Summary: Bail granted --- (a) Anti-Money Laundering Act, 2010 – Ss. 3 & 4 – CrPC, S. 497(1) – Prohibitory clause – Bail in money laundering cases – Scope of sentence range While determining the applicability of the prohibitory clause of Section 497(1) CrPC, the maximum prescribed sentence under Section 4 of the AMLA (1 to 10 years) must be considered—not the minimum. The Supreme Court clarified that courts at bail stage are not permitted to undertake speculative exercises about the likely sentence. This aligns with the rulings in Socha Gul v. State (2015 SCMR 1077) and Qasim Ali case (2019 SCMR 1928), overruling earlier views that focused on minimum sentence (e.g., Jamal-ud-Din v. State). Held: Section 3 AMLA falls within the prohibitory clause of Section 497(1) CrPC. (b) CrPC, S. 497(2) – Further inquiry – Post-arrest bail – Circumstantial bail grant Petitioner Jabran, alleged to be a front-man aiding money laundering, had no direct role in predicate offences and was not nominated in FIRs based on them. Documentary evidence showed he merely brokered the property deal and his cheque used as security was never encashed. Moreover, he was incarcerated for over six months without submission of challan. Held: Case warranted further inquiry; bail granted under Section 497(2) CrPC. (c) Anti-Money Laundering Act, 2010 – S. 2(xxiii) – “Proceeds of crime” – Nexus with predicate offences – Timing of property purchase Accused Muhammad Afnan Alam was alleged to have purchased properties from proceeds of crimes allegedly committed while serving in CDA. However, scrutiny of interim challan and official records showed that the three questioned properties were purchased before the relevant allotment approvals forming the predicate offences, raising doubt over nexus. Held: In absence of clear connection with predicate offences and with bail already granted in all predicate FIRs, case fell under further inquiry. (d) Constitutional Rights – Article 10-A – Fair trial and due process – Bail as a safeguard against pre-trial punishment Both accused were incarcerated without trial for extended durations, with no risk of tampering with documentary evidence. In light of Article 10-A, prolonged pre-trial detention without strong evidence linking them directly to laundering proceeds of crime violated fair trial guarantees. Held: Bail granted to preserve due process rights. Disposition: Leave granted. Petitions converted to appeals. Bail granted to Jabran and Muhammad Afnan Alam in FIR No.02/2024 under AMLA Ss. 3 & 4, subject to furnishing bail bonds of PKR 1,000,000 with two sureties each.

Summary: Bail granted ---- (a) Constitution of Pakistan (1973) ----Art. 10-A--- Right to fair trial---Scope---Held, that in criminal proceedings involving multiple accused persons and overlapping FIRs, Anti-Terrorism and Trial Courts must ensure the accused’s access to fair trial under Art. 10-A, including timely provision of case records, exemption from personal appearance where legally warranted, and attention to logistical challenges due to concurrent proceedings. (b) Criminal Procedure Code (V of 1898) ----S. 497(1)--- Bail---Prohibitory clause---Scope---Interpretation of punishment range---Held, for purposes of S. 497(1), Cr.P.C., the maximum punishment prescribed under the statute is to be considered in determining application of the prohibitory clause; courts cannot base decisions on speculative minimum sentencing or sentencing guidelines. Previous contrary interpretation in Jamal-ud-Din v. State (2012 SCMR 573) and Khuda Bux v. State (2010 SCMR 1160) clarified and departed from. [Ref: Socha Gul v. State (2015 SCMR 1077), ANF v. Qasim Ali (2019 SCMR 1928)] (c) Anti-Money Laundering Act (VII of 2010) ----Ss. 3 & 4--- Money laundering---Bail---Petitioners accused of laundering proceeds of crime through purchase of property and vehicle---Petitioner No. 1 alleged to have acted as frontman and issued cheque for Rs.3.5 million---Cheque not encashed and property documents indicated role of a property dealer---Held, case against both petitioners fell under “further inquiry” per S. 497(2), Cr.P.C.---All predicate offences under FIRs No.03, 05, and 11/2024 arose after the acquisition of properties mentioned in FIR No.02/2024---Prosecution’s reliance on documents already in possession and lack of tampering risk justified grant of post-arrest bail. (d) Interpretation of Statutes ----Statutory construction--- “Punishable” under S. 497, Cr.P.C.---Held, the term “punishable” in prohibitory clause must be interpreted in light of maximum sentence prescribed in law, not minimum threshold---Any contrary approach amounts to prejudging the merits and usurping trial court’s discretion on sentencing. (e) Bail ----Post-arrest bail---Further inquiry---Predicate offences---Held, where accused has already secured bail in all predicate offences from which alleged proceeds of crime were generated, new case under AMLA, based on same allegations, falls within scope of further inquiry---Interim findings or suspicion do not justify continued incarceration absent concrete proof of illegal gains. Disposition: Leave to appeal granted. Petitions converted into appeals and allowed. Petitioners admitted to post-arrest bail subject to furnishing bail bonds of Rs. 1,000,000/- each with two sureties to satisfaction of trial court.

