Summary: Civil Procedure Code (V of 1908)--- ----O. VIII, R. 9---Specific Relief Act (I of 1877), Ss.42, 54 & 55---Suit for declaration, permanent and mandatory injunction---Rejoinder, filing of---Purpose, nature and scope---Grant of leave for filing rejoinder---Discretion of court---Optional pleading---Efficiency in judicial process---Application for filing the rejoinder to the written statement was dismissed, however, the appellate court allowed the said application in a civil revision---Validity---Respondent/plaintiff could file a rejoinder only with the leave of the court, which had discretion in granting or refusing permission to file a rejoinder, and typically, it would allow it if necessary for a just determination of the lis---If the written statement of the defendant raised new defences or arguments, the plaintiff could be allowed to file rejoinder to clarify, explain or deny those defences--- Rejoinder is an optional pleading and can only be filed under the circumstances where it is needed to respond to new defences or issues raised by the petitioners/defendants that have not been adequately addressed as pleaded by the respondents/plaintiffs in their written application seeking permission of the Court to allow them to file rejoinder---Court's discretion envisages that unnecessary or frivolous replies are avoided, promoting efficiency in the judicial process---Constitutional petition was dismissed in limine, in circumstances. Mian Humayun Ahmad Kakakhel for Petitioner.

Summary: (Against the judgment dated 17.05.2017 of the Lahore High Court, Lahore passed in Crl.A. 140 of 2015). Anti-Terrorism Act (XXVII of 1997)--- ----S. 7 (ff)---Explosive Substances Act (VI of 1908), S.5---Explosive material, recovery of---Re-appraisal of evidence---Benefit of doubt---Defence version---Accused was convicted for recovery of explosive material from his possession and was sentenced to imprisonment for fourteen years---Validity---Accused produced compelling evidence which had raised serious questions about mode and manner in which police alleged to have arrested and investigated him---Besides reasonable doubts that could arise in a prudent mind due to evidence presented by accused, prosecution's own account of events was fraught with doubtful circumstances that had created doubt, which automatically favoured accused without reservation---Prosecution failed to prove guilt of accused beyond reasonable doubt, rather existence of such doubts decisively favoured accused and such aspect was not considered by Trial Court and High Court---Supreme Court set aside conviction and sentence awarded to accused and he was acquitted of the charge---Appeal was allowed. Tariq Parvez v. The State 1995 SCMR 1345; Muhammad Akram v. The State 2009 SCMR 230; Muhammad Imran v. The State 2020 SCMR 857; Mst Asia Bibi v. The State PLD 2019 SC 64; Ayub Masih v. The State PLD 2002 SC 1048; Abdul Jabbar v. The State 2019 SCMR 129 and Maqsood Alam v. The State 2024 SCMR 156 rel. Arif Mehmood Rana, Advocate Supreme Court for Petitioner. Sajjad Hussain, DPG for the State. Date of hearing: 24th January, 2025.

