Summary: (a) Civil Procedure Code (V of 1908) ----S. 115---Revisional jurisdiction---Scope---Concurrent findings---Petitioner challenged concurrent judgments and decrees of Trial Court and Appellate Court dismissing suit for declaration, partition, and injunction---Supreme Court reiterated that revisional powers under Section 115, C.P.C. are limited to correcting jurisdictional defects, material irregularities, or errors of law affecting merits of the case---Findings of fact by lower courts, even if erroneous, cannot be interfered with merely because another view is possible---No jurisdictional defect, illegality, or material irregularity found in concurrent judgments---Revision petition dismissed accordingly. (b) Law of Evidence ----Proof of heirship---Inheritance---Requirement---Petitioner failed to substantiate claim of being legal heir of deceased owner---No credible evidence produced regarding relationship or ownership---Mere assertions without documentary or reliable evidence held insufficient to establish entitlement in inheritance matters---Unsubstantiated claims rejected. (c) Specific Relief Act (I of 1877) ----Ss. 42 & 54---Declaration and injunction---Fraud---Pleading and proof---Petitioner alleged fraud in execution of sale deeds but failed to plead fraud with necessary particulars or substantiate it through evidence---Court held that general allegations without specific details regarding manner, time, collusion, and purpose do not constitute valid plea of fraud---Principles of acquiescence and waiver also attracted due to prolonged inaction by petitioner---Relief rightly denied. Cited Cases: • Bashir Ahmed through Legal Representative and others v. Muhammad Hussain and others (PLD 2019 SC 504) • Jubilee General Insurance Co. Ltd., Karachi v. Ravi Steel Company, Lahore (PLD 2020 SC 324) • Taj Wali Khan v. Hukam Khan (decd.) through L.Rs. (2025 SCMR 231) • Muhammad Hanif Qureshi v. Muhammad Ayub and another (2024 CLC 1838) • Mariyappa K.S. v. K.T. Siddalinga Setty [1989(1) KantLJ 150 = 1989 CivCC 183] • S. Kaliyammal v. K. Palaniammal [1999 AIR (Madras) 40] • Kisan Ramji Khandare v. Kausalyabai Gangaram [2007(3) BCR 118] • Cambridge Solutions Ltd., Bangalore v. Global Software Ltd. [2009 AIR (Madras) 74] • Khudadad v. Syed Ghazanfar Ali Shah alias S. Inaam Hussain and others (2022 SCMR 933) • Mst. Zarsheda v. Nobat Khan (PLD 2022 SC 21) • Government of Khyber Pakhtunkhwa through Secretary Elementary and Secondary Education, Peshawar and others v. Latif Ullah Khan (2021 SCMR 829) • Abdul Khaliq (Deceased) through L.Rs. v. Ch. Rehmat Ali (Deceased) through L.Rs. and others (2012 SCMR 508) • Ahmad Nawaz Khan v. Muhammad Jaffar Khan and others (2010 SCMR 984) • Malik Falaksher through L.Rs. v. Muhammad Baran and another (2024 YLR 2578) • Imtiaz Ali v. Muhammad Sadiq (2023 MLD 1819) • Mst. Farzana Zia and others v. Mst. Saadia Andaleeb and others (2024 SCMR 916) • Abdul Aziz v. Sheikh Fateh Muhammad (2007 SCMR 336) • Mst. Zaitoon Begum v. Nazar Hussain and another (2014 SCMR 1469) • Hakim-ud-Din through L.Rs. and others v. Faiz Bakhsh and others (2007 SCMR 870) • Rashid Ahmad v. Said Ahmad (2007 SCMR 926) • Muhammad Feroze and others v. Muhammad Jamaat Ali (2006 SCMR 1304) • Muhammad Khan v. Muhammad Aslam through Legal Heirs and 7 others (2008 CLC 1055) • The Chairman, Wapda and 4 others v. Messrs Sitara Marbles Industry through Managing Director (2016 YLR 205)

