Summary: For Revision to be maintainable, the impugned order should have finality attached to the same otherwise if the said order is only a discretionary procedural interlocutory order, the same would not be a 'case decided' amenable to Revisional jurisdiction. 54Writ Petition- Criminal Proceedings- Bail 15346-25 MUHAMMAD AHMAD RAMZAN VS STATE ETC Mr. Justice Tanveer Ahmad Sheikh 07- 01- 2026 2026 LHC 957

Summary: Summary pending

Summary: (Against order dated 03.07.2024 of the Federal Service Tribunal, Islamabad passed in Appeal No.61(P) CS of 2023). Civil Servants Act (LXXI of 1973)--- ----S. 13(1) [as amended by Civil Servants (Amendment) Ordinance (XXIV of 2001)]---Civil Service Regulations (CSR), Regln. 418---Service Tribunals Act (LXX of 1973), S. 4---Pensionary benefits---Length of service---Delay in claiming pensionary benefits---Effect---Civil servant was aggrieved of denial of pensionary benefits to him due to belated application---Validity---Pensionary benefits after retirement devolve upon a civil servant soon after his/her resignation followed by its acceptance---Formal application is only required to keep the record streamlined---Delay of any kind to claim pensionary benefits should not be counted as to one of the disentitlements, especially for pensionary claims---Neither the principle of laches applied (as indeed no one else had any claim over the money) nor any provision of Limitation Act, 1908 would come as an obstacle to decline claim of pensionary benefits---If a government servant resigns from an appointment to take up another appointment in which there is a provision for counting of past service, then period served can be taken into account subject to reservation identified in Regulation 418(a) of Civil Service Regulations (CSR)---Supreme Court set aside the judgment of Service Tribunal and order passed by authorities who failed to understand the spirit of Regulation 418 of Civil Service Regulation (CSR) and also that the belated application to claim pensionary benefits was not a disentitlement---Appeal was allowed. Secretary, Government of Punjab, Finance Department v. Ismail Tayer 2015 PLC (C.S.) 296; I.A. Sharwani v. Government of Punjab 1991 SCMR 1041; Chief Engineer, Hydel (North) and Project Director, WAPDA v. Zafarullah Shah 2003 SCMR 684 and Federation of Pakistan v. Muhammad Mubarak PLD 1990 SC 346 rel. Ms. Shireen Imran, Advocate Supreme Court for Petitioner. Rashideen Nawaz Qasoori, Additional Attorney-General for Pakistan, M. Saeed Anwar, Assistant Account Officer and Abdul Rehman, APS for Respondents. Date of hearing: 7th January, 2026.

Summary: (Against judgment dated 07.10.2025 passed in C.R. No. 80-P of 2017 by Peshawar High Court, Peshawar). (a) Civil Procedure Code (V of 1908)--- ----O.XXIII, R.1---Limitation Act (IX of 1908), S.14---Civil suit challenging registered lease deed --- Suit withdrawn “as withdrawn” simpliciter ---No liberty/permission sought/granted to instituted fresh suit---Effect---Subsequent suit on same cause of action---Permissibility---Limitation---Exclusion of time spent before wrong forum---Scope--- Briefly, the petitioners’ (through their late father) filed a civil suit before seeking declaration, perpetual injunction and, in the alternative, possession regarding the shop in question, claiming leasehold rights and challenging a registered lease deed executed in favour of respondent No.1; the suit was decreed and the respondent’s appeal was dismissed, but in civil revision the High Court set aside the concurrent judgments and dismissed the suit, leading to the filing of present petition for leave to appeal before the Supreme Court, whereby, the Supreme Court considered maintainability of the suit in view of the earlier civil suit (on the same cause and lease deed) which was withdrawn without permission to file a fresh suit---Held: The application seeking withdrawal of the earlier suit was completely silent as to any condition, reservation, or liberty to institute a fresh suit on the same cause of action ---A withdrawal founded upon a private arrangement which neither received judicial recognition nor was reflected in the order of the Court could not, in law, be treated as anything other than a withdrawal simpliciter---Such an unconditional withdrawal squarely attracted the bar contained in Order XXIII, Rule 1(3), C.P.C., thereby precluding