Summary: Bail granted ----- (a) Criminal Law – Post-Arrest Bail – Further Inquiry---Bail—Grant of post-arrest bail under Section 497(2) Cr.P.C.—Allegations against petitioners pertain to electronic financial fraud and forgery under the Prevention of Electronic Crimes Act, 2016 ("PECA") and Pakistan Penal Code, 1860 ("PPC")—No conclusive evidence linking petitioners to offenses—Held, due to lack of sufficient material at this stage, case falls under "further inquiry" as per Section 497(2) Cr.P.C.—Reliance placed on Mazhar Ali v. The State (2025 SCMR 318), Abdul Qadir alias Ali v. The State (2022 YLR Note 22 Sindh).(b) Bailable Offenses – Right to Bail---Statutory rights—Offenses under Sections 3, 4, 13, 14, and 16 of PECA and Sections 420 and 471 of PPC are bailable—Held, in bailable offenses, bail is an indefeasible right of the accused, and there is no provision in the Code permitting cancellation of such bail—Reliance placed on Mian Mahmud Ali Qasuri v. The State (PLD 1963 SC 478), Alam Zeb v. The State (PLD 2014 SC 760).(c) Retrospective Application of Law – Substantive vs. Procedural Amendment---Statutory interpretation—Whether the Prevention of Electronic Crimes (Amendment) Act, 2025 ("Amendment Act")—which converted offenses under Sections 13 and 14 of PECA from bailable to non-bailable—applies retrospectively—Held, amendments affecting substantive rights operate prospectively unless expressly stated otherwise—Grant of bail in bailable offenses is a substantive right, not a procedural matter—Therefore, the Amendment Act applies prospectively and does not affect cases registered before its promulgation on 29.01.2025—Reliance placed on Khurshid Soap and Chemical Industries v. Federation of Pakistan (PLD 2020 SC 641), Pakistan Steel Mills Corporation v. Muhammad Azam Katper (2002 SCMR 1023), Muhammad Shabbir v. Quaid-e-Azam University (2022 SCMR 487), Mekotex (Pvt.) Ltd. v. Commissioner Inland Revenue (PLD 2024 SC 1168).(d) Bail as a Substantive Right – Change in Bail Status as a Vested Right---Bail jurisprudence—Conversion of bailable offenses into non-bailable offenses through amendment—Held, bail in bailable offenses is an absolute, vested right and cannot be taken away retrospectively—Changes affecting personal liberty are substantive, not procedural, and therefore do not apply retroactively—Reliance placed on Emperor v. Shreekant Pandurang Ketkar (1943 46 Bom. L.R. 50 (FB)), State (Govt. of NCT of Delhi) v. Pankaj Yadav (Indian Kanoon), Alam Zeb v. The State (PLD 2014 SC 760), Mian Mahmud Ali Qasuri v. The State (PLD 1963 SC 478).(e) Non-Prohibitory Offenses – Bail as a Rule---Non-prohibitory clause—None of the offenses in PECA or PPC invoked in the FIR fall under the prohibitory clause of Section 497(1) Cr.P.C.—Held, grant of bail in non-prohibitory offenses is a rule, and refusal is an exception—Petitioners incarcerated since 07.11.2024—No risk of absconding or tampering with prosecution evidence—Bail granted—Reliance placed on Syed Muhammad Ali Jaferi v. The State (2025 SCP 61), Ahmad Shahzad v. The State (2023 SCMR 679), Muhammad Ajmal v. The State (2022 SCMR 274), Ahmad Khalid Butt v. The State (2021 SCMR 1016).----- Disposition:Criminal Misc. Nos. 10519-B and 10278-B of 2024 allowed – Bail granted.Amendment Act, 2025 held to apply prospectively, ensuring no retrospective impact on offenses registered before 29.01.2025.Petitioners released on bail upon furnishing surety bonds of PKR 1,000,000/- each, with two sureties in like amount.

