Summary: The core question that requires adjudication is whether the fact that the vendor-respondent is a villager lady alone can be a ground for upending the sale transaction, when both the marginal witnesses have appeared and corroborated the stance of the purchaser?petitioner, and no connivance of the revenue officials concerned could be established? Held that in presence of overwhelming evidence supporting the validity of the transaction and in absence of any substantiated claim of fraud, the fact that the vendor is a villager lady alone cannot be made a ground for disputing the sale transaction.

Summary: Criminal Procedure Code (V of 1898)--- ----Ss. 498 & 403---Penal Code (XLV of 1860), Ss. 406 & 408---Criminal breach of trust, criminal breach of trust by a clerk or servant---Ad-interim pre-arrest bail, withdrawal of---Allegations against the accused-petitioner were that he being employee of complainant embezzled an amount of 26,300 Omani Riyal of which were given to him for the purchase of gold---Complainant reported the incident immediately to Pakistan Embassy at Oman and the matter was onward referred to FIA for legal action---Petitioner claimed that a crime report was already registered by the complainant at Masqat/Oman, there was no scope for lodging of second FIR with respect to the same occurrence in Pakistan---In the case in hand only a crime report was registered against the petitioner at Masqat/Oman---Petitioner was neither tried nor convicted or acquitted of the charge there---Petitioner escaped from Oman/Musqat and entered into the limits of Pakistan and was arrested by the F.I.A. authorities---Since case against the petitioner was just at initial stage of investigation at Oman, hence he could not seek the help of S.403, Cr.P.C.---Inquiry/investigation, arrest and trial of petitioner in Pakistan was legal and valid for all the purposes, therefore, objection raised by petitioner was devoid of any force, hence rejected outrightly---Record spoke that when petitioner committed embezzlement in Masqat/ Oman, he immediately transferred certain amounts into his bank account at Pakistan and bank account of his wife---Petitioner, being an employee of complainant, was entrusted with cash, diamond ring and bank card, which he misappropriated and converted the same to his own use in flagrant violation of his duties as an employee---Petitioner breached the trust of his employer/ complainant---Ingredients of offence of criminal breach of trust prescribed in S.405 of P.P.C were fully attracted---Whole of the documentary evidence floating on the surface during the investigation fully connected him with the crime alleged against him---Petitioner failed to dislodge his prima facie involvement in the offence---All the circumstances were encircling petitioner from all the sides---First Information Report presented a dreadful picture---Petitioner failed to show any mala fide or ulterior motive on the part of complainant for his false implication---Extra ordinary relief of pre-arrest bail, being available only for innocent people, could not be extended in favour of the petitioner---Another aspect of the matter had escaped the notice of Investigating Officer, as such it was appropriate to adhere to the same---Amount was transferred by petitioner from Masqat/Oman to Pakistan into his own bank account as well as the bank account of his wife with the knowledge that it was proceeds of crime, as such the relevant offences under the Anti-Money Laundering Act, 2010, were also prima facie made out against the petitioner---Investigating Officer of the case was supposed to look into the said aspect of the case---Thus, the present petition had no force---Ad-interim pre-arrest bail already allowed to the petitioner was withdrawn---Petition was dismissed, in circumstances. 2022 PCr.LJ 1511 and 2011 YLR 2882 rel. Zaqa Ullah Sohi and Sajjad Mehmood Bhatti with petitioner. Mian Muhammad Naseem for the Complainant. Tayyab Ahsan Siddiqui, Assistant Attorney General. Badar, SI/FIA, with record.