the institution of a subsequent suit in respect of the same subject-matter---With respect to the issue of limitation the petitioners had neither pleaded nor established any factual or legal basis to attract the benefit of Section 14 of the Limitation Act, 1908---There was no assertion, much less proof, that the earlier proceedings were prosecuted with due diligence and in good faith before a Court lacking jurisdiction or suffering from any defect of a like nature---Consequently, the challenge laid to the registered lease deed, after the lapse of several years, was manifestly beyond the prescribed period of limitation and was, therefore, hopelessly time-barred---Withdrawal of the earlier suit without permission to institute a fresh suit operated as a complete bar under Order XXIII, Rule 1, C.P.C.---The subsequent suit was not only barred by law but also by limitation---The failure of the petitioners to challenge the withdrawal order further estopped them from re-agitating the same cause of action---Leave was refused and present petition being devoid of merit was dismissed. Ghulam Abbas and others v. Mohammad Shafi through LRs and others 2016 SCMR 1403; Azhar Hayat v. Karachi Port Trust through Chairman and others 2016 SCMR 1916; Muhammad Yar (Deceased) through L.Rs. and others v. Muhammad Amin (Deceased) through L.Rs. and others 2013 SCMR 464; Malik Shahid Mehmood v. Malik Afzal Mehmood and others 2011 SCMR 551; Ch. Ghulam Rasool v. Mrs. Nusrat Rasool and 4 others PLD 2008 SC 146; Mrs. Akram Yaseen and others v. Asif Yaseen and others 2013 SCMR 1099 and Muhammad Saeed Bacha and another v. Late Badshah Amir and others 2011 SCMR 345 rel. (b) Civil Procedure Code (V of 1908)--- ----O.XXIII, R.1---Withdrawal of suit---Filing of fresh suit on same cause of action---Permission, non-seeking of---Subsequent suit, maintainability of---Scope---Where the withdrawal order is passed in the presence of the parties and remained unchallenged despite the availability of adequate statutory remedies the party having acquiesced in the said order and allowing it to attain finality, cannot be permitted to question its legal consequences or to re-characterize an unconditional withdrawal as a conditional one---The law does not countenance such an approach. Hassan Ullah Khan Afridi, Advocate Supreme Court for Petitioners. Nemo for Respondents. Date of hearing: 5th January, 2026.

Summary: (Against judgment and decree dated 30.06.2011 passed in R.S.A. No. 107 of 2000 by Lahore High Court, Lahore). Punjab Pre-emption Act (I of 1913)--- ----S.4---Superior right of pre-emption---Term ‘waiver’---Applicability---Respondent / pre-emptor was son of vendor who had claimed possession of suit land through exercise of superior right of pre-emption---Trial Court dismissed the suit but Lower Appellate Court and High Court decreed the suit in favour of respondent / pre-emptor---Validity---Respondent / pre-emptor was not only aware of sale transaction but remained present at the time of execution and registration of sale deed---Despite such knowledge, respondent / pre-emptor neither objected to the sale nor asserted his right of pre-emption---Respondent / pre-emptor allowed transaction to be completed and vendees to act upon it, thereby inducting a legitimate expectation that the sale would not be disturbed---High Court while dismissing second appeal, failed to properly appreciate the cumulative effect of respondent’s/pre-emptor’s conduct and treated his presence in isolation ignoring that waiver was to be inferred from totality of circumstances and not from a single fact viewed in vacuum---Supreme Court set aside judgments and decrees passed by High Court and Lower Appellate Court as the same were result of misreading of evidence and misapplication of law---Appeal was allowed. Said Kamal's case PLD 1986 SC 360; Sardar Ali's case PLD 1988 SC 287; Black's Law Dictionary; Abdul Hameed and others v. Muzamil Haq and others 2005 SCMR 895; Hassan Din and others v. Manzoor Hussain and others 2010 SCMR 810; Naseer Ahmed v. Arshad Ahmad PLD 1984 SC 403 and Dr. Muhammad Javaid Shafi v. Syed Rashid Arshad and others PLD 2015 SC 212 ref. Sheikh Naveed Shehryar and Sh. Usman Karim Ud Din, Advocates Supreme Court for Appellants. Imran Humayun Cheema and Khawaja Waseem Abbas, Advocates Supreme Court for Respondent. Date of hearing: 5th January, 2026.