Summary: a) Constitution of Pakistan ----Arts. 4, 10-A, 15, 25 & 199 Freedom of movement—Placement of civil servant’s name on PNIL, PCL and restricted lists—Scope and legality—Petitioner, a serving Collector of Customs, challenged inclusion of his name on travel restriction lists without notice or hearing—Name was placed on Passport Control List (PCL) under Rule 22(2)(b) of the Passports Rules, 2021, and on PNIL under FIA Standing Order No. 2/2018 in connection with FIR No. 19/2023 registered under S. 5(2) PCA, 1947, read with Customs Act, 1969 and S. 109, PPC—Held, petitioner was not a fugitive nor accused of any heinous crime as required for PNIL placement—FIA acted mechanically without applying mind or forming opinion independently—Name placed on PCL without approval of Federal Government, in violation of Rule 22 and law laid down in Mustafa Impex case—No show cause notice issued nor any opportunity of hearing afforded—Action held to be arbitrary, mala fide, and lacking lawful authority—Fundamental rights under Arts. 4 (due process), 10-A (fair trial), and 15 (freedom of movement) were infringed—Availability of alternate remedy before Review Committee did not bar exercise of constitutional jurisdiction where violation of fundamental rights was apparent—Petition allowed. Cited Cases: • Govt. of Pakistan and another v. Dada Amir Haider Khan, PLD 1987 SC 504 • Federation of Pakistan v. General (R) Pervez Musharraf, PLD 2016 SC 570 • Federal Government v. Ms. Ayyan Ali, 2017 SCMR 1179 • Sheikh Shan Ilahi v. Federation of Pakistan, PLD 2023 Lahore 359 • Messrs Mustafa Impex v. Government of Pakistan, PLD 2016 SC 808

Summary: Bail granted ---- a) Criminal Procedure Code (V of 1898) ---- ----S. 497---Bail in cases not falling within prohibitory clause---Marital disputes and allegations of cyber harassment---Judicial discretion in granting bail. The petitioner, a medical professional, was accused of accessing and disseminating private images of his spouse on social media, allegedly for blackmail. The prosecution asserted that the act amounted to sexual harassment and tarnished the complainant's reputation. The petitioner contended that the case arose from a marital dispute and that the allegations were exaggerated. The Supreme Court noted that the offences in question carried a maximum punishment of five and three years, respectively, and did not fall within the prohibitory clause of S. 497, Cr.P.C. The Court emphasized that bail is a rule and refusal an exception, particularly where the accused has been in custody for months without trial. Finding no exceptional circumstances warranting denial of bail, the Court granted bail to the petitioner, directing the Trial Court to expedite proceedings. Cited Cases: Abdul Samad v. The State 2025 SCP 31 Abdul Hayee and Abdullah alias Ghazali & another v. The State 2025 SCMR 281 Syed Fida Hussain Shah v. The State 2024 SCMR 1622

Summary: (a) Constitution of Pakistan ----Arts. 4, 10-A, 15 & 199 Freedom of movement—Passport blocked and name placed on Passport Control List (PCL)—Legality—Petitioner was stopped at airport and informed his passport had been blocked by FIA due to inclusion of name on blacklist—Respondents placed petitioner’s name on PCL based on recommendation of FIA Balochistan Zone, citing deportation by Iranian authorities for illegal stay in 2021—No notice issued, no opportunity of hearing granted, and no approval obtained from Federal Government as required under Rule 22(1) of the Passports Rules, 2021—Held, petitioner’s fundamental rights under Arts. 4, 10-A and 15 of the Constitution were violated—Power to regulate travel rests with the Federal Government, which includes the Cabinet, not subordinate agencies—Absence of due process and lack of lawful authority rendered action void—Mere deportation in past without present legal bar or criminal case could not justify continued restriction—Petitioner held valid visa and intended to travel abroad for employment—Action declared illegal, arbitrary