Summary: (a) Constitution of Pakistan ----Art. 199 Maintainability---Writ petition---Challenge to review of mutation by revenue authorities---Scope---Mutation sanctioned in compliance with civil court decree transferring ownership to petitioners---Revenue authorities held to have no jurisdiction to question, review, or nullify decree passed by competent civil court---Revenue mutation being consequential act without independent authority---High Court set aside impugned orders reviewing mutation as illegal and without lawful authority---Petition allowed. (b) Land Acquisition Act, 1894 ----S. 48---Surplus acquired land---Reversion to original owners---Principles---Government has discretion to either auction surplus land or restore it to original owners---Discretion must be exercised fairly, reasonably, and not arbitrarily---Where no alternative public purpose is demonstrated, surplus land must revert to original owners upon fulfillment of procedural requirements---Doctrine of fair exercise of discretion applied. (c) Revenue Law ----Mutation---Effect of civil court decree---Scope---Mutation entered pursuant to valid civil court decree merely formalizes rights determined by judicial process---Revenue officers have no jurisdiction to reassess correctness or merits of decree---Implementation of decree by mutation entry held mandatory without independent review---Orders contrary to decree declared void. Cited Cases: • Administrator, Municipal Committee, Kotli and another v. Muhammad Abdullah and 3 others (2001 YLR 3367) [Supreme Court (AJ&K)] • Shahid Sharif and 22 others v. Azad Jammu and Kashmir Government, through Chief Secretary and 12 others (2017 YLR 746) [Supreme Court (AJ&K)] • Peer Muhammad Ghoas Gillani and another v. Azad Jammu and Kashmir Government through Chief Secretary and 3 others (2018 YLR Note 12) • Col. Shah Sadiq v. Muhammad Ashiq and others (2006 SCMR 276) • CORRUPTION IN HAJJ ARRANGEMENTS IN 2010 (PLD 2011 Supreme Court 963) • Workers' Party Pakistan Through Akhtar Hussain, Advocate, General Secretary and 6 others v. Federation of Pakistan and 2 others (PLD 2012 Supreme Court 681) • M.Q.M. (Pakistan) and others v. Pakistan through Secretary Cabinet Division, Government of Pakistan and others (PLD 2022 Supreme Court 439) • Malik Gull Zaman v. Deputy Commissioner and others (2022 CLC 1261) • Messrs Mirpurkhas Sugar Mills Limited and 4 others (2021 CLC 1801) • Province of Punjab through Collector, Lahore and another v. Mian Saeed Ahmad and 4 others (PLJ 1993 SC 184) • Ghulam Rasool and another v. Said Ahmed and others (2012 CLC 1655) [Supreme Court (AJ&K)] • Muhammad Tariq and another v. Syed Alam Shah and 17 others (2014 MLD 1519) • Khushi Muhammad and others v. Member, Board of Revenue and others (1992 CLC 125) • Syed Mustafa Haider v. Provincial Government and others (1992 CLC 1329) • Hakeem Khadim Hussain through Legal Heirs v. Member (Judicial-II), Board of Revenue, Punjab Lahore and 3 others (2019 YLR 710)

Summary: Summary pending

Summary: Summary pending

Summary: (a) Anti-Terrorism Act, 1997 ----S. 19(7)---Expeditious trial---Duty of Anti-Terrorism Court---Scope---Where trial is not concluded within seven days, the Anti-Terrorism Court is obligated to inform the Chief Justice of the High Court for appropriate directions---In the present case, considering the large number of accused persons, multiplicity of related cases, and volume of prosecution witnesses, the Supreme Court directed the Anti-Terrorism Court to conclude the trial within four months from receipt of the order. (b) Constitution of Pakistan ----Art. 10-A---Right to fair trial---Scope---Direction issued to ensure that trial rights of accused are protected---Anti-Terrorism Court directed to ensure that no impediment occurs to fair trial of accused---Applications for exemption from personal appearance should be considered in accordance with law where accused are facing multiple trials---Court noted that copies of charge and prosecution evidence must be provided to accused to enable preparation of defence. (c) Criminal Procedure ----Monitoring of trial---Scope---Provincial Chief Justices may, if deemed appropriate, call for fortnightly progress reports from Anti-Terrorism Courts or their Administrative Judges to ensure compliance with directives for fair and expeditious trial. (d) Bail ----Abuse of concession---Scope---While disposing of the petition, the Supreme Court observed that the prosecution shall remain at liberty to renew its plea for cancellation of bail if abuse or non-cooperation is established. Disposition: Petition disposed of with directions.