Summary: Summary pending

Summary: Summary pending

Summary: Powers of Appellate Court to reframe issues at appellate stage discussed. 56Family 64981/25 Harris Rasheed & 1 Other Vs Guardian Judge Lahore etc Mr. Justice Sultan Tanvir Ahmad 24-12- 2025 2025 LHC 8203

Summary: ----Ss.131, 132, 134(2), 136, 286, 287, 288, 290, 397, 298, 299 & 400---Financial statements of company for past years---Approval in EGM, challenge to---Company failing to hold AGMs for preceding financial years---Such conduct constituting oppression, allegation of---Subsequent convening of EGM to approve audited financial statements of past years---Legality---Statutory lapse and its legal consequence---Moot point---Whether, upon expiry of statutory period for holding AGM, the company is legally competent to transact AGM business through an EGM---Appointment of auditors for subsequent years through EGM---Permissibility---Non-holding of AGM attracting regulatory consequences but not rendering subsequent EGM proceedings void---Briefly, the petitioner was a minority shareholder holding approximately 22.5% shares in the respondent company who invoked the jurisdiction of the High Court under the Companies Act, 2017, complaining of prolonged non-holding of Annual General Meetings (AGMs), non-approval and filing of financial statements for multiple past years, and subsequent steps taken by the board of directors to approve audited accounts for earlier periods and to appoint auditors for later periods through an Extraordinary General Meeting---The petitioner participated in and voted at the said EGM, where resolutions were passed by majority---The core issue before the High Court was “whether, in the absence of timely AGMs, the company could lawfully transact the business of approval of past financial statements and appointment of auditors through an EOGM, and whether such acts amounted to unlawful conduct or oppression of minority shareholders requiring interference under the Companies Act, 2017?”---Held: Subsequent auditors were to be appointed by the company in the annual general meeting on the recommendation of the board---In the present case, it had been done in an extraordinary general meeting for which a special resolution was required to be passed in terms of S.2(66) of the Act---Doubtless, the necessary majority for a special resolution was conspicuously missing in the present case for appointment of auditors---Only course open to the company was for convening an extraordinary general meeting which had duly been done yet the foremost requirement of special resolution had not been fulfilled---Members of the company could in any EGM consider the financial statements of previous financial years as well as the reports of the Board and auditors---This was precisely what was considered and approved by the members of respondent company in the EGM under challenge in the present petition---Law provided for the transaction of a business in an EGM which could have been transacted in an AGM but was not so done at the relevant time---If such transaction through an EGM was disallowed then this would have given carte blanche to the directors to simply evade their duty to place the financial statements before the members of the company by deliberately failing to hold an AGM---This could not be the intention of the legislature under the law---As regards the plea of oppression taken in the petition, same did not make out an actionable claim---Since the petitioner did not challenge the proceedings of the general meeting within time (thirty days), he could not bring the present petition alleging oppression of the minority shareholders---Instead of bringing a separate petition to challenge the EGM (of 23.5.2024), the petitioner ought to have added this as a ground to C.O.24829/2023 (whereby challenge to the election of Board held on 01.02.2023 in an EOGM was made) to seek winding up of respondent company---On this basis too, the instant petition was an abuse of the process of the court---Though no case for oppression was made out, in order to streamline the future affairs of the respondent company, it was directed that (i) the audited accounts were to be completed expeditiously and placed before a general meeting for consideration soon thereafter; ii) The AGM for the upcoming financial year to be held on time and according to law; iii) The petitioner and other shareholders were to have access to financial statements, directors reports, audited reports etc. as and when same were prepared and presented---Holding of EGM of 23.5.2024 and other factors mentioned in the petition did not give rise to unlawful and fraudulent acts by the respondents Nos. 2-6 to