Summary: (a) Constitution of Pakistan (1973), Art. 199—Writ jurisdiction—Multiple FIRs—Positive jurisdiction under S. 185 Cr.P.C.—High Court’s non-determination of jurisdictional claim—Remand ordered The petitioner challenged the registration of multiple FIRs under writ jurisdiction, invoking Section 185 Cr.P.C. before the Lahore High Court. The Supreme Court noted that the High Court failed to examine the petitioner’s core contention under Section 185 Cr.P.C., as it confined its decision only to joinder of charges under Section 239 Cr.P.C. The omission warranted interference, and the case was remanded for fresh adjudication. Held: Failure to decide a critical jurisdictional plea amounts to a legal error and justifies remand. Relevant Provision: Section 185, Cr.P.C. (Jurisdiction to try offences subject to High Court’s direction) (b) Constitution of Pakistan (1973), Art. 199—Scope of remand—Maintainability objections—Trial continuation not barred—Direction to High Court to decide pending writs uninfluenced by Supreme Court observations The Court clarified that its earlier remand order in Civil Petition No. 14 of 2025 was limited to addressing the Office’s objections to maintainability and did not preclude the High Court from examining merits. In the instant case, the Supreme Court directed the High Court to adjudicate both connected writ petitions afresh, uninfluenced by prior procedural history. Held: The High Court must decide all pending matters, including joinder and multiple FIR issues, independently and expeditiously. (c) Anti-Terrorism Trials—Simultaneous proceedings—No bar on trial progression—Remedy for suspension lies before High Court Petitioner requested suspension of trials in Anti-Terrorism Courts at Lahore and Faisalabad pending High Court proceedings. The Supreme Court refused to interfere, holding that suspension of trial is within the High Court’s jurisdiction, and that the trial courts should proceed in accordance with law unless directed otherwise by competent authority. Held: No stay on ATC proceedings; High Court empowered to decide suspension on merits. Disposition: Petition converted into appeal and partially allowed. Impugned judgment of Lahore High Court dated 20.03.2025 set aside. Writ Petition No. 17090/2025 deemed pending and remanded for fresh decision along with Case Diary No. 174515/2024.

Summary: Bail granted ---- (a) Legal Practitioners and Bar Councils Act, 1973 ----Ss. 58 & 59---Punjab Legal Practitioners & Bar Council Rules, 2023, Rr. 4.17, 4.19, 4.21, 4.23, 4.25 & 4.26---Impersonation as advocate---Mode of prosecution---Maintainability of FIR---Petitioner accused of fraudulently impersonating a lawyer and threatening complainant during court proceedings---FIR registered under various Penal Code sections without involvement of Punjab Bar Council---Held, prosecution for impersonation as an advocate must originate through prescribed mechanism under Punjab Bar Council Rules---No prior complaint or inquiry initiated by Punjab Bar Council before registration of FIR---Executive Committee of Bar Council is competent authority to investigate and initiate criminal proceedings under S. 58 of the Act---Private individuals cannot unilaterally initiate prosecution in such matters unless Bar Council declines to act---FIR held to be premature and without jurisdiction---Bail granted on ground of further inquiry. Cited Cases: • Syed Sakhawat Hussain v. The State and another (2024 SCMR 1103) • Ahmad Nawaz and another v. The State and another (2024 SCMR 1525) (b) Criminal Procedure Code (V of 1898) ----S. 185---Jurisdiction---Conflict of territorial jurisdiction in offences under Legal Practitioners & Bar Councils Act, 1973---Punjab Legal Practitioners & Bar Council Rules, 2023, R. 4.26---Held, offence may be tried at the place of commission or consequences, or where Bar Council’s office is situated (Lahore)---If doubt arises as to proper forum, High Court is competent to determine jurisdiction under S. 185, Cr.P.C. (c) Pakistan Penal Code (XLV of 1860) ----Ss. 419, 468, 471 & 379---Cheating by impersonation, forgery, and theft---Allegation of posing as fake lawyer---No documentary evidence on record---No cause list or signed pleadings by petitioner to prove impersonation---Copy of license allegedly handed over by complainant not recovered from accused---Police failed to obtain confirmation from Punjab Bar Council prior to registration of FIR---Held, no prima facie case made out at this stage---Petitioner admitted to post-arrest bail. Disposition: Post-arrest bail granted---FIR registered prematurely without invoking Bar Council’s authority---Case falls under further inquiry.