Summary: Summary pending

Summary: (Against the judgment dated 12.10.2022 of the High Court of Sindh Circuit Court Hyderabad passed in Crl. A. No. D-118 of 2020). (a) Penal Code (XLV of 1860)--- ----S. 302(b)---Criminal Procedure Code (V of 1898), S. 367(5)---Qatl-i-amd---Quantum of sentence---Determining factor---Expression "having regard to the facts and circumstances of the case" is of significance in the context of exercising discretion by Court in handing down one of the two prescribed punishments---If accused is convicted of an offence punishable with death and Court sentences him to any punishment other than death, then under S. 367(5), Cr.P.C. the reason why sentence of death was not passed has to be recorded in the judgment. Dadullah and another v. The State 2015 SCMR 856; Khurram Malik and others v. The State and others PLD 2006 SC 354; Muhammad Aslam and another v. The State 2007 SCMR 1412; Ms. Najiba and another v. Ahmed Sultan and others 2001 SCMR 988; Khalid Mehmood and others v. The State 2011 SCMR 664; Asad Mahmood v. Akhlaq Ahmed and another 2010 SCMR 868 and Nadeem alias Nanha alias Billa Sher v. The State 2010 SCMR 949 rel. (b) Penal Code (XLV of 1860)--- ----S. 302(b)---Qatl-i-amd---Re-appraisal of evidence---Mitigating circumstances---Motive not proved---Effect---Accused and three co-accused persons were convicted by Trial Court for committing Qatl-i-amd of wife of accused and were sentenced to imprisonment for life---High Court acquitted three co-accused persons while sentence of accused was enhanced to death---Validity---Factum of motive was not proved by prosecution by bringing on record reliable and confidence inspiring evidence---All mitigating factors justified not handing down the sentence of death---Trial Court mentioned mitigating factors which had led to awarding sentence of life imprisonment---High Court had erroneously assumed that Trial Court did not record reasons---High Court enhanced sentence because, in its opinion, a harsher sentence should have been awarded---Supreme Court maintained conviction of accused as the prosecution had proved his guilt beyond reasonable doubt but sentence of death was reduced to imprisonment for life as awarded by Trial Court---Appeal was partly allowed. Dilawar Hussain v. The State 2013 SCMR 1582; Hassan and others v. The State and others PLD 2013 SC 793; Ghulam Mohyuddin alias Haji Babu and others v. The State 2014 SCMR 1034; Muhammad Asif v. Muhammad Akhtar 2016 SCMR 2035; Zafar Iqbal v. The State 2017 SCMR 1721; Hassan v. The State PLD 2013 SC 793; Abdul Haque v. The State PLD 1996 SC 1; Amjad Shah v. The State PLD 2017 SC 152 and Haji Muhammad Ilahi and others v. Muhammad Altaf alias Tedi and others 2011 SCMR 513 rel. (c) Criminal Procedure Code (V of 1898)--- ----S. 417---Appeal against acquittal---Scope of interference with acquittal is narrow---There is a heavy burden on prosecution as there is a presumption of double innocence. Ghulam Sajjad Gopang and Qari Abdul Rasheed, Advocates Supreme Court for Appellant. Ghulam Shabbir Shar, Advocate Supreme Court for the Complainant (though video link from Karachi) Saleem Akhtar, Additional Prosecutor General for the State. Date of hearing: 29th January, 2025.