Summary: The concealment of registration of F.I.R in Police recruitment by a candidate against the specific terms and conditions of recruitment will lead to his disqualification for deliberately and willfully concealing or withholding of solicited information. ----- (a) Constitution of Pakistan ----Arts. 18, 199---- Public employment—Recruitment to disciplined force—Requirement of full disclosure in application—Deliberate concealment of prior FIR—Effect—Scope of judicial review— Petitioner, having successfully passed the recruitment process for the post of Constable in District Muzaffargarh Police, was denied appointment due to concealment of an earlier FIR registered under Sections 354, 148, and 149 PPC—Petitioner argued that he had been declared innocent during investigation and subsequently discharged by the Magistrate, hence was under no obligation to disclose such information—Held, recruitment to a post is not a vested right but conditional upon fulfilling eligibility and disclosure requirements set by the department—Filing of a sworn affidavit and oath-bound application form obligates a candidate to truthfully disclose any past involvement in criminal proceedings—Registration of FIR and subsequent arrest were facts material to the evaluation of petitioner’s suitability and had been deliberately withheld—Such concealment constituted valid grounds for disqualification, irrespective of subsequent exoneration—Departmental action found to be in accordance with law and recruitment rules—Writ petition dismissed as meritless. Cited Cases: • Zeeshan Ahmad v. Government of Punjab (Civil Petition No. 4709/2019, Supreme Court, decided 01.11.2022) • Rizwana Altaf v. Chief Justice, High Court of Sindh 2020 SCMR 1401 • Abdul Manan v. Provincial Police Officer 2017 PLC (C.S.) 862 • Ali Hamza v. Government of Punjab 2018 PLC (C.S.) 1103 (b) Police Rules, 1934 ----R. 12.14 & R. 12.18---- Character verification of recruit—Requirement of unblemished record—Departmental discretion in assessment of suitability—Scope— Rules 12.14 and 12.18 mandate that great care be exercised in selecting men of good character for police service—Recruitment authorities are vested with discretion to assess suitability based on past conduct and disclosure compliance—Deliberate suppression of antecedents, including registered FIRs, frustrates the objective of character verification and undermines trust—Mere absence of criminal conviction does not eliminate the duty to disclose registered cases—Department lawfully declined issuance of appointment letter in light of concealment. Cited Provisions: • Police Rules, 1934, Rr. 12.14, 12.18 (c) Service Law—Recruitment in Police Department— ----Concealment of antecedents—False affidavit—Impact on eligibility— Held, submission of a false affidavit denying involvement in any FIR amounts to willful concealment of material information—Candidate had affirmed in writing that no FIR or criminal inquiry was pending against him despite record showing otherwise—Such misrepresentation disentitled the candidate to claim appointment—Supreme Court jurisprudence affirms that non-disclosure, even in cases of subsequent acquittal or discharge, justifies refusal of appointment to maintain integrity of public service, especially in law enforcement. Cited Case: • Umar Sheraz v. Government of Punjab 2025 LHC 965 — distinguished • Syed Ali Hassan Naqvi v. Senior Superintendent of Police PLJ 2024 Lahore (Note) 71 — distinguished • Syed Ali Raza Naqvi v. Chairman PPSC 2024 PLC (C.S.) 826 — not applicable Disposition: Petition dismissed—Concealment of FIR and misrepresentation in affidavit constituted valid ground for denial of appointment—No illegality found in respondents’ decision.

