Summary: (a) Constitution of Pakistan ----Arts. 51(6)(d)(e), 106(3)(c), 187, 188 & 225—Elections Act, 2017, Ss. 57, 60, 62, 64, 66, 67, 98 & 104—Elections Rules, 2017, R.94 (Explanation)—Reserved seats—Allocation of reserved seats for women and non-Muslims—Powers and jurisdiction of Election Commission of Pakistan—Scope of judicial review—Interpretation of constitutional provisions. The Supreme Court held that the scheme of the Constitution and election laws for elections to reserved seats is identical in principle to that governing general seats. Nomination papers must be filed, scrutinized, and lists of candidates for reserved seats must be submitted by political parties in accordance with constitutional timelines. Since the Sunni Ittehad Council (SIC) neither contested the general election as a political party nor submitted any list of candidates for reserved seats before the Election Commission of Pakistan (ECP), it was not entitled to any allocation of reserved seats. The unanimous dismissal of SIC’s appeals before the Supreme Court in 2024 had attained finality; therefore, SIC had no standing to reopen or contest the issue in review. (b) Constitution of Pakistan ----Art. 187—“Complete justice”—Scope—Jurisdiction of the Supreme Court—Limits. Article 187 is not a stand-alone provision and can be invoked only when the Court is properly seised of a lis under Articles 184, 185, 186 or 188 of the Constitution. The provision does not authorize the Court to legislate or grant relief to a person not before it, or to extend jurisdiction beyond the pleadings. The majority in the impugned judgment (PLD 2025 SC 67) had erred by granting relief to the Pakistan Tehreek-e-Insaf (PTI), which was neither a party to the proceedings nor had sought such relief. Substitution of constitutional text for subjective notions of equity or political preference constitutes a reviewable error apparent on the face of the record. (c) Constitution of Pakistan ----Arts. 51, 106, 187 & 225—Elections Act, 2017, Ss. 66 & 67—Certificates of party affiliation—Validity. Certificates of party affiliation issued under Section 66 of the Elections Act, 2017, by the purported Chairman of PTI were held to be a nullity as his election was not recognized under the law; consequently, candidates filing such certificates were to be treated as independents under Section 67(2) of the Act. (d) Constitution of Pakistan ----Art. 225—Elections Act, 2017—Challenge to election results—Mandatory procedure—Effect of non-observance. The Court reaffirmed that any grievance against the decision of Returning Officers or election results must be pursued under the procedure prescribed by Article 225 of the Constitution and the Elections Act, 2017. PTI and its candidates, having failed to challenge the Returning Officers’ orders declaring them independents, could not later claim that their seats be treated as PTI seats. (e) Constitutional law ----Review jurisdiction—Scope—Error apparent on the face of the record—Grounds. A review lies when a judgment is based on an erroneous assumption of material facts, contravenes a provision of law, departs from settled construction of the Constitution, or renders a constitutional provision inoperative for affected persons. Relief granted to a non-party, alteration of constitutional timelines, or exercise of legislative power in the guise of adjudication amounts to such an error warranting review. (f) Courts and jurisdiction ----Functus officio—Special bench for clarifications—Legality. Upon pronouncement of a judgment, all members of the Court become functus officio. The majority in the impugned judgment had constituted itself into a special bench for issuing further directions and clarifications; such constitution was unprecedented and contrary to law. After acceptance of the review petitions and setting aside of the impugned judgment, that self-constituted bench and its subsequent clarifications stood annulled. (g) Constitution of Pakistan ----Art. 27-A, C.P.C.—Notice to Attorney-General—Constitutionality of rules. Explanation to Rule 94 of the Election Rules, 2017, could not have been struck down without prior notice to the Attorney-General for Pakistan as mandated by Order XXVII-A, C.P.C. The question of validity of the said Explanation was left open to be decided in appropriate proceedings after such notice. (h) Review petitions—Maintainability—Parties entitled to seek review—Authority of ECP to file review petition. The Court held that review petitions filed by political parties and individuals directly affected by the impugned judgment were maintainable. The Election Commission of Pakistan, being the constitutional body responsible for superintendence of elections, possessed the right to seek review where a question of law affecting its jurisdiction and future conduct of elections was involved. (i) Constitutional law ----Doctrine of separation of powers—Judicial restraint—Observations. The Court emphasized that judicial power must not transgress into the legislative domain. Relief granted beyond the pleadings and in disregard of express constitutional mandates undermines the constitutional scheme and the separation of powers. (g) Disposition— By a majority of seven judges (Amin-ud-Din Khan, Senior Judge; Musarrat Hilali; Naeem Akhter Afghan; Shahid Bilal Hassan; Muhammad Hashim Khan Kakar; Aamer Farooq; and Ali Baqar Najafi, JJ.), all Civil Review Petitions were allowed; the impugned majority judgment dated 12.07.2024 (PLD 2025 SC 67) was set aside; Civil Appeals Nos. 333 and 334 of 2024 filed by the Sunni Ittehad Council were dismissed, and the judgment of the Peshawar High Court dated 25.03.2024 was restored. Justice Jamal Khan Mandokhel partly allowed the review petitions to the extent of forty-one seats. Justices Muhammad Ali Mazhar and Syed Hasan Azhar Rizvi allowed the review petitions with directions to the ECP to undertake a de novo exercise regarding affiliation of all eighty returned candidates and decide allocation of reserved seats within fifteen days. Cited Cases: • Suba v. Fatima Bibi 1996 SCMR 158 • Pakistan v. Fecto Belarus Tractors Ltd. PLD 2002 SC 208 • Managing Director SSGC v. Ghulam Abbas PLD 2003 SC 724 • Muhammad Siddiqul Farooq v. The State 2010 SCMR 198 • Dr. Raja Aamer Zaman v. Omar Ayub Khan 2015 SCMR 1303 • Basharat Ali Khan v. Muhammad Akbar 2017 SCMR 309 • Justice Qazi Faez Isa v. President of Pakistan PLD 2022 SC 119 • Nadia Naz v. President of Pakistan 2023 PLC (C.S.) 1353 • Supreme Court Bar Association v. Federation of Pakistan PLD 2024 SC 1199 • Inter Quest Informatics Services v. Commissioner of Income Tax 2025 SCMR 257.