and mala fide—Petition allowed, and respondents directed to immediately remove petitioner’s name from PCL. Cited Cases: • Messrs Mustafa Impex v. Government of Pakistan, PLD 2016 SC 808 • Controller General of Accounts v. Fazil Ahmad, 2021 SCMR 800 • Govt. of Sindh v. Dr. Nadeem Rizvi, 2020 SCMR 1 • Dr. Shireen M. Mazari v. Federation of Pakistan, 2024 MLD 1020 • Rasikh Ellahi v. Federation of Pakistan, 2024 YLR 2616 • Tariq Shafi v. Federation of Pakistan, W.P. No. 224/2024 • Faisal Maqbool Sheikh v. Federation of Pakistan, W.P. No. 2141/2023 • Fawad Ahmed v. Federation of Pakistan, W.P. No. 2129/2024 • Sadaf Sharjeel v. NAB, 2022 YLR 2441 • Farah Mazhar v. Federation of Pakistan, PLD 2022 Lahore 119 • Syed Zulfiqar Abbas Bukhari v. Federation of Pakistan, PLD 2019 Islamabad 316 • Dr. Joseph Wilson v. Federation of Pakistan, 2017 PCrLJ 1569 • Mahboob Ali Abro v. Ayyan Ali, 2016 PSC 938 • Sohail Latif v. Federation of Pakistan, PLD 2008 Lahore 341

Summary: (a) Offense of Qazf (Enforcement of Hudood) Ordinance, 1979: ---- Ss. 3, 5, 6 & 7 ---- Qazf liability for denying paternity of a child ---- Whether denial of paternity of a child amounts to qazf against the mother ---- Respondent No. 2, after divorcing the petitioner, denied the paternity of their third daughter, alleging that he was abroad during the time of conception ---- The Federal Investigation Agency (FIA) confirmed that the respondent was present in Pakistan within the relevant period ---- Held, denial of paternity, when unfounded, constitutes an attribution of zina against the mother, falling under the definition of qazf ---- The Federal Shariat Court had previously held that hadd punishment could not be awarded due to lack of tazkiyat-al-shuhud (witness verification) ---- Supreme Court ruled that tazkiyat-al-shuhud was unnecessary as the qazf was committed in the presence of the court. (b) Islamic Law ---- ---- Li’an and its applicability in Qazf cases ---- Procedure under S. 14 of the Ordinance ---- Li’an (mutual imprecation) applies when a husband accuses his wife of zina while the marriage is subsisting ---- Held, since the respondent’s accusation was made after divorce, Li’an was not applicable ---- Respondent’s statement, both in court and in the divorce deed, constituted qazf liable to hadd under S. 6(1)(b) of the Ordinance ---- Reference made to Islamic juristic authorities, including Imam Kasani, Imam Marghinani, and Imam Sarakhsi, affirming that post-divorce denial of paternity attracts qazf liability rather than Li’an. (c) Qanun-e-Shahadat Order, 1984: ---- Art. 128 ---- Legitimacy of a child ---- Presumption of legitimacy in Islamic and statutory law ---- A child born during a valid marriage or within two years after its dissolution is conclusively presumed to be legitimate, provided the mother remains unmarried ---- Respondent No. 2’s denial of paternity was contrary to this presumption ---- Supreme Court reaffirmed the principles established in Ghazala Tehsin Zohra v. Mehr Ghulam Dastagir Khan (PLD 2015 SC 327), emphasizing the societal importance of protecting the legitimacy of children. (d) Criminal Procedure ---- ---- Withdrawal of complaint and impact on Hadd punishment ---- In Islamic jurisprudence, the complainant’s continued pursuit of punishment is essential for enforcing Hadd ---- Petitioner withdrew her request for the respondent’s punishment, stating that her only concern was the legitimacy of her child ---- Held, as per classical juristic principles, withdrawal created shubhah (doubt), preventing the imposition of Hadd punishment ---- Supreme Court sustained the acquittal of Respondent No. 2 but clarified that his act constituted qazf liable to hadd. ----Disposition: Shariat Review Petition allowed to the extent that Respondent No. 2’s accusation constituted Qazf, not Li’an. However, as the petitioner withdrew her demand for punishment, proceedings could not continue. The legitimacy of the child was affirmed, and Respondent No. 2’s acquittal was sustained.