Summary: Sindh Rented Premises Ordinance (XVII of 1979)--- ----Ss. 10 & 15(2)(ii)---Constitution of Pakistan, Art. 199---Constitutional petition---Ejectment of tenant---Default in payment of rent and bona fide personal need---Ejectment application filed by the landlord/respondent was allowed by the Rent Controller, which was upheld by the Appellate Court---Validity---Petitioner/Tenant in his evidence had admitted that he had sent the rent for four months, that is, July, August, September and October, 2014, through Money Order in the month of October, 2014 and that as per agreement, he was bound to pay monthly rent in advance latest by 5thof each calendar month---Previous conduct of the petitioner showed that he had defaulted in payment of rent, as he cleared the rent subsequently in installments---Petitioner admitted in his testimony that as per the agreement he had to pay the rent by 5thof each month, thus, rent of July 2014 should have been paid within 15 (fifteen) days, which admittedly was not done--It was not necessary that there should be a written tenancy agreement, but the standard practice between a landlord and tenant to pay and receive the rentals, which also constituted an agreement, should be adhered to while paying rent---If the acceptable practice between the landlord and tenant was that rent was to be paid by 5thof each month, then Sub-S. 2 (ii) of S. 15 would be applicable, that is, rent should be paid within fifteen days when the rent was due---Non-payment of rent carried a penal consequence, thus, evidence given by the parties must be construed strictly and in the event of a probable doubt, it must be resolved in favour of tenant rather than landlord---Plaintiff cannot get benefit from the weaknesses of the defendant's evidence alone, rather plaintiff has to prove his case on its own strength---Jurisdiction was exercised correctly by Courts below---Constitutional petition was dismissed, in circumstances. Hirjibhai Behrana Dar-e-Meher through Attorney v. Messrs Bombay Steel Works, Partnership Firm, through Partner 2001 SCMR 1888; Hakim Ali v. Muhammad Salim and another 1992 SCMR 46; Sher Afgan v. Shaikh Anjum Iqbal 1997 MLD 98; Mushtaq-ul-Aarifin and others v.Mumtaz Muhammad and others 2022 SCMR 55; Sh. Fateh Muhammad v. Muhammad Adil and others PLD 2007 SC 460; Ijaz Ahmed Khan v. Jahanzeb Khan and others 2016 CLC Note 128; Nasir Akhtar v. Sher Alam 2019 YLR 1967; Abdul Rehman and others v. Ghulam Fatima and others 2017 YLR 2276; Ilyas Ahmed v. Muhammad Munir and 10 others PLD 2012 Sindh 92; Sir E.H. Jaffar and Sons Ltd. v. Sultan Karam Ali and others 1995 SCMR 330 and Naeem Noor Muhammad alias Naeem Cyclwala's 2017 CLC 625 distinguished. Allah Din v. Habib PLD 1982 SC 465; Tajammal Hussain Shah v. Mst.Taj Aslam 1989 CLC 662; Abdul Rasheed v. Hanifur Rahman 1994 MLD 955; Muhammad Subhan and another v. Mst. Bilquis Begum through Legal Heirs and 3 others 1994 SCMR 1507; Abdul Mateen v. Muhammad Hussain (Late) 1997 CLC 216; Haji Qasim (Deceased) through L.Rs v. Syed Rahim Shah 1999 MLD 1014; Ghulam Nabi and another v. T. Ismail 2000 MLD 186; Inam Ahmed and another v. Hakimuddin and another 2000 CLC 1140; Muhammad Yakoob v. Mst. Zaibunnisa and 2 others 2009 CLC 177; Shafiq-ud-Din and others v. Mst. Shahida Ghazala and others 2000 CLC Note 29; Nizar Noor and others v. Ameer Ali and others and 2020 CLC 254 Hakim Ali v. Muhammad Salim and aother 1992 SCMR 46 ref. Zayyad Khan Abbasi and Ch. Tariq Yousuf for Petitioner. Mahmooda Suleman and Muhammad Rizwan Naich for Respondent No. 1. Nemo for Respondents Nos. 2 and 3. Date of hearing: 25th January, 2025. Order Muhammad Faisal Kamal Alam, J .--- Through this Petition, learned Counsel for the Petitioner has challenged the Judgments dated 05.03.2020 and 16.11.2019 passed by the learned Appellate Court and Rent Controller, deciding the Eviction Application of Respondent No.1, directing the Petitioner to vacate the Premises-Shop No.1, at Plot No.603, Main Road, PIB Colony, Karachi the Demised Premises, on the ground of committing default in payment of rent. 2. Messrs Zayyad Khan Abbasi and Ch. Tariq Yousuf, Advocates for the Petitioner have argued the matter at length and stated that the concurrent findings result of misreading of evidence and misinterpretation of the provisions of the