Summary: (a) Criminal Procedure Code (V of 1898)--- ----S.497 (2)--- Prevention of Electronic Crimes Act (XL of 2016), Ss. 3, 4, 13, 14 & 16---Penal Code (XLV of 1860), 419, 420, 468, 471 & 109--- Unauthorized access to information system or data, unauthorized copying or transmission of data, electronic forgery, electronic fraud, unauthorized use of identity information, cheating, forgery and abetment--- Bail, grant of--- Beneficiary of transaction--- Proof--- Case of further inquiry--- Accused persons were involved in acts of electronic financial fraud and forgery, specifically in the unlawful acquisition of funds from both national and international bank accounts--- It was to be determined after recording of evidence by Trial Court as to who utilized the accounts to perpetrate alleged offences---No conclusive evidence was gathered by investigating agency with regard to such aspect of prosecution case--- Due to absence of sufficient material at bail stage to connect accused persons with offences alleged against them, the matter had become one of further inquiry into their guilt in terms of S.497(2), Cr.P.C.--- Bail was allowed in circumstances. Mazhar Ali v. The State and another 2025 SCMR 318; Abdul Qadir alias Ali and another v. The State 2022 YLR Note 22; Alam Zeb and another v. The State and others PLD 2014 SC 760; Khurshid Soap and Chemical Industries (Pvt.) Ltd. v. Federation of Pakistan PLD 2020 SC 641; Pakistan Steel Mills Corporation v. Muhammad Azam Katper 2002 SCMR 1023; Muslim Commercial Bank Limited v. Punjab Labour Appellate Tribunal through Chairman, Lahore and others 2025 SCMR 303; Muhammad Shabbir and another v. Quaid-e-Azam University 2022 SCMR 487; Gul Hassan and Co. v. Allied Bank of Pakistan 1996 SCMR 237; The Commissioner Inland Revenue and others v. Mekotex (Pvt.) Limited and others PLD 2024 SC 1168; Nabi Ahmed v. Government of West Pakistan PLD 1969 SC 599; C.I.T v. Vatika Township 2015 SCC 1; Office Cherifien v. Yamashita-Shinnihon Steampship Co (1994) 1 AC 486; Secretary of State v. Tunnicliffe (1991) 2 ALL ER 712; Nagina Silk Mill v. Income-Tax Officer PLD 1963 SC 322; Province of East Pakistan v. Sharafatullah PLD 1970 SC 514; C.I.T. v. EFU Insurance Co. PLD 1982 SC 247; Ghulam Hyder Shah v. Chief Land Commissioner 1983 CLC 1585 + Chief Land Commissioner v. Ghulam Hyder Shah 1988 SCMR 715; Molasses Trading v. Federation of Pakistan 1993 SCMR 1905; Muhammad Hussain v. Muhamad 2000 SCMR 367; Footnote reproduced: Molasses Trading v. Federation of Pakistan 1993 SCMR 1905; Zila Counel Jehlum v. Pakistan Tobacco Company PLD 2016 SC 398; Shahnawaz (Pvt.) Ltd. v. Pakistan 2011 PTD 1558; Zaibun Nisa v. Land Commissioner PLD 1975 SC 397 and Yusuf Abbas v. Ismat Mustafa PLD 1968 Kar 480; Lalji Raja and Sons v. Firm Hansraj Nathuram (1971)1 SCC 721 (5MB). Hamilton Gell v. White [1922] 2 K.B. 422; Abbot v. Minister for Lands [1895] A.C. 425; Ogden Industries Pty. Ltd. v. Lucas [1969] 1 All E.R 121; Emperor v. Shreekant Pandurang Kethar (1943) 46 Bom. L.R. 50; Government of Punjab v. Kamran Bashir 2022 PLC (C.S.) 6; Nabi Ahmed v. Government of West Pakistan PLD 1969 SC 599; Zaman Cement Co. v. CBR 2002 SCMR 312; Asdullah Mangi v. PIA Corporation 2005 SCMR 445; Syed Muhammad Ali Jaferi v. The State and another 2025 SCMR 838 rel. (b) Prevention of Electronic Crimes Act (XL of 2016)--- ---- Ss. 13, 14 & 43--- Amendment to nature of offences--- Principle--- Amendment made to S.43 of Prevention of Electronic Crimes Act, 2016 whereby offences under Ss.13 and 14 of Prevention of Electronic Crimes Act, 2016 have been converted into non-bailable offences is not merely procedural but substantive in nature--- Such amendment applies prospectively. Alam Zeb and another v. The State and others PLD 2014 SC 760 and, Mian Mahmud Ali Qasuri and others v. The State PLD 1963 SC 478 rel. Tahir Hussain Khan Malazai for Petitioner (in Crl. Misc. No. 10519-B of 2024). Rana Abdul Rehman for Petitioner (in Crl. Misc. No. 10278-B of 2024). Mehroz Aziz Khan, Assistant Attorney General for Pakistan, with Atif Khan, SI for the State. Muhammad Jawad Zafar, J .--- Through this common order, Crl. Misc. No.10519-B of 2024, titled “Muhammad Rizwan v. The State and another”, and Crl. Misc. No.10278-B of 2024, titled “Irfan Ali v. The State and another”, are being decided because both the petitions, filed under Section 497 of the Code of Criminal Procedure 1898 (“Code” or “Cr.P.C”), are emanating from crime report bearing FIR No. 122 of 2024, dated 07.11.2024, for offences under Sections 3, 4, 13, 14, and 16 of the Prevention of Electronic Crimes Act 2016 (“PECA”) and Sections 419, 420, 468, 471, and 109 of the Pakistan Penal Code 1860 (“P.P.C”), registered with Federal Investigation Agency (“FIA”) Cyber Crime Reporting Centre, Multan (“Crime Report” or “FIR”). Both petitioners seek grant of bail after arrest.

