries, however, she has been negated by the doctor, who categorically stated that police brought the deceased in injured condition to the hospital, then this major contradiction reduced the testimonial value of the deposition of the complainant; and when genesis to the occurrence are not discernable from the record, then this is also fatal for the case of the prosecution in the circumstances of the case.

Summary: (a) Pakistan Penal Code----Ss. 336-A & 336-B---Hurt caused by corrosive substance (vitriolage / acid attack)---Conviction and sentence of life imprisonment---Appreciation of evidence---Petitioner was convicted by the Anti-Terrorism Court, Faisalabad, in Sessions Case No.138/ATC/FSD/2019 under S. 336-B, P.P.C., for causing burn injuries to Mst. Iqra Perveen by throwing acid, and was sentenced to rigorous imprisonment for life, fine of Rs.1,000,000/- to the victim towards compensation and, in default, simple imprisonment for two years; High Court upheld the conviction and sentences---Prosecution case was that on 04.09.2019 at noon the petitioner, intending to permanently injure and disfigure the victim, threw acid on her face and body while she was cooking in the kitchen of her home, causing extensive burns on the face, chest, back, left leg and left foot and complete destruction of the left ear---Held, that the occurrence took place in broad daylight within the complainant’s residence in the presence of witnesses who were inmates of the house, whose presence could not be disputed---Victim’s ocular account was unimpeachable; petitioner was identified as the sole perpetrator in the FIR---Medical evidence completely supported the ocular account and was confirmed by a positive report of the Punjab Forensic Science Agency that the substance was sulfuric acid---Injuries fell within S. 336-A and specifically attracted S. 336-B, P.P.C., which requires a minimum sentence of fourteen years’ rigorous imprisonment, extendable to life, and a minimum fine of one million rupees---Act was intentional, with the intention of disfiguring the victim---Synergy between the confidence-inspiring ocular account and the medical evidence, including acid burns found on the petitioner’s own fingers, left no room for a hypothesis of innocence---Plea of alibi was unsupported; false implication was not supported by any evidence---On independent assessment of the evidence, Supreme Court was unable to differ from the trial and appellate courts---Leave refused; conviction and sentence of life imprisonment maintained. (b) Pakistan Penal Code----S. 336-B---Quantum of sentence---Plea of juvenility---Poena debit commensurari delicto---Petitioner’s plea of juvenility (alleged age 17/18 years) was considered---Held, that punishment should correspond to the gravity of the crime---In acid cases the injury is perpetual agony, not a temporary wound---Sheer gravity and calculated brutality precluded leniency---Shield of juvenility could not be invoked to mitigate punishment for such an inhumane act: petitioner did not act on sudden impulse but arrived at the victim’s residence equipped with a can of acid, demonstrating a premeditated plan; physical devastation included third-degree burns over 40% of the body, complete destruction of the left ear and total disfigurement of facial features, besides perpetual emotional trauma and social ostracization; petitioner demonstrated capacity to handle a dangerous corrosive with lethal precision; post-occurrence conduct aggravated his position by a defence of victim-blaming (self-inflicted injuries) which was debunked by medical testimony of PW-4---Minimum sentence of fourteen years was grossly inadequate; a life sentence was not excessive but the only penalty matching the lifelong sentence of disfigurement imposed upon the victim---Petitioner was entirely undeserving of the lesser penalty and deserving of the maximum penalty provided by the statute. (c) Code of Criminal Procedure----S. 544-A---Compensation to the person hurt---Mandatory nature unless reasons recorded---Courts below had inadvertently overlooked the mandatory nature of S. 544-A, Cr.P.C., which obligates the Court, when convicting a person of an offence in the commission whereof death, hurt, injury or mental anguish or psychological damage is caused, to order compensation to the person hurt unless reasons for directing otherwise are recorded in writing---To rectify the omission, and in view of the gravity of the harm, Supreme Court exercised powers under S. 544-A, Cr.P.C., and directed the petitioner to pay a further sum of Rs.1,000,000/- (one million) as compensation to the victim, recoverable as arrears of land revenue in the event of default. (d) Pakistan Penal Code----Ss. 336-A & 336-B---Criminal Law (Second Amendment) Act (XXV of 2011)---Code of Criminal Procedure---Schedule---Hurt by corrosive substance made a distinct offence and declared non-compoundable---Legislative object---Held, that the Legislature enacted Act XXV of 