Summary: (a) Criminal Procedure Code (V of 1898): ----S. 160—Federal Investigation Agency (FIA) inquiry—Legality of Joint Venture (JV) Agreement—Stay of criminal proceedings pending civil litigation—Principle of sub-judice—Binding effect of High Court's decision under Art. 201 of the Constitution—Doctrine of mens rea—Petitioners impugned notices issued by FIA under S.160 of the Cr.P.C. in connection with an inquiry into the legality of a Joint Venture Agreement between Pakistan Television Corporation (PTV), GroupM Pakistan Pvt. Ltd., and ARY Communications Ltd.—Lahore High Court, in Independent Media Corporation (Pvt.) Ltd. v. Federation of Pakistan (PLD 2022 Lahore 288), had already adjudicated that the JV Agreement resulted from a transparent and competitive bidding process and suffered from no legal infirmity—Petitioners argued that FIA’s inquiry was mala fide, aimed at prejudicing the Lahore High Court’s ruling and proceedings pending before the Sindh High Court regarding the JV Agreement’s validity—Held, under Art. 201 of the Constitution, a decision of the High Court on a question of law is binding on subordinate courts and executive functionaries—Doctrine of sub-judice under Art. 204(2)(c) of the Constitution prohibits initiation of proceedings that may prejudice a pending matter before the High Court—FIA inquiry and criminal proceedings against the petitioners stayed, as any determination of criminal liability depended on the outcome of pending civil proceedings before the Lahore and Sindh High Courts. ----Cited Cases: • Muhammad Akbar v. The State (PLD 1968 SC 281) • SW Sugar Mills Ltd v. FBR, Islamabad and Others (2020 PTD 925) • Abdul Ahad v. Amjad Ali and Others (PLD 2006 SC 771) • Misbah ud din Zaigham and Others v. FIA and Others (2021 CLD 906) • Akhlaq Hussain Kayani v. Zafar Iqbal Kiyani and Others (2010 SCMR 1835) • Universal Cables Industries Ltd. v. Federation of Pakistan (PLD 2020 Sindh 601) (b) Constitution of Pakistan: ----Art. 204(2)(c)—Contempt of court—Prejudice to pending proceedings—Judicial restraint on executive action—Effect of High Court’s decision on subordinate courts and executive authorities—Held, executive authorities, including FIA and PTV, could not initiate criminal proceedings that would directly or indirectly defeat the Lahore High Court’s ruling regarding the JV Agreement’s legality—Any investigative or prosecutorial action taken by FIA in this matter, while parallel civil proceedings were pending before the High Courts, would violate the doctrine of sub-judice and fall within the ambit of contempt under Art. 204(2)(c) of the Constitution. (c) Administrative Law: ----FIA Act, 1974—Jurisdiction of FIA—Fact-finding committees—Presumption of legality in executive actions—Standard for judicial intervention in investigative proceedings—FIA initiated inquiry No. RE-150/2022 based on the recommendations of a fact-finding committee constituted by PTV—Petitioners contended that the committee lacked impartiality as its members had previously approved the JV Agreement—Held, Courts generally do not interfere in police or FIA investigations unless there is a jurisdictional defect or evident mala fide—However, where an inquiry appears to undermine a judicial determination or pending litigation, the courts may exercise discretion to stay proceedings—FIA was barred from proceeding with any criminal charges against petitioners until resolution of pending civil litigation. (d) Corporate Law—Public Procurement: ----Public Procurement Regulatory Authority Ordinance, 2002 & Public Procurement Rules, 2004—Application to Joint Venture agreements—Determination of legal framework governing procurement processes—Fact-finding committee concluded that the JV Agreement violated the PPRA framework, while PTV’s Board had initially advised that the framework did not apply—Held, Lahore High Court left the question of PPRA framework applicability open but affirmed that the agreement was reached through a lawful and transparent process—FIA’s inquiry could not retroactively re-characterize the agreement as illegal in the absence of an appellate court setting aside the Lahore High Court’s decision. ----Disposition: Petitions allowed. FIA was restrained from framing criminal charges against the petitioners during the pendency of civil proceedings before the Lahore High Court and Sindh High Court. FIA was required to seek permission from the respective High Courts before initiating any further action.