Summary: (a) Criminal Procedure Code (V of 1898)--- ----S. 497(2)---Penal Code (XLV of 1860), Ss. 324 & 109---Explosive Substances Act (VI of 1908), S. 6---Attempt to commit qatl-i-amd, abetment, possession of explosive substance---Bail, grant of---Further inquiry---Allegations against the petitioner-accused were that he along with his co-accused attempted to commit murder of complainant by opening fires from outside of house of the complainant and one bullet hit the complainant---From perusal of record it transpired that the complainant had nominated the present petitioner/accused and his co-accused on the basis of suspicion claiming that he had old enmity with the co-accused of the present petitioner and the present petitioner and his father were relative of the other accused, therefore, the present petitioner and his co-accused might have opened fire on him---Neither any eye-witness nor the complainant himself witnessed/saw the accused/petitioner and his co-accused at the place of occurrence---No specific role had been attributed to the accused/petitioner in the FIR and no incriminating material/weapon of offence had been recovered from the present petitioner/accused by the police during investigation of the case---Petitioner/accused was confined in judicial custody since the day of his arrest and police had submitted challan against him in the Court of competent jurisdiction, hence, the petitioner was not required for further investigation---Therefore, keeping in view the facts and circumstances of the case, prima facie case against the petitioner/accused required further inquiry as contemplated under subsection.(2) of S.497, Cr.P.C.---Moreover, three other nominated co-accused of the petitioner/accused had been discharged under S.169, Cr.P.C., by the police---One co-accused had been released on bail by High Court, hence, rule of consistency applied to the case of the present petitioner/accused and he was entitled for concession of post arrest bail---Bail petition was allowed, in circumstances. 2025 MLD 173; 2017 MLD 386 and 2020 SCMR 1486 ref. (b) Criminal Procedure Code (V of 1898)--- ----S. 497---Bail order---Observations of the Court---Scope---Observations made in thebail order regarding factual aspects of case are tentative in nature---Trial Court should adjudicate the case strictly on its merits based solely on the evidence without being influenced by such observations. Imtiaz Hussain and Zafeer Ahmed for Petitioner. Dy. A.G Malik Sherbaz for the State. Mushtaq Ahmed for the Complainant. Date of hearing: 4th March, 2025.

Summary: When accused was related and already known to the complainant as well as injured/victim but not nominated in the F.I.R. as well as in the statement of injured who was vitally stable at the time of his medical examination then subsequent nomination of the accused through supplementary statements of the complainant and injured require evidential verification during trial of the case.

Summary: This judgement decides whether amendment to Section 43 of PECA via the 2025 Amendment Act, whereby certain offences have been converted from bailable to non-bailable, is substantive in nature or merely procedural. Based on the above, it is deliberated whether the Amendment Act will have prospective or retrospective applicability.

Summary: When as per ocular account, deceased died in the hospital however column No.24 of the inquest report clearly reflects that the dead body was lying in the area of the complainant, then case of the prosecution is bound to fall like the house of cards and benefit will go to convict.

Summary: Declining Glasgow Coma Scale (GCS) indicates a worsening neurological condition due to head injuries, stroke and other brain related issues.

Summary: Summary pending

Summary: Summary pending