Summary: (a) Customs Act (IV of 1969)--- ----Ss.179 & 193---'Functus officio', doctrine of---Judicial or quasi-judicial authority---Passing of order---Alteration/modification---Scope--Adjudicating Authority of the Customs issued Corrigendum ('impugned Corrigendum'), which purportedly modified the Order-in-Original substantively altering the same (order-in-original), enhancing individual personal penalties imposed upon the petitioners from Rs.10,000/- to a total amount of Rs.7,922,048/=---Validity---Record incontrovertibly demonstrated that the order-in-original was passed by the respondent acting as an Adjudicating Authority under S. 179 of the Customs Act, 1969, and the sole and exclusive remedy available to any party aggrieved by said order was an appeal under S. 193 of the Customs Act, 1969, before the Collector Customs (Appeals)---Critically, the respondent had no suo-motu power to modify the order-in-original, enhancing the personal penalties from Rs.10,000/- each to an aggregate amount of Rs.7,922,048/-, particularly in absence of any application from the aggrieved party requesting such modification---Once the matter was adjudicated upon, the respondent became functus officio with respect to the Order-in-Original, and unless and until the matter was remanded to the respondent by the Appellate Authority or any other higher forum, the order-in-original could not be unilaterally modified---The 'judicial' or 'quasi-judicial authorities' cannot change its determination in an adjudication after signing 'judgment', 'order' and 'decree' as the doctrine of 'functus officio' comes in the way---Expression 'functus officio' means that having fulfilled the functions, discharged the duties, discharged the office, or the purpose having been accomplished, there remains no further force or authority with the 'judicial' or 'quasi-judicial Authorities'---High Court set-aside the impugned Corrigendum, as the same was without lawful authority and of no legal effect whatsoever from its purported inception---Constitutional petition was allowed, in circumstances. Kh. Muhammad Fazil v. Mumtaz Munnawar Khan Niazi (deceased) through L.Rs. and another 2024 SCMR 1059; Anees-ur-Rehman v. Messrs Faysal Bank Limited through Manager 2020 CLD 473; Iqbal Pervaiz and others v. Harsan and others 2018 SCMR 359; Muhammad Wahid and another v. Nasrullah and another 2016 SCMR 179; Shujat Ali v. Muhammad Riasat and others PLD 2006 SC 140; Muhammad Anwar v. Saeed Akhtar and others PLD 2004 SC 911 and Bank Al Habib Limited through Branch Manager v. Abu Bakar Textile Mills through Managing Partner and 8 others 2016 CLD 454 ref. (b) Customs Act (IV of 1969)--- ----Ss. 179 & 194-B (2)---Order passed by Customs Authority, rectifying of ---Scope---Adjudicating Authority of the Customs (respondent) issued Corrigendum ('impugned Corrigendum'), which purportedly modified the Order-in-Original substantively altering the same (order-in-original), enhancing individual personal penalties imposed upon the petitioners from Rs.10,000/- to a total amount of Rs.7,922,048/=---Validity---Section 179 of the Customs Act, 1969, reveals no provision for conferring upon the Adjudicating Authority of the Customs (respondent) the power to rectify Order-in-Original, rather such power vests exclusively in the Customs Appellate Tribunal under S.194-B (2) of the Customs Act, 1969, and same is also exercisable only upon a mistake apparent on record being duly brought before the Tribunal by a party to an appeal---Consequently, the impugned Corrigendum was manifestly ultra vires the relevant provision of the Customs Act, 1969---High Court set-aside the impugned Corrigendum, being without lawful authority and of no legal effect whatsoever from its purported inception---Constitutional petition was allowed, in circumstances. Hassan Raza Shakir for Petitioners. Nadeem Mahmood Mian and Huriya Fatima for Respondents. Ms. Deeba Tasnim Anwar, Assistant Attorney-General for Pakistan along with Syed Babar Ali, Inspector (Customs). Date of hearing: 29th January, 2025.

Summary: (a) Criminal Procedure Code, 1898 ----S. 154—Azad Jammu & Kashmir Interim Constitution, 1974, Art. 44—Electricity Act, 1910, S. 12—Electricity Rules, 1937, Ch. VIII (Rules 65–69)—Negligence of public officials—Failure to register F.I.R.—Scope and duty of police. Where the petitioner’s minor son sustained severe burn injuries due to contact with high-tension electric wires installed merely three to four feet above the roof of the petitioner’s house, and despite repeated applications to shift the dangerous line, no action was taken, the High Court held that the negligent conduct of electricity department officials, prima facie, constituted a cognizable offence within the meaning of Section 154, Cr.P.C. The S.H.O. was legally bound to register an F.I.R. once such information was disclosed, and failure to do so was a dereliction of statutory duty. Registration of a case under Section 154, Cr.P.C., is mandatory and not discretionary, as its purpose is to set the law in motion for investigation. (b) Penal Code (XLV of 1860) ----Ss. 337-H, 337-L—Negligent act causing hurt—Criminal liability of public servants. Electricity officials’ omission to maintain safety clearance and failure to shift the high-tension line despite prior complaints amounted to advertent negligence or recklessness, punishable under Ss. 337-H and 337-L, P.P.C. The Court observed that negligence in official duty, when resulting in serious bodily injury, attracts criminal