constitute oppression---The petition to that extent was dismissed, in circumstances. (b) Companies Act (XIX of 2017)--- ----S.223---Financial statements---Statutory duty of Board to lay the same before the company in general meeting---Time-frame---Scope and obligation---Board of every company has to lay before the company in AGM its financial statements for the period since the preceding financial statements made up to the date of close of financial year adopted by the company---The financial statements must be laid within a period of one hundred and twenty days following the close of financial year of a company. (c) Companies Act (XIX of 2017)--- ----Ss.2(66) & 204(8)---Breach of duty, default or negligence by a director, ratification of---Procedure---Special resolution, holding of---Requirement---Any breach of duty, default or negligence by a director in contravention of the articles of the company or any of its policy may be ratified by the company through a special resolution and the Commission may impose any restriction as may be specified---The requirements of special resolution have been spelt out in S.2(66)---A special resolution can only be passed by a majority of not less than three-fourths of such members of the company entitled to vote as are present in person or by proxy at a general meeting---The connotation is that past acts of default of a director may be ratified by a company if it chooses to do so and by a special resolution only. (d) Companies Act (XIX of 2017)--- ----Ss.131 & 132---Statutory meeting---Mandatory compliance---Holding of Annual General Meeting (AGM), obligation of---Statutory timeframe---Failure to hold AGM---Consequences---Extraordinary General Meeting (EGM), resort to---Mechanism---Board’s power to convene EGM---Scope---Every public company having a share capital is obligated to hold a general meeting of members of the company within a period of one hundred and eighty days from the date of which the company is entitled to commence business or within nine months from the date of its incorporation whichever is earlier---This shall be called a statutory meeting---Section 132 is about annual general meetings of a company and provides that every company shall hold an annual general meeting within sixteen months from the date of its incorporation and thereafter once in every calendar year within a period of one hundred and twenty days following the close of its financial year---Thus, by the tenor of S.132 every company is obliged under the law to hold an annual general meeting once in every calendar year within a period of one hundred and twenty days following the close of its financial year---Time for holding an AGM cannot be extended beyond a period of thirty days from the original one hundred and twenty days provided by law---That period has come to pass in respect of financial years till 2024---It was under these circumstances that the respondents resorted to calling of extraordinary general meeting as contemplated by S.133---A reading of S.133 indubitably leads to the conclusion that all meetings of the members of the company shall be referred as general meetings of a company---Further, all general meetings of a company other than the annual general meeting referred in S.132 and statutory meeting mentioned in S.131 shall be called extra ordinary general meetings for the precise reason that an EGM is held under special circumstances and by subsection (2) the Board may at any time call an extraordinary general meeting of the company to consider any matter which requires approval of the company in a general meeting---Doubtless, subsection (2) of S.133 confers power on the Board to call an EGM and any matter may be considered in an EGM which requires the approval of a company in a general meeting. (e) Companies Act (XIX of 2017)--- ----Ss.131, 132 & 134(2)---Financial statements---Reports of the board and auditors---Annual General Meeting, non-holding of---Effect---Holding of an Extraordinary General Meeting instead---Permissibility---In case an AGM is not held on time as provided by law for any reason whatsoever and no extension can be granted by the Commission, the only option left is for an EGM to be held for transaction of a business. (f) Companies Act (XIX of 2017)--- ----Ss.131, 132 & 204---Breach of duty by a director, ratification of---Mode of ratification---Special resolution, holding of---In case the company considers that a director is in breach of his duties in contravention of the articles of the company or any of its policy or decision of a board, it may proceed to convene an EGM for the purpose of ratification of the act of a director and for which a special