relevant Law, viz. the Sindh Rented Premises Ordinance, 1979-the Rent Law; in particular, Sections 10 and 15 [2] (ii), inter alia, concerning the time period of sixty days to pay rents, if, there is no tenancy agreement; stated that the Rent Application is filed with mala fide intention and that is why personal bona fide need of Respondent No.l was discarded. The Legal Team of Petitioner has cited the following Case Law to augment their arguments. i) 2001 SCMR 1888 [Hirjibhai Behrana Dar-e-Meher through Attorney v.Mesars Bombay Steel Works, Partnership Firm, through Partner] ii) 1992 SCMR 46 [Hakim Ali v. Muhammad Salim and another] ii) 1997 MLD 98 [Karachi] [Sher Afgan v. Shaikh Anjum Iqbal] iv) 2022 SCMR 55 [Mushtaq-ul-Aarifin and others v. Mumtaz Muhammad and others] v) PLD 2007 SC 460 [Sh. Fateh Muhammad v. Muhammad Adil and others] vi) 2016 CLC Note 128 [Ijaz Ahmed Khan v. Jahanzeb Khan and others] vii) 2019 YLR 1967 [Nasir Akhtar v. Sher Alam) viii) 2017 YLR 2276 [Lahore] [Abdul Rehman and others v. Ghulam Fatima and others] ix) PLD 2012 Sindh 92 [Ilyas Ahmed v. Muhammad Munir and 10 others] (x) 1995 SCMR 330 1 [Sir E.H. Jaffar and Sons Ltd. v. Sultan Karam Ali and others] xi) 2017 CLC 625 [Sindh) [Naeem Noor Muhammad alias Naeem Cyehwala) 3. The above arguments are refuted by M/s. Mahmooda Suleman and Muhammad Rizwan Naich, learned Advocates for Respondent No.1 (Landlord). They stated that findings of both the Fora are based on a proper appraisal of evidence, which cannot be set-aside in writ jurisdiction. The Legal Team of Respondent No.1 has cited the following Case Law. i) PLD 1982 SC 465 [Allah Din v. Habib] ii) 1989 CLC 662 [Karachil [Tajammal Hussain Shah v. Mst. Taj Aslam] iii) 1994 MLD 955 (Karachi) [Abdul Rasheed v. Hanifur Rahman] iv) 1994 SCMR 1507 (2) [Muhammad Subhan and another v. Mst. Bilquis Begum through Legal Heirs and 3 others] (v) 1997 CLC 216 [Karachi] [Abdul Mateen v. Muhammad Hussain (late)] vi) 1999 MLD 1014 [Haji Qasim (Deceased) through L.Rs v. Syed Rahim Shah) vii) 2000 MLD 186 [Ghulam Nabi and another v. T. Ismail] viii) 2000 CLC 1140 [Karachi] [Inam Ahmed and another v. Hakimuddin and another] ix) 2009 CLC 177 [Karachi] [Muhammad Yakoob v. Mst. Z?ibunnisa and 2 others] x) 2020 CLC Note 29 [Shafiq-ud-Din and others v. Mst. Shahida Ghazala and others] xi) 2020 CLC 254 [Sindh] [Nizar Noor and others v. Ameer Ali and others] xii) 1992 SCMR 46 [Hakim Ali v. Muhammad Salim and another] 4. Arguments heard and Record perused. 5. The above argument of the Petitioner's Legal Team has been considered by the learned Rent Controller in the Impugned Order and he disagreed with the same, on the basis of the evidence adduced by both the Petitioner and Respondent. 6. Interestingly, the Petitioner was given further opportunity to lead the evidence at the Appellate stage, inter alia, to produce the Postal Receipt of the Money Order through which he sent the rents of the four months, from July, 2014 onwards; that is, the period in which the Petitioner is allegedly committed default. 7. The Petitioner in his evidence has admitted that he had sent the rent for four months, that is, July, August, September and October, 2014, through Money Order in the month of October, 2014; admitted that as per agreement, he "was bound to pay monthly rent in advance latest by 5th of each calendar month". 8. It has come on record that earlier also, the Petitioner had defaulted in payment of rent from 1st July 2005 till 31 December 2011, which was paid/cleared subsequently in installments; although, this fact is not the subject dispute of the present proceeding, but shows the conduct of the Petitioner. 9. The argument of Petitioner's Counsel, that since no written agreement exists, therefore, in terms of the above provisions of the Rent Law, the monthly rent of July 2014 and following three months was correctly paid in the month of October and no default is committed, is a misconceived one, and aptly discussed in the impugned Decisions, inter alia, that since it is admitted by the Petitioner in his testimony] that as per the agreement he had to pay the rent by 5th of each month, therefore, rent of July 2014 should have been paid within 15 (fifteen) days, which admittedly was not done. It is further clarified that it is not necessary that there should be