2011 and introduced Ss. 336-A and 336-B into the P.P.C. to provide a robust penal response to acid violence as a distinct class of atrocity---Parallel amendment to the Schedule of the Cr.P.C. declaring the offence under S. 336-B non-compoundable was a deliberate departure from private settlement, in response to the trend of coercing victims into settlement, and recognized that a victim’s disfigurement is a permanent assault on the collective dignity of the citizenry. (e) Anti-Rape (Investigation and Trial) Act (2021)----Ss. 9 & 16 and Schedule-II---Offence under S. 336-B, P.P.C., included in Schedule-II---Special Courts, statutory timeline and Special Sexual Offences Investigation Units---Held, that Schedule-II of the Act of 2021 explicitly includes the offence punishable under S. 336-B, P.P.C., assigning jurisdiction to Special Courts established thereunder---Object of the Act, as declared in its preamble, is expeditious redressal of sexual abuse crimes in respect of women and children through special investigation teams and special Courts---By S. 16, Special Courts are mandated to preferably decide the case within four months of taking cognizance---Success of the speedy-trial framework depends on strict implementation of prescribed statutory timelines---By S. 9, Special Sexual Offences Investigation Units have been established in every district (and by the Federal Government in Islamabad Capital Territory) to investigate Schedule-II offences, including acid attacks under S. 336-B, under supervision of a police officer not below BPS-17, with a safeguard of transfer of investigation to the district head of investigation if the complainant expresses dissatisfaction on reasonable grounds---Supreme Court strongly recommended that all High Courts actively monitor and ensure that in all cases of vitriolage the statutory timelines for completion of trials are strictly adhered to. (f) Acid control and restorative justice---Punjab Acid Control Act (XXVI of 2025)---Recommendations to Federation and Provinces---Disability classification of acid-attack survivors---Held, that penal sanctions alone are insufficient while corrosive substances remain easily available---Punjab Acid Control Act, 2025, representing a shift from post-occurrence punishment to pre-emptive regulation, mandates a rigorous licensing regime and categorically prohibits sale of acid to individuals under the age of 18---Supreme Court strongly recommended that the Federal and all Provincial Governments ensure that sale of acid to private individuals be completely banned wherever unregulated retail trade still persists, and recommended a centralized digital system, governed and monitored in real time, to process all legal acid sales and purchases with essential particulars of quantity, purpose, purchaser’s identity, picture and biometric thumb impression---Until specialized frameworks are adopted across remaining jurisdictions, stringent administrative policies and regulatory rules must immediately be formulated to standardize sale and distribution of corrosive substances---Principles of restorative justice and reparative liability must be integrated into the judicial framework; while the primary offender must be held strictly liable for costs of the victim’s treatment, the State cannot absolve itself of its parens patriae obligation---Acid-attack survivors who suffer permanent sensory or physical damage are fully qualified to be classified as persons with disabilities and entitled to official Disability Certificates and dedicated disability quotas in employment, educational institutions and state-sponsored welfare benefits---Federal and Provincial Governments were recommended to accommodate acid-attack victims under disability quotas and to enact and enforce specialized legislation for a National Acid Survivors’ Rehabilitation Fund covering reconstructive surgery and physical therapy, psychological and social rehabilitation, a mandatory monthly stipend where the survivor is incapable of financial self-support, and national rehabilitation guidelines for gratuitous lifelong medical and mental-health treatment---Office directed to forward a copy of the judgment to all High Courts through their Registrars, the Federal Secretary for Law and Justice, the Chairman, Parliamentary Committee for Law and Justice, Provincial Law Secretaries, the Attorney General for Pakistan and Advocate General/Prosecutor General offices of all Provinces; steps taken to be intimated to the Court through the Registrar. Cited Cases: • Laxmi v. Union of India (2014) 4 SCC 427 Disposition: Leave refused; criminal petition dismissed; conviction and sentence of life imprisonment maintained; petitioner further directed under S. 544-A, Cr.P.C., to pay Rs.1,000,000/- as compensation to the victim, recoverable as arrears of land revenue in default. (Crl. P. No.1718 of 2022, Supreme Court of Pakistan, Islamabad, decided 07.05.2026; Approved for Reporting.)

Summary: Summary pending