liability. Mens rea may arise from knowledge of risk or conscious disregard of consequences. (c) Electricity Act, 1910 & Rules, 1937 ----S. 12; Rules 65–69—Laying of aerial lines—Consent of landowner and safety precautions—Mandatory compliance. Under S. 12 of the Electricity Act, 1910, high-voltage lines cannot be laid without the consent of the landowner or permission of the District Magistrate. Rules 65–69 of the Electricity Rules, 1937, prescribe mandatory safety standards for aerial lines, including minimum distances from buildings and grounding of supports. Non-compliance by the department demonstrated gross negligence and disregard for statutory duties. (d) Constitutional law—Fundamental rights and public safety. The High Court reaffirmed that it is the State’s constitutional duty to safeguard citizens’ lives. Leaving departmental negligence unchecked would amount to giving “a licence to play with human lives.” Courts must intervene where failure of public functionaries threatens life and safety, which are protected under fundamental rights. (e) Criminal law—Concept of mens rea and actus reus—Application to negligence cases. The Court elaborated that mens rea (mental element) includes recklessness and conscious disregard for consequences, while actus reus (guilty act) may include acts of omission. Electricity officials, fully aware of the proximity and risk posed by the high-voltage line, displayed both recklessness and negligence, thereby satisfying both components of criminal liability. (f) Direction to authorities. The impugned order of the Ex-Officio Justice of Peace (dated 30.01.2021) declining registration of the case was set aside. The S.H.O. Police Station Hajira was directed to register an F.I.R. and proceed strictly in accordance with law. The Senior Superintendent of Police (SSP) Poonch, Rawalakot, was instructed to supervise the investigation personally and ensure its completion within one month. Disposition: Writ Petition No. 871 of 2021 accepted—Impugned order of Justice of Peace set aside—Directions issued to register F.I.R. and conduct investigation—Compliance report to be submitted.

Summary: Conviction upheld ---- (a) Criminal Procedure Code (V of 1898), S. 512—Trial in absentia—Subsequent retrial—Effect— Appellant was initially convicted and sentenced to death in absentia under S. 512, Cr.P.C. upon his escape from judicial custody. After his re-arrest, the High Court set aside the conviction and remanded the case for retrial. The trial court again convicted and sentenced the appellant to death on five counts under S. 302(b), P.P.C., which was upheld by the High Court. Held, retrial following arrest and remand is lawful and does not attract double jeopardy under Art. 13 of the Constitution or S. 403, Cr.P.C. Retrial was consistent with due process and legal remedy. (b) Penal Code (XLV of 1860), S. 302(b)—Murder—Quantum of sentence—Rule of expectancy of life—Delay in execution—Mitigating factors—Concurrent sentence— Appellant remained incarcerated for over twenty-five years, most of which was served in the death cell, pending conclusion of legal remedies. Supreme Court held that while conviction was valid and supported by ocular and medical evidence, several mitigating factors warranted commutation of sentence: (i) prolonged incarceration in death cell without remission; (ii) appellant’s young age at the time of occurrence; (iii) lack of prior criminal record; (iv) role under influence of his father who had enmity with victims; (v) unreliable recovery of weapon; and (vi) unauthorized punishment due to degrading prison conditions. Death sentence on five counts converted to imprisonment for life on five counts to run concurrently. Benefit of S. 382-B, Cr.P.C., extended. Cases cited: • Abdul Malik v. The State PLD 2006 SC 365 • Dilawar Hussain v. The State 2013 SCMR 1582 • Hassan v. The State PLD 2013 SC 793 • Khalid Iqbal v. Mirza Khan PLD 2015 SC 50 • Ghulam Rasool v. The State 2025 SCMR 74 • Shahid Ali v. The State PLD 1970 SC 447 • Khadim Hussain v. Secretary HR PLD 2020 Islamabad 268 (c) Constitution of Pakistan, Arts. 9, 12(b), 13(a), 14 & 37(d)—Right to life and dignity—Double punishment—Cruel and inhumane treatment—Delay in appellate disposal— Held, prolonged delay of over 17 years in final disposal of death sentence appeal, not attributable to the appellant, subjected him to unauthorized punishment beyond the statutory scope of S. 302(b), P.P.C. Such incarceration in substandard prison conditions amounts to cruel, degrading, and inhumane treatment, violating Arts. 9, 12(b), and 14 of the Constitution. Court emphasized constitutional responsibility of State organs to eliminate systemic delays and ensure humane treatment of prisoners. Judiciary, executive, and legislature must coordinate to reform and restore trust in the criminal justice system. (d) Administration of justice—Delay in appellate process—Impact on fairness and public confidence— Delay of six years in High Court and nearly a decade in Supreme Court to hear and decide appeal constituted failure of the criminal justice system. Held, such delays undermine public trust, especially when disproportionately affecting economically marginalized convicts. Supreme Court urged urgent structural reforms to ensure expeditious, transparent, and dignified delivery of justice. Disposition: Appeal partly allowed; conviction upheld; death sentence on five counts commuted to life imprisonment on five counts to run concurrently; benefit under S. 382-B, Cr.P.C., granted.