a written Tenancy Agreement, but the standard practice between a Landlord and Tenant to pay and receive the rentals also constitute an agreement, should be adhered to while paying rents. If the acceptable practice between the Landlord and Tenant is that rent is paid by 5th of each month, then Subsection 2 (ii) of Section 15 will be applicable, that is, rent should be paid within fifteen days when the rent is due. 10. The Case Law cited by the Petitioner does not need an elaborate discussion in view of the above undisputed factual aspect of the case, because the Cited Decisions are ?n respect of the interpretation of second part of Subsection 2 (ii) of Section 15 [ibid), that is, payment of rent within sixty days when it has fallen due; non-payment of rent carries a penal consequence, thus, evidence given by the Parties must be construed strictly and in the event of a probable doubt, it must be resolved in favour of tenant rather than Landlord; reiterating the established Rule, that Plaintiff cannot get benefit from the weaknesses of the Defendant's evidence alone, rather Plaintiff has to prove his case on its own strength. 11. Both the Impugned Judgments are handed down after proper appreciation of the evidence and relevant provisions of the Rent Law; hence, the jurisdiction is exercised correctly. Constitution Petition is dismissed. Since, the demised Premises is commercial, therefore, 30 (thirty) days' time is granted to the Petitioner, for handing over physical, peaceful and vacant possession to the Respondent; or, after the lapse of 30 (thirty) days, the learned Rent Controller will issue Writ of Possession without any further Notice. 12. There will be no order as to costs. SA/Z-8/Sindh Petition dismissed.

Summary: (a) Elections Act (XXXIII of 2017)--- ----Ss. 142, 143,144(4) & 145(1)---Election petition---Maintainability---Non-fulfilment of mandatory procedural requirements while filing the election petition---Verification of election petition being a mandatory requirement---Effect and consequences---A deficient election petition must be rejected at the outset---Detailed particulars with documentary evidence to be provided in order to substantiate incidences of corrupt practices, requirement of---The challenge in the present case was against the election held on 08.02.2024 in constituency PP-167 Lahore-XXIII---The election petitioner alleged that while consolidating the results, Forms-45 issued to polling agents were unlawfully discarded, corrupt practices occurred on polling day, and the results were manipulated with ulterior motives---On the other hand, the returned candidate had raised preliminary objections, contending that the election petition suffered from procedural defects, particularly improper verification and absence of a valid affidavit of service as required under S. 144 of the Elections Act, 2017---Held: It has been settled law that details of the person identifying the election petition must be mentioned in accordance with the provisions of law and the oath commissioner was bound to specify, at the foot of the affidavit, name of the person by whom the identification of the deponent was made and in the regard certificate had to be appended---Verification of an election petition was mandatory and a petition which lacked proper verification should be summarily dismissed by the tribunal, even if the respondent had not asked or prayed for its dismissal---Moreover, when an election petition was not verified in accordance with law, this could not be treated as curable defect particularly after lapse of period of limitation prescribed for filing of election petition---In the present case, the declaration given by the oath commissioner did not reveal if the election petitioner was personally known to him---The identification was not with reference to his Computerized National Identity Card (CNIC)---Moreover, full particulars of any corrupt or illegal practices were required to be given by the petitioner, including the details as to date and place of commission of such acts of illegal practices together with documentary evidence in support of such allegations---Election petition was deficient in many respects, therefore, the same was rejected under S. 145(1) of the Act. (b) Elections Act (XXXIII of 2017)--- ----Ss. 142, 143, 144(4) & 