Summary: (a) Constitution of Pakistan: ----Arts. 9 & 199 Right to identity and due process––Blocking of CNIC––Jurisdiction of NADRA––Scope and limitations––Petitioner’s CNIC was digitally impounded based on a letter from intelligence agencies alleging fraud in acquisition of citizenship––Held, NADRA has no authority under the Constitution or National Database & Registration Authority Ordinance, 2000 to determine or revoke citizenship of a person once registered––Such action, absent prior adjudication by the Competent Authority under the Pakistan Citizenship Act, 1951, was unlawful––Citizenship is a fundamental right, and arbitrary deprivation thereof infringes the right to dignity and life protected under Art.9 of the Constitution––Due process must be strictly followed before impounding identity documents––Intelligence agencies cannot unilaterally determine or recommend cancellation of citizenship; they may only submit material to the Federal Government, which is the competent authority to adjudicate such matters––Petition was partly allowed with direction to NADRA to restore CNIC until lawful adjudication by competent forum. Cited Cases: • Fatima v. National Database and Registration Authority PLD 2022 Balochistan 73 • Hafiz Hamdullah Saboor v. Government of Pakistan PLD 2021 Islamabad 305 • Abdul Qadir v. Federation of Pakistan 2024 MLD 1774 • Hafiz Awais Zafar v. Judge Family Court, Lahore PLD 2022 Lahore 756 (b) National Database & Registration Authority Ordinance, 2000: ----S. 18(2)(a)––Scope––Cancellation or impounding of CNIC––Jurisdictional bar––Held, NADRA may impound a CNIC only in cases involving tampering, forgery, or duplication, or where the CNIC was obtained by impersonation, provided that eligibility is not based on citizenship determination––Where CNIC was issued after due process, NADRA must not act on mere suspicion or unverified reports to impound the card––Power to adjudicate questions of citizenship vests solely in the Federal Government under the Pakistan Citizenship Act, 1951––NADRA's reference of such matters to “Verification Boards” or “District Committees” was declared ultra vires––NADRA may only act after final adjudication by the competent authority––Petition was partly allowed and CNIC ordered to be restored temporarily. (c) Pakistan Citizenship Act, 1951 & Citizenship Rules, 1952: ----S. 16 & Citizenship Rules––Determination of citizenship––Exclusive jurisdiction of the Federal Government––Intelligence agency reports––Status––Held, the Federal Government is the sole competent authority to determine or revoke citizenship status––Intelligence agencies can report alleged fraud or concealment but cannot adjudicate or cause blocking of CNIC––Reports must be submitted to relevant Ministry, which may refer the case for adjudication––Right of citizenship cannot be revoked except by following the specific process under the Act and its Rules––Appeal under NADRA Ordinance does not substitute due process under the Citizenship Act––Restoration of CNIC directed pending lawful determination. ----Cited Cases: • Hafiz Hamdullah Saboor v. Government of Pakistan PLD 2021 Islamabad 305 • Abdul Qadir v. Federation of Pakistan 2024 MLD 1774 ----Disposition: Petition partly allowed––NADRA directed to temporarily restore Petitioner’s CNIC pending final determination by the Competent Authority under the Citizenship Act––Petitioner directed to cooperate and produce requisite documents––Respondents instructed to follow due process and ensure protection of fundamental rights.

Summary: Revision by plaintiff of specific performance suit against order of court directing payment of sale consideration (Apprehension of dismissal of main suit & recovery of Rs. 38,000,000)

Summary: Against order dated 14.10.2019 passed by learned ADJ East Islamabad whereby revision petition filed by respondent is patly allowed and directed the learned trial court to record the evidence of respondnet no.1

Summary: (a) Civil Procedure Code, 1908 (CPC) ----S. 12(2)—Ex parte decree—Application for setting aside—Grounds—Fraud—Misrepresentation—Want of jurisdiction—Burden of proof—Scope— Petitioner sought to set aside ex parte judgment and decree dated 15.12.2016 by invoking S.12(2), CPC, alleging that the decree was obtained through fraud and misrepresentation—Trial Court dismissed the application, holding that Petitioner failed to prove any of the statutory grounds under S.12(2), CPC—Held, to invoke S.12(2), CPC, Petitioner must substantiate existence of fraud, misrepresentation, or lack of jurisdiction—Personal service was effected, signatures matched those in CNIC and affidavit—Learned Civil Judge was empowered under Article 84 of Qanun-e-Shahadat Order, 1984 to compare signatures without forensic report—Petitioner failed to file application for setting aside ex parte proceedings within limitation and instead resorted to S.12(2), CPC without sufficient evidence—No illegality or material irregularity found in impugned order. Cited Provisions: S.12(2), CPC; Art. 84, Qanun-e-Shahadat Order, 1984; Art. 164, Limitation Act, 1908 (b) Limitation Act, 1908 ----Art. 164—Ex parte decree—Application to set aside—Limitation—30 days—Scope— Application for setting aside ex parte decree must be filed within 30 days under Article 164—Petitioner failed to avail remedy within limitation—Instead, belatedly invoked S.12(2), CPC without establishing fraud or misrepresentation—Held, Petitioner cannot bypass statutory limitation by framing ordinary procedural lapse as fraud. (c) Evidence Law—Signature verification—Article 84, Qanun-e-Shahadat Order, 1984—Judicial comparison of handwriting—Scope— Trial Court’s comparison of signatures on service summons and application under S.12(2) held valid—Court competent under Article 84 of QSO, 1984 to form opinion on handwriting—Forensic referral not mandatory where signature comparison is straightforward. Disposition: Civil Revision dismissed—Impugned Order dated 12.09.2023 upheld—Petitioner failed to prove grounds under S.12(2), CPC—No fraud, misrepresentation or jurisdictional defect established—No costs. "Revision against dismissal of application u/s 12(2) CPC filled by petitioner for setting aside Ex-Parte Judgment and Decree dated 15.12.2016."