Summary: Sentence upheld ---- (a) Penal Code (XLV of 1860) ----S. 302(b)—Qatl-e-Amd—Discretion in sentencing—Normal vs. alternate punishment—Appellant convicted for murdering his wife by firearm—Trial court sentenced appellant to life imprisonment considering mitigating factors, including his young age, first-offender status, and unproven motive—High Court enhanced sentence to death on the ground that trial court did not comply with S. 367(5), Cr.P.C.—Held, S. 302(b), P.P.C. provides two alternate punishments: death or life imprisonment as tazir, and the courts must exercise discretion having regard to the facts and circumstances—Appellate court may not interfere with trial court’s discretion where mitigating factors exist—Trial court had explicitly recorded reasons for not awarding death—High Court erred in treating death sentence as the normal punishment without appreciating the mitigating circumstances already judicially acknowledged— Cited Cases: • Ghulam Mohyuddin v. The State 2014 SCMR 1034 • Hassan v. The State PLD 2013 SC 793 • Dilawar Hussain v. The State 2013 SCMR 1582 • Muhammad Aslam v. The State 2007 SCMR 1412 • Khalid Mehmood v. The State 2011 SCMR 664 • Najiba v. Ahmed Sultan 2001 SCMR 988 • Khurram Malik v. The State PLD 2006 SC 354 (b) Criminal Procedure Code (V of 1898) ----S. 367(5)—Punishment other than death in capital offences—Requirement to record reasons—Held, where sentence of life imprisonment is awarded instead of death in an offence punishable under S. 302(b), P.P.C., trial court must record specific reasons—Trial court in present case complied with this obligation by noting age, lack of prior record, and lack of proven motive—High Court misapplied S. 367(5) and erroneously assumed reasons were absent—Provision applies to trial courts only and not to appellate or revisional courts. Cited Cases: • Ghulam Mohyuddin v. The State 2014 SCMR 1034 • Haji Muhammad Ilahi v. Muhammad Altaf 2011 SCMR 513 • Asad Mehmood v. Akhlaq Ahmed 2010 SCMR 868 **(c) Criminal Trial—Sentence— ----Principle of proportionality—Mitigating circumstances— Held, in sentencing for qatl-e-amd under S. 302(b), P.P.C., courts must balance retributive, deterrent, and reformative goals—Multiple precedents hold that even a single mitigating factor may justify awarding life imprisonment instead of death—Factors such as unproven motive, young age, lack of prior criminal record, and questionable recovery of weapon were present in this case—Appellant’s conviction was upheld, but sentence of death was not warranted in light of mitigating factors. Cited Cases: • Amjad Shah v. The State PLD 2017 SC 152 • Nadeem alias Nanha v. The State 2010 SCMR 949 • Zafar Iqbal v. The State 2017 SCMR 1721 • Muhammad Asif v. Muhammad Akhtar 2016 SCMR 2035 • Abdul Haque v. The State PLD 1996 SC 1 (d) Sindh Arms Act, 2013 ----S. 23(1)(a)—Conviction for unlawful possession of firearm—Sentence upheld—Recovery of firearm led by appellant was questioned due to simultaneous submission of spent bullets and weapon to Forensic Lab—Held, even if firearm recovery deemed doubtful, prosecution proved guilt through consistent and confidence-inspiring ocular and medical evidence—Conviction under Sindh Arms Act and corresponding sentence and fine maintained. (e) Criminal Procedure Code (V of 1898) ----S. 544-A—Compensation to heirs of deceased—Amount of Rs. 200,000/- awarded to legal heirs by trial court—Held, compensation to remain intact and recoverable as arrears of land revenue—In case of default, appellant to undergo six months’ simple imprisonment. (f) Constitution of Pakistan ----Art. 9—Right to life—Judicial discretion in awarding sentence—Held, life and liberty are constitutionally protected rights—Exercise of sentencing discretion must favor preservation of life where justified—Recognition of mitigating circumstances aligns with constitutional principles protecting individual rights. **(g) Criminal Appeal—Scope of interference with acquittal— ----Standard of review—High Court had acquitted co-accused after reappraisal of evidence for lack of incriminating material—Held, presumption of double innocence attaches to acquittal—Supreme Court declined to interfere, finding acquittal to be well-reasoned and not perverse. Cited Case: • Haji Muhammad Ilahi v. Muhammad Altaf 2011 SCMR 513 Disposition: Appeal partially allowed—Conviction under S. 302(b), P.P.C. maintained—High Court’s enhancement of sentence from life imprisonment to death set aside—Life sentence awarded by trial court restored—Compensation under S. 544-A, Cr.P.C. upheld—In case of default, appellant to undergo six months’ simple imprisonment—Conviction and sentence under S. 23(1)(a) of the Sindh Arms Act also upheld—All sentences to run concurrently—Benefit of S. 382-B, Cr.P.C. extended to the appellant—Appeal against acquittal of co-accused dismissed.