145(1)---Election petition---Maintainability---Non-fulfilment of mandatory requirements while filing the election petition---Consequences and effect---Tribunal bound to reject petition at the outset---The requirements given in Ss. 142 to 144 of the Elections Act, 2017 for presentation of election petition, impleading parties to such petition and contents of the election petition to challenge election in any constituency are followed by S. 145(1) of the Act, 2017 which requires rejection of election petition if aforesaid provisions were not complied with, moreover, the Tribunal cannot wait till the culmination of the proceedings through regular trial and it is mandate of law to reject the plaint. Col. (R) Muhammad Shabir Awan v. Raja Saghir Ahmed and 4 others PLD 2023 Lah. 458 ref. Waqar Mushtaaq Toor for Petitioner. Waqas Ahmad Mir and Hammad Hussain for Respondent No. 1/Returned Candidate). Ex-parte for Respondents Nos. 2 to 30 and 32 to 38. Date of hearing: 24th January, 2025.

Summary: Non-framing of issues on the plea of the petitioner-defendant and its effect. A perusal of the impugned judgment of the learned lower for a clearly demonstrate that parties were aware thereabout and adduced evidence in that behalf and also made their submissions in relation thereto but did not raise objection over it. He is not permitted to raise this objection at revisional stage hence revision petition is dismissed in the circumstances.

Summary: Provisions of Order VIII Rule 9 CPC reflects that it enables the Court to allow the plaintiff to file rejoinder in response of the written statement submitted by the defendants but subject to certain conditions and circumstances. Under the circumstances the writ petition is allowed and petitioners are permitted to file rejoinder to clarify explain or deny the defences taken by the respondent in the written statement.

Summary: (a) Enforcement of Women’s Property Rights Act, 2020 ----Ss. 5 & 7---Ownership and possession---Maintainability of complaint during pendency of civil proceedings---Complainant (female owner) sought possession of commercial property (Shop No.2, Block No.6, Civic Centre, Melody Market, Islamabad) gifted to her by her parents through registered Gift Deed dated 16-01-2018---Respondents (tenants’ sons) claimed ownership through an alleged oral agreement to sell made by their deceased father in 1982---Held, complaint maintainable under S.7(1) of the Act notwithstanding pendency of civil suit for declaration and recovery of rent---Provision expressly empowers Ombudsperson to entertain complaint even when court proceedings are pending concerning ownership or possession of property claimed by a woman. (b) Ownership and title---Registered gift deed---Evidentiary value---Gift deed duly executed and registered with Sub-Registrar, Islamabad, constituted valid and conclusive title in favor of Complainant---Respondents’ reliance on electricity bill and tax notice held immaterial as these do not confer proprietary rights---Absence of proof of payment, consideration, or written sale instrument rendered alleged oral sale unenforceable in law---Complainant thus declared sole lawful owner of the suit shop. (c) Leasehold rights---Chain of title established---Report from Capital Development Authority confirmed that leasehold rights of the commercial property were originally granted to Colonel Saeed Tariq, later transferred to Mrs. Parveen Tariq, and thereafter sold to Dr. Abdul Wahid and Dr. Haseena Parveen (Complainant’s parents), who gifted it to the Complainant---Respondents had no legal title or tenancy subsisting upon termination of the earlier arrangement. (d) Possession---Right to eviction of unlawful occupants---Scope of Section 5 of the Act---Where a woman proves ownership and shows that others unlawfully retain her property, Ombudsperson empowered to order immediate restoration of possession---Respondents directed to vacate shop and hand over vacant possession within one month, failing which coercive measures for eviction to follow. (e) Disposition— Complaint allowed---Respondents held to be illegal occupants of Shop No.2, Ground Floor, Block No.6, Civic Centre, Melody Market, G-6/4, Islamabad---Directed to vacate and hand over possession to Complainant within one month---Compliance fixed for 14-02-2025.