Summary: (a) Constitution of Pakistan ----Arts. 15, 20 & 199 Fundamental rights—Freedom of movement and religion—Petitioners argued that offloading passengers from an international flight and registering FIR No. 215/2024 violated their constitutional rights under Arts. 15 and 20 of the Constitution. Held, that fundamental rights are not absolute and may be lawfully restricted under specific circumstances, such as national security, public safety, or public interest. Restrictions on international travel are permissible to ensure compliance with immigration laws and international obligations, provided they are proportionate and non-discriminatory. (b) Prevention of Trafficking in Persons Act, 2018 (PTPA) ----Ss. 3, 4, & 5---Trafficking in persons—Elements of coercion, fraud, or exploitation—Case involved allegations of sending individuals abroad under the guise of Umrah visas for organized begging. Held, that allegations, including financial exploitation and control over victims, prima facie satisfied the elements of trafficking under Ss. 3 and 4 of the PTPA. However, determination of whether trafficking occurred required further investigation and factual determination at trial. (c) Emigration Ordinance, 1979 ----S. 22(b)---Unauthorized emigration and exploitation—Petitioners allegedly charged individuals for fake Umrah visas without hotel bookings or return tickets. Held, that while initial facts did not conclusively justify invoking S. 22(b), the Investigating Officer could incorporate the provision if further evidence emerged during investigation. (d) Criminal Procedure Code (V of 1898) ----Ss. 154 & 561-A---Quashing of FIR—Principles—FIR can be quashed only where it unequivocally fails to establish an offence or reflects clear misuse of legal authority. Supreme Court precedents emphasize that quashing an FIR during investigation disrupts the criminal justice process and should only be exercised in extraordinary circumstances. In the present case, the allegations in FIR No. 215/2024 constituted a prima facie case, and there were no grounds for quashing. (e) Vagrancy Laws ----Punjab Vagrancy Ordinance, 1958 & Punjab Destitute and Neglected Children Act, 2004—Organized beggary—Definitions and remedies—While beggary alone does not fall under the PTPA unless it involves coercion or exploitation, it may constitute an offence under the Vagrancy Ordinance or other laws addressing organized begging. Cited Cases: • Pakistan Muslim League (N) v. Federation of Pakistan (PLD 2007 SC 642) • Bashir Ahmad v. Zafar-ul-Islam (PLD 2004 SC 298) • Ajmeel Khan v. Abdur Rahim (PLD 2009 SC 102) • The State v. Chaudhry Muhammad Khan (2024 SC decision) ------ Disposition: Petition for quashing FIR No. 215/2024 dismissed. Held, that the investigation must proceed, and the trial court shall address the applicability of the PTPA or vagrancy laws based on evidence.