Summary: (a) Qatl-i-Amd – Exception 4 to Section 300, PPC – Sudden Fight – Free Fight – Section 302(c), PPC Where two parties are armed, have enmity, and unexpectedly clash upon a sudden quarrel, resulting in fatalities on both sides, the case may fall under Exception 4 to the erstwhile Section 300, PPC. In the present case, although the appellants were initially convicted under Section 302(b), PPC, the Court held that the incident was a sudden free fight, not a premeditated murder, and accordingly converted the conviction to Section 302(c), PPC. Both Liaquat Ali and Saeed Ahmad were not the sole aggressors. The incident was a mutual confrontation wherein both parties anticipated resistance and were prepared. The Court ruled that the offense fell within the ambit of Exception 4, PPC and altered the sentence from death to 14 years' rigorous imprisonment. ---Relied on: PLD 1996 SC 274 (Ali Muhammad v. Ali Muhammad), PLD 2015 SC 77 (Zahid Rehman v. The State), PLD 1962 SC 502 (Syed Ali Beopari v. Nibaran Mollah), 2007 SCMR 1896 (Muhammad Saleem v. The State), 2022 SCMR 1328 (Muhammad Ashraf alias Nikka v. The State) (b) Medical Evidence – Presence at Scene – Injured Witnesses – Corroboration: Medical evidence confirmed firearm injuries on two prosecution witnesses. Their presence at the scene was not disputed by the defence. However, it was also proven that the accused sustained firearm injuries on the same date and were hospitalized, contradicting the prosecution’s one-sided version and supporting the finding of a mutual fight. Medical evidence corroborated presence of both prosecution witnesses and the accused at the scene. Both sides concealed material facts, undermining exclusive aggression by either. (c) CCTV Footage – Discrepancy in Prosecution's Version – Non-Involvement of Co-Accused: CCTV footage from the place of occurrence, secured during investigation, did not show the presence of all co-accused as alleged by the prosecution. The footage contradicted the complainant’s narrative and showed that only Liaquat Ali and Saeed Ahmad were at the scene, leading to acquittal of co-accused. Evidence from CCTV undermined the credibility of the complainant’s exaggerated version and supported the investigation's finding that several accused were not present. (d) Section 324 & 337-F(vi), PPC – Lack of Attribution of Specific Injuries – Acquittal: No specific role was attributed to the accused in relation to injuries suffered by injured witnesses Amanat Ali and Muhammad Idrees. Hence, their convictions under Sections 324 and 337-F(vi), PPC were set aside. Conviction requires direct attribution of injury. In absence of specific evidence, benefit must go to accused. Relied on: 2009 SCMR 736 (Allah Nawaz v. The State) (e) Sentence – Conversion from Death to Imprisonment – Section 302(c), PPC Death sentences awarded under Section 302(b), PPC were not confirmed in Murder Reference. Both accused were sentenced to 14 years rigorous imprisonment under Section 302(c), PPC, along with payment of Rs. 300,000/- compensation to legal heirs of the deceased. Benefit of Section 382-B, Cr.P.C. was also granted. ---Disposition: Criminal Appeal No. 883 of 2023 (Liaquat Ali): Partly Allowed Criminal Appeal No. 892 of 2023 (Saeed Ahmad): Partly Allowed Murder Reference No. 71 of 2023: Answered in Negative – Death Sentences Not Confirmed

Summary: Blasphemy case ---- summary pending.