Summary: (a) Enforcement of Women’s Property Rights Act, 2020 ----S. 8---Determination of rent for period of dispossession---Scope of remand by President of Pakistan---Complainant (widow) sought recovery of rent for period during which she and her children were deprived of their share in residential house at E-7, Islamabad---Case remanded by Hon’ble President to Ombudsperson to determine market rent and duration of dispossession—Evidence, including plaint in civil proceedings (filed 22-02-2016), established that dispossession commenced in September 2015 and possession was restored on 06-07-2021—Held, under S.8 of the Act, the Ombudsperson is empowered to direct payment of market rental value for entire duration of unlawful deprivation—Respondents found jointly liable for rent. (b) Civil litigation history---Effect of collusion---Earlier suit filed by Respondent No.1 for declaration and possession dismissed by civil court on 29-02-2015 for failure to prove alleged exchange of property—Record showed Respondent No.2 admitted claim of Respondent No.1 in that suit, evidencing collusion to dispossess Complainant—Respondent No.2, therefore, estopped from denying involvement or liability for rent. (c) Calculation of rent---Principles---Market rental value assessed at Rs.360,000 per annum in 2021 with 10% annual reduction applied retrospectively to October 2015—Husband of Complainant held 1/3rd share in property; Complainant entitled to 1/8th of entire estate—Total rent corresponding to husband’s share calculated at approx. Rs.5.5 million; Complainant’s personal share assessed at Rs.700,000---Both Respondents held jointly and severally liable to pay said amount within one month. (d) Administrative law---Remand compliance---Where superior authority remands matter for specific determination, forum must confine itself to scope of remand—Directions of Hon’ble President of Pakistan (order dated 10-12-2024) duly complied with by recalculating rent and duration based on evidence of dispossession. (e) Disposition— Complaint partly allowed---Dispossession determined to have commenced in September 2015 and ended on 06-07-2021---Respondents directed to pay Rs.700,000 to Complainant jointly and severally within one month---In case of default, Complainant entitled to approach forum for enforcement under S.8 of the Act—File consigned.

Summary: (a) Civil Procedure Code (V of 1908) ----S. 115---Civil Revision---Jurisdiction of High Court---Scope---Concurrent findings of fact by lower courts---Interference by High Court---Principles. Petitioners challenged the judgments and decrees of the Trial Court and the Appellate Court, both of which dismissed their suit for declaration, permanent, and mandatory injunction regarding ownership and correction of revenue record. The lower courts found that the suit was hopelessly time-barred as the disputed revenue mutations dated back to 1945, 1951, 1954, and 1955, and no legal action was taken by the petitioners’ predecessors during their lifetime. The petitioners first raised the issue in 2008 and subsequently filed a suit in 2020, failing to provide any explanation for the delay. The High Court held that when a lis is initiated beyond the prescribed period of limitation, a vested right is created in favor of the opposite party, which cannot be negated by granting relief to a delinquent litigant. The petitioners neither established their possession of the suit land nor produced any evidence to substantiate their claims. The High Court, under S. 115, CPC, reiterated that revisional jurisdiction is limited to correcting jurisdictional errors, illegalities, or material irregularities, none of which were evident in the concurrent findings of fact by the lower courts. Hence, the civil revision was dismissed in limine. Cited Cases: • Khushi Muhammad v. Fazal Bibi (PLD 2016 SC 872) • Muhammad Aslam and others v. Muhammad Anwar (2023 SCMR 1371) • Messrs Pak Suzuki Motors Company Limited v. Faisal Jameel Butt and another (PLD 2023 SC 482)