resolution would be required---Thus, the company has firstly to form an opinion that any of its directors has committed a breach of duty or is in default of its policies or decision of the board and thereafter it may further decide to ratify that act by a special resolution---That opinion can only be formed by the Board of Directors of a company and none else. (g) Companies Act (XIX of 2017)--- ----Ss.131, 132 & 204---Company failing to hold an Annual General Meeting (AGM)---Whether directors of a company can be held liable for such failure---Power of company to ratify its own default---Scope---Failure to hold AGMs is the act of the company and not of an individual director, therefore, the default of the company will have to be ratified in contradistinction to the default of an individual director---Section 204 does not deal with such species of default---Any default by a company will be for the Securities and Exchange Commission of Pakistan (SECP) to determine and fix liability---The company itself cannot be conceived to have power to ratify its own defaults or breach of duty. (h) Companies Act (XIX of 2017)--- ----Ss.131, 132 & 286---Oppression and mismanagement, allegation of---Ratification of acts/omissions---Scope---There can conceivably be no oppression in respects of acts which, under the law, can be ratified. (i) Companies Act (XIX of 2017)--- ----Ss.136 & 286---General meeting proceedings---Court’s power to invalidate---Limitation---Failure to challenge within time, effect of---Subsequent oppression petition---Maintainability---Court is empowered to declare the proceedings of a general meeting including an EGM, invalid---This would require a petition by members having not less than 10% of the voting power in the company and may be declared invalid by reason of a material defect or omission in the notice or irregularity in the proceedings of the meeting---Therefore, the law itself provides an alternate remedy to the members having not less than 10% of the voting power---Petition shall be made within thirty days of the impugned meeting---If a minority shareholder does not file the petition within time he cannot allege oppression of the minority shareholders. Samar Masood Soofi, Ahmad Raza Mirza and Salman Hanif Rajput for Petitioner. Adil Umar Bandial, Sajjad Ali and Taimoor Sultan for Respondents. Sikandar Bashir Mohmand for Respondents Nos. 2 to 6. Ruman Bilal for SECP. Dates of hearing: 2nd and 3rd December, 2025.

Summary: (a) Companies Act (XIX of 2017)--- ----Ss.131, 132, 134(2), 136, 286, 287, 288, 290, 397, 398, 399 & 400---Financial statements of company for past years---Approval in EGM, challenge to---Company failing to hold AGMs for preceding financial years---Such conduct constituting oppression, allegation of---Subsequent convening of EGM to approve audited financial statements of past years---Legality---Statutory lapse and its legal consequence---Moot point---Whether, upon expiry of statutory period for holding AGM, the company is legally competent to transact AGM business through an EGM---Appointment of auditors for subsequent years through EGM---Permissibility---Non-holding of AGM attracting regulatory consequences but not rendering subsequent EGM proceedings void---Briefly, the petitioner was a minority shareholder holding approximately 22.5% shares in the respondent company who invoked the jurisdiction of the High Court under the Companies Act, 2017, complaining of prolonged non-holding of Annual General Meetings (AGMs), non-approval and filing of financial statements for multiple past years, and subsequent steps taken by the board of directors to approve audited accounts for earlier periods and to appoint auditors for later periods through an Extraordinary General Meeting---The petitioner participated in and voted at the said EGM, where resolutions were passed by majority---The core issue before the High Court was “whether, in the absence of timely AGMs, the company could lawfully transact the business of approval of past financial statements and appointment of auditors through an EOGM, and whether such acts amounted to unlawful conduct or oppression of minority shareholders requiring interference under the Companies Act, 2017?”