Summary: The Supreme Court of Pakistan has ruled that FIRs cannot be quashed once a challan has been filed, affirming the limited scope for judicial intervention during the investigative process. Justice Syed Hasan Azhar Rizvi emphasized that "quashment of FIR during investigation tantamounts to throttling the investigation, which is not permissible in law," underlining that such judicial powers are reserved for truly exceptional cases. ------ - Key Points of the Judgment include: ------ 1) Judicial and Investigative Roles Are Distinct: Justice Rizvi highlighted the complementary, non-overlapping roles of the judiciary and law enforcement, stating that law enforcement is obligated under Section 154 of the Code of Criminal Procedure to investigate cognizable offences. Courts should not interfere with this duty unless the case is extraordinary. ------ 2) Concurrent Civil and Criminal Proceedings: The judgment clarified that a concurrent civil dispute does not preclude criminal proceedings. Justice Rizvi referenced precedent, stating that "a criminal case must be allowed to proceed on its own merits, regardless of any parallel civil matters." Criminal and civil cases can coexist and be adjudicated independently. ------ 3) Grounds for Quashment Must Be Exceptional: FIR quashment is only permissible if there is clear evidence of misuse of legal authority or if the allegations lack legal basis. Justice Rizvi noted that concerns over conviction probability should be handled within trial proceedings and not preempt the investigation. ----- 4) No Premature Judicial Intervention: The Court emphasized that quashing an FIR should not impede the police's statutory role in evidence gathering. Interference should be limited to cases where allegations unequivocally indicate no offence or a clear abuse of process. ------ This case involves Civil Petitions No. 671-L and 672-L of 2017, where the State challenged the Lahore High Court, Multan Bench’s decision to quash FIR No. 58/2012. This FIR, registered on August 2, 2012, alleged that the respondents fraudulently transferred significant state land in Tehsil Jalalpur to private persons using forged orders from the Deputy Settlement Commissioner. An inquiry by the Anti-Corruption Establishment (ACE) revealed irregularities, leading to FIR registration. However, the respondents contended that the FIR was baseless and filed with malafide intent, ultimately convincing the High Court to quash it. ------Issues ------1) Whether the High Court erred in quashing an FIR involving alleged fraudulent land transfers under Article 199 of the Constitution. ------2) Whether the existence of a civil dispute negates the necessity for criminal proceedings. ------3) Whether the High Court’s quashing of the FIR was justified based on the improbability of conviction. ------Holding/Reasoning/Outcome The Supreme Court set aside the High Court’s order, finding that quashing the FIR was improper. Key points of reasoning include: The High Court’s jurisdiction under Article 199 to quash FIRs is limited to cases where the FIR is evidently without legal basis or constitutes an abuse of legal authority. Criminal proceedings should not be prematurely quashed, especially when material evidence supports a cognizable offense. The existence of a civil dispute does not preclude criminal liability; both civil and criminal proceedings can proceed concurrently if the facts disclose a criminal offense. Probable conviction or acquittal is a matter for trial courts to decide, and without strong evidence of malafide intent by investigative authorities, the FIR should not have been quashed at this stage. ------Citations/Precedents Ajmeel Khan v. Abdul Rahim and others (PLD 2009 SC 102) – On the complementary roles of judiciary and police and the conditions under which an FIR may be quashed. FIA, Director General FIA and others v. Syed Hamid Ali Shah and others (PLD 2023 SC 265) – Reaffirming the High Court’s power to quash FIRs when the allegations do not constitute a cognizable offense. Seema Fareed and Others v. The State and another (2008 SCMR 839) – Civil disputes do not bar criminal proceedings if criminal liability is indicated. Neeharika Infrastructure v. State of Maharashtra (AIR 2021 SC 5041) – Guidelines on judicial restraint in staying investigations and quashing FIRs in India. Mst. Tayyeba Ambareen v. Shafqat Ali Kiyani (2023 SCMR 246), Amir Jamal v. Malik Zahoor-ul-Haq (2011 SCMR 1023), Fida Hussain v. Mst Saiqa (2011 SCMR 1990) – High Court’s limited scope under Article 199 in cases requiring factual determinations. The Supreme Court allowed the appeals, thereby reinstating the FIR for investigation and trial.