Summary: (a) Criminal Procedure Code (V of 1898) ----Ss. 337-J PPC, 173 & 129(g)---Qanun-e-Shahadat Order, 1984---Appeal against acquittal---Burden of proof on prosecution---Unexplained delay in lodging FIR---Adverse inference for withholding material evidence---Scope of appellate interference in acquittal. The appellant challenged the acquittal of the accused (respondent No.1) in a case under S. 337-J, PPC, alleging that he forcibly administered acid to her with intent to kill. The FIR was lodged with a significant delay of 14 days despite the appellant being conscious and able to report the incident. The prosecution failed to explain the delay, which created serious doubts regarding the veracity of the allegations. Furthermore, a key witness, who had transported the appellant to the hospital, was withheld by the prosecution, justifying an adverse inference under S. 129(g) of the Qanun-e-Shahadat Order, 1984. The medical evidence also did not conclusively support the prosecution’s case, as the doctor stated that the injury could have been caused by consuming toxic or unhygienic food rather than acid ingestion. The Investigating Officer admitted that no incriminating evidence was recovered from the crime scene. The Court reiterated that in appeals against acquittal, findings of the Trial Court are generally not disturbed unless there is gross misreading or non-reading of material evidence. Given the doubts in the prosecution case and the established principle that such doubts benefit the accused, the acquittal was upheld, and the appeal was dismissed. Cited Cases: • Mst. Zarsheda v. Nobat Khan (PLD 2022 SC 21) • Ghulam Sikandar and another v. Mamaraz Khan and others (PLD 1985 SC 11)

Summary: Once a matter has been decided by a 'judicial' or 'quasi-judicial' authority, it will become 'functus officio' and on its own cannot modify the adjudicated matter subsequently. (a) Customs Act, 1969— ----S. 179—Adjudication—Jurisdiction of Adjudicating Authority—Scope—Finality of orders—Doctrine of Functus Officio—Held, once an Adjudicating Authority passes an order under Section 179 of the Customs Act, 1969, it becomes functus officio and cannot unilaterally modify, amend, or alter its order—In the present case, the Additional Collector of Customs (Adjudication) initially imposed a personal penalty of Rs.10,000/- per petitioner but later, through a Corrigendum, increased it to Rs.7,922,048/-, equivalent to the assessed value of the seized mobile phones—Held, such modification was without jurisdiction and ultra vires the Act—Reliance placed on Kh. Muhammad Fazil v. Mumtaz Munnawar Khan Niazi (2024 SCMR 1059), affirming that adjudicatory authorities cannot alter final decisions except for clerical or arithmetical mistakes. ----Cited Cases: • Kh. Muhammad Fazil v. Mumtaz Munnawar Khan Niazi (2024 SCMR 1059) • Iqbal Pervaiz v. Harsan (2018 SCMR 359) • Muhammad Wahid v. Nasrullah (2016 SCMR 179) • Shujat Ali v. Muhammad Riasat (PLD 2006 SC 140) • Muhammad Anwar v. Saeed Akhtar (PLD 2004 SC 911) (b) Customs Act, 1969— ----Ss. 179 & 193—Appeal against an order-in-original—Exclusive remedy—Held, an order passed under Section 179 of the Act can only be challenged through an appeal under Section 193 before the Collector (Appeals)—No provision in the Act allows the Adjudicating Authority to suo moto amend its own final decision—Respondent had no lawful authority to issue a Corrigendum altering the order-in-original—Such modification is without legal effect—Reliance placed on Anees-ur-Rehman v. Faysal Bank (2020 CLD 473) confirming that adjudicatory bodies cannot alter their final decisions post-issuance. (c) Administrative Law—Functus Officio Doctrine— ----Judicial and quasi-judicial orders—Finality—Scope—Once an adjudicating authority finalizes a decision, it cannot be altered except by an appellate forum or under a limited statutory provision for correction of clerical mistakes—Held, allowing authorities to unilaterally amend their final orders would create legal uncertainty and undermine judicial process—Reliance placed on Bank Al Habib Ltd. v. Abu Bakar Textile Mills (2016 CLD 454). ----Disposition: Writ Petition allowed—Impugned Corrigendum dated 10.06.2024 set aside as being without lawful authority and of no legal effect—Restoration of the original adjudicated penalties.