---Held: Subsequent auditors were to be appointed by the company in the annual general meeting on the recommendation of the board---In the present case, it had been done in an extraordinary general meeting for which a special resolution was required to be passed in terms of S.2(66) of the Act---Doubtless, the necessary majority for a special resolution was conspicuously missing in the present case for appointment of auditors---Only course open to the company was for convening an extraordinary general meeting which had duly been done yet the foremost requirement of special resolution had not been fulfilled---Members of the company could in any EGM consider the financial statements of previous financial years as well as the reports of the Board and auditors---This was precisely what was considered and approved by the members of respondent company in the EGM under challenge in the present petition---Law provided for the transaction of a business in an EGM which could have been transacted in an AGM but was not so done at the relevant time---If such transaction through an EGM was disallowed then this would have given carte blanche to the directors to simply evade their duty to place the financial statements before the members of the company by deliberately failing to hold an AGM---This could not be the intention of the legislature under the law---As regards the plea of oppression taken in the petition, same did not make out an actionable claim---Since the petitioner did not challenge the proceedings of the general meeting within time (thirty days), he could not bring the present petition alleging oppression of the minority shareholders---Instead of bringing a separate petition to challenge the EGM (of 23.5.2024), the petitioner ought to have added this as a ground to C.O.24829/2023 (whereby challenge to the election of Board held on 01.02.2023 in an EOGM was made) to seek winding up of respondent company---On this basis too, the instant petition was an abuse of the process of the court---Though no case for oppression was made out, in order to streamline the future affairs of the respondent company, it was directed that (i) the audited accounts were to be completed expeditiously and placed before a general meeting for consideration soon thereafter; ii) The AGM for the upcoming financial year to be held on time and according to law; iii) The petitioner and other shareholders were to have access to financial statements, directors reports, audited reports etc. as and when same were prepared and presented---Holding of EGM of 23.5.2024 and other factors mentioned in the petition did not give rise to unlawful and fraudulent acts by the respondents Nos. 2-6 to constitute oppression---The petition to that extent was dismissed, in circumstances. (b) Companies Act (XIX of 2017)--- ----S.223---Financial statements---Statutory duty of Board to lay the same before the company in general meeting---Time-frame---Scope and obligation---Board of every company has to lay before the company in AGM its financial statements for the period since the preceding financial statements made up to the date of close of financial year adopted by the company---The financial statements must be laid within a period of one hundred and twenty days following the close of financial year of a company. (c) Companies Act (XIX of 2017)--- ----Ss.2(66) & 204(8)---Breach of duty, default or negligence by a director, ratification of---Procedure---Special resolution, holding of---Requirement---Any breach of duty, default or negligence by a director in contravention of the articles of the company or any of its policy may be ratified by the company through a special resolution and the Commission may impose any restriction as may be specified---The requirements of special resolution have been spelt out in S.2(66)---A special resolution can only be passed by a majority of not less than three-fourths of such members of the company entitled to vote as are present in person or by proxy at a general meeting---The connotation is that past acts of default of a director may be ratified by a company if it chooses to do so and by a special resolution only. (d) Companies Act (XIX of 2017)--- ----Ss.131 & 132---Statutory meeting---Mandatory compliance---Holding of Annual General Meeting (AGM), obligation of---Statutory timeframe---Failure to hold AGM---Consequences---Extraordinary General Meeting (EGM), resort to---Mechanism---Board’s power to convene EGM---Scope---Every public company having a share capital is obligated to hold a general meeting of members of the company within a period of one hundred and eighty days from the date of which the company is entitled to commence business or within nine months from the date of its incorporation whichever is earlier---This shall be called a statutory meeting---Section 132 is about annual general meetings of a company and provides that every company shall hold an annual general meeting within sixteen months from the date of its incorporation and thereafter once in every calendar year within a period of one hundred and twenty days following the close of its financial year---Thus, by the