Summary: Bail granted---(a) Criminal Procedure Code (V of 1898) & Juvenile Justice System Act, 2018---- ----Ss. 496, 497, 6, 9, 10 & 14 JJSA, 2018----Post-arrest bail of juvenile offender----Scope----Juvenile accused arrested under Sections 9(1)6(d) & 9(2)5 of the Control of Narcotic Substances Act, 1997, and found in possession of 2516 grams of heroin and 590 grams of “ice” (methamphetamine)---Petitioner claimed to be a minor at the time of arrest, and NADRA record verified his date of birth as 13-03-2009, confirming that he was 14 years and 9 months old at the time of arrest---Held, that under Section 6 of the Juvenile Justice System Act, 2018, a juvenile accused under 16 years of age is entitled to bail as a matter of right unless exceptional circumstances exist, such as exposure to criminal influence or endangerment to society---Further held, that while the offence carried a capital sentence, the absence of elements such as brutality, shocking public morality, or gruesome nature of the crime did not make it a “heinous offence” within the meaning of Section 2(g) of the JJSA, 2018---Failure of police and trial court to comply with mandatory procedures under Sections 5, 9 & 10 of the JJSA, 2018, including failure to inform the guardian and probation officer, was noted as a serious lapse---Bail granted subject to submission of surety or, in case of financial incapacity, personal surety bond by a family member. Cited Cases: • Shehzad Ali v. State 2023 YLR 1025 • State v. Muhammad Javed 2022 SCMR 1256 • Shahbaz Ali v. The State 2021 PCrLJ 2094 (b) Juvenile Justice System Act, 2018---- ----Ss. 5, 6, 9, 10, 14 & 15----Failure to comply with procedural safeguards for juvenile accused----Obligation of courts and police----Scope----Held, that JJSA, 2018 provides a distinct procedural framework for handling juvenile offenders emphasizing rehabilitation over punitive measures---Police failed to place the juvenile in an observation home, inform his guardian, and notify the probation officer as required under Sections 5 & 9 of the JJSA, 2018---Trial court also failed to direct verification of the petitioner’s age at the outset, causing unnecessary delay in securing his rights under the law---Further held, that international obligations under the Child Rights Convention, 1989, mandate the use of diversion mechanisms to prevent undue incarceration of juveniles---Courts directed to ensure timely verification of juvenility, and police instructed to submit age verification reports from NADRA, school records, or hospital data before producing minors in court. Cited Cases: • Muhammad Jameel v. State 2023 MLD 756 • Naveed Akhtar v. State 2022 SCMR 1431 (c) Juvenile Rights & Administration of Justice---- ----International child rights obligations & judicial directions for compliance----Scope----Held, that courts and law enforcement agencies are duty-bound to uphold international commitments made by Pakistan under the Child Rights Convention, 1989, ensuring juveniles are dealt with in a rehabilitative rather than punitive manner---Inspector General of Police, SSP Investigation, and District & Sessions Judges of Islamabad directed to implement juvenile protection measures including: (i) Immediate notification of guardians upon arrest; (ii) Submission of age verification report from NADRA, Union Council, or hospitals before court proceedings; (iii) Involvement of probation officers in diversion plans; (iv) Prohibition of juvenile detention in regular jails; and (v) Ensuring state-funded legal assistance for juveniles---Non-compliance with these requirements to be considered misconduct, and quarterly compliance reports to be submitted to the court. ----Disposition: Criminal Misc. No. 28/B/2025 allowed---Petitioner granted post-arrest bail subject to furnishing surety of Rs. 20,000/- or personal surety bond by a family member in case of financial hardship. Directions issued to law enforcement and judicial authorities for mandatory compliance with JJSA, 2018 and Child Rights Convention, 1989.