tenor of S.132 every company is obliged under the law to hold an annual general meeting once in every calendar year within a period of one hundred and twenty days following the close of its financial year---Time for holding an AGM cannot be extended beyond a period of thirty days from the original one hundred and twenty days provided by law---That period has come to pass in respect of financial years till 2024---It was under these circumstances that the respondents resorted to calling of extraordinary general meeting as contemplated by S.133---A reading of S.133 indubitably leads to the conclusion that all meetings of the members of the company shall be referred as general meetings of a company---Further, all general meetings of a company other than the annual general meeting referred in S.132 and statutory meeting mentioned in S.131 shall be called extra ordinary general meetings for the precise reason that an EGM is held under special circumstances and by subsection (2) the Board may at any time call an extraordinary general meeting of the company to consider any matter which requires approval of the company in a general meeting---Doubtless, subsection (2) of S.133 confers power on the Board to call an EGM and any matter may be considered in an EGM which requires the approval of a company in a general meeting. (e) Companies Act (XIX of 2017)--- ----Ss.131, 132 & 134(2)---Financial statements---Reports of the board and auditors---Annual General Meeting, non-holding of---Effect---Holding of an Extraordinary General Meeting instead---Permissibility---In case an AGM is not held on time as provided by law for any reason whatsoever and no extension can be granted by the Commission, the only option left is for an EGM to be held for transaction of a business. (f) Companies Act (XIX of 2017)--- ----Ss.131, 132 & 204---Breach of duty by a director, ratification of---Mode of ratification---Special resolution, holding of---In case the company considers that a director is in breach of his duties in contravention of the articles of the company or any of its policy or decision of a board, it may proceed to convene an EGM for the purpose of ratification of the act of a director and for which a special resolution would be required---Thus, the company has firstly to form an opinion that any of its directors has committed a breach of duty or is in default of its policies or decision of the board and thereafter it may further decide to ratify that act by a special resolution---That opinion can only be formed by the Board of Directors of a company and none else. (g) Companies Act (XIX of 2017)--- ----Ss.131, 132 & 204---Company failing to hold an Annual General Meeting (AGM)---Whether directors of a company can be held liable for such failure---Power of company to ratify its own default---Scope---Failure to hold AGMs is the act of the company and not of an individual director, therefore, the default of the company will have to be ratified in contradistinction to the default of an individual director---Section 204 does not deal with such species of default---Any default by a company will be for the Securities and Exchange Commission of Pakistan (SECP) to determine and fix liability---The company itself cannot be conceived to have power to ratify its own defaults or breach of duty. (h) Companies Act (XIX of 2017)--- ----Ss.131, 132 & 286---Oppression and mismanagement, allegation of---Ratification of acts/omissions---Scope---There can conceivably be no oppression in respects of acts which, under the law, can be ratified. (i) Companies Act (XIX of 2017)--- ----Ss.136 & 286---General meeting proceedings---Court’s power to invalidate---Limitation---Failure to challenge within time, effect of---Subsequent oppression petition---Maintainability---Court is empowered to declare the proceedings of a general meeting including an EGM, invalid---This would require a petition by members having not less than 10% of the voting power in the company and may be declared invalid by reason of a material defect or omission in the notice or irregularity in the proceedings of the meeting---Therefore, the law itself provides an alternate remedy to the members having not less than 10% of the voting power---Petition shall be made within thirty days of the impugned meeting---If a minority shareholder does not file the petition within time he cannot allege oppression of the minority shareholders. Samar Masood Soofi, Ahmad Raza Mirza and Salman Hanif Rajput for Petitioner. Adil Umar Bandial, Sajjad Ali and Taimoor Sultan for Respondents. Sikandar Bashir Mohmand for Respondents Nos. 2 to 6. Ruman Bilal for SECP. Dates of hearing: 2nd and 3rd December, 2025.