Summary: Acquittal granted ---- (a) Criminal Trial—Presumption of Innocence—Burden of Proof ---- Constitution of Pakistan, Art. 10-A ---- An accused is presumed innocent until proven guilty beyond a reasonable doubt. The prosecution bears the burden of proving guilt through legally admissible, confidence-inspiring, and reliable evidence. Any weakness in the defense does not benefit the prosecution. Failure to establish the case beyond doubt entitles the accused to acquittal. (Rel. 2009 SCMR 230, 2024 SCMR 1579, PLD 1993 SC 251) (b) Ocular Testimony—Unreliable and Interested Witnesses ---- Qanun-e-Shahadat Order, 1984, Art. 17 & 129 ---- The prosecution relied on eyewitnesses who were close relatives of the deceased, rendering their testimony interested and requiring corroboration. Contradictions in their statements regarding the exact location of the incident, the movement of the deceased, and the presence of the accused weakened their credibility. The unnatural conduct of witnesses in failing to prevent the attack further cast doubt on their version of events. (Rel. 2020 SCMR 319, 2024 SCMR 1579) (c) Nighttime Incident—Failure to Establish Proper Identification ---- Qanun-e-Shahadat Order, 1984, Art. 129 ---- The occurrence took place at night, yet the FIR did not mention any source of light at the crime scene. In such circumstances, the possibility of mistaken identity of the accused cannot be ruled out. The absence of independent evidence confirming identification further weakened the prosecution’s case. (Rel. 2017 SCMR 596, 2017 SCMR 1572, 2019 SCMR 1170) (d) Motive—Failure to Prove—Effect ---- Qanun-e-Shahadat Order, 1984, Art. 129 ---- The prosecution alleged an exchange of hot words between the complainant and the accused as the motive for the murder. However, no independent witnesses were produced to establish this motive. The investigating officer also admitted that no witnesses were examined in support of the motive. Since motive is a supporting factor, its absence significantly weakened the prosecution's case. (Rel. 2017 SCMR 596, 2017 SCMR 1572, 2019 SCMR 1170) (e) Recovery of Weapon—Violation of Section 103 Cr.P.C.—Negative Forensic Report ---- Criminal Procedure Code (V of 1898), S. 103 ---- The alleged recovery of a 12-bore repeater gun was made in the absence of independent witnesses and in violation of Section 103 Cr.P.C. Moreover, the forensic report did not link the weapon to the crime, rendering the recovery inconsequential. (Rel. 2017 SCMR 898, 2024 SCMR 1741) (f) Medical Evidence—Corroborative Value—Failure to Link Accused ---- Qanun-e-Shahadat Order, 1984, Art. 129 ---- Medical evidence can corroborate the manner and weapon used in the crime, but it cannot identify the accused. In this case, the prosecution failed to produce reliable eyewitness testimony linking the accused to the crime. Thus, the medical evidence alone was insufficient to establish guilt. (Rel. PLD 1993 SC 251, PLD 1976 SC 695, 2024 SCMR 1741) (g) Unnatural Conduct of the Accused—Doubtful Prosecution Story ---- Qanun-e-Shahadat Order, 1984, Art. 129 ---- The prosecution alleged that the accused had a dispute with the complainant (PW-8) but targeted the complainant's father instead. The accused did not even threaten the complainant, raising serious doubts about the real motive behind the incident. The unnatural conduct of the accused, in sparing the person he allegedly had a dispute with, suggested that the prosecution story was fabricated. (Rel. 2017 SCMR 596, 2017 SCMR 1572, 2019 SCMR 1170) (h) Benefit of Doubt—Legal Requirement for Acquittal ---- Criminal Procedure Code (V of 1898), S. 265-K ---- If even a single reasonable doubt arises in the prosecution’s case, the accused is entitled to an acquittal. In this case, multiple serious discrepancies were found in the ocular testimony, motive, recovery, forensic evidence, and medical evidence, all of which created reasonable doubt about the prosecution's version. (Rel. 2009 SCMR 230, 2024 SCMR 1579, 2024 SCMR 1741) Disposition: Appeal allowed. Conviction and death sentence of Muhammad Amjad set aside. He was acquitted of all charges and ordered to be released unless required in another case. Murder Reference answered in the negative—death sentence not confirmed. Complainant’s appeal against the acquittal of Muhammad Usman dismissed for lack of merit.

Summary: (a) Constitution of Pakistan ---Art. 15, 199, and Rule 22 of the Passports Rules, 2021 Right to freedom of movement—Placement of citizen’s name on Passport Control List (PCL)—Legality—Due process—Requirement of Federal Government’s approval The Petitioner challenged the placement of his name on the Passport Control List (PCL) under Article 199 of the Constitution, contending that the restriction was arbitrary, unlawful, and a violation of his fundamental rights. The Petitioner was accused in FIR No. 96/23 under various sections of the Pakistan Penal Code, 1860, and the Anti-Terrorism Act, 1997. However, his pre-arrest bail petition was withdrawn after the investigating officer found him not guilty. Despite this, his name remained on the PCL based on the recommendation of the Home Department, Punjab, without any prior notice or opportunity for a hearing. Rule 22 of the Passports Rules, 2021, requires approval from the Federal Government for placing an individual on the PCL, which was absent in the present case. The court held that such a restriction, in the absence of lawful authority and procedural fairness, violated Article 15 of the Constitution, which guarantees the right to free movement subject to reasonable restrictions imposed by law. Therefore, the placement of the Petitioner’s name on the PCL was declared illegal, unconstitutional, and of no legal effect. Cited Cases: Dr. Joseph Wilson v. Federation of Pakistan 2017 PCrLJ 1569 Dr. Shireen M. Mazari v. Federation of Pakistan 2024 MLD 1020 Rasikh Ellahi v. Federation of Pakistan 2024 YLR 2616 Messrs Mustafa Impex, Karachi v. Government of Pakistan PLD 2016 SC 808 Farah Mazhar v. Federation of Pakistan PLD 2022 Lahore 119 ----- Disposition: Writ petition allowed—Respondents directed to remove Petitioner’s name from PCL, as its inclusion was found to be unjustified, illegal, and violative of constitutional rights.

Summary: (a) Anti-Dumping Duties Act, 2015 ----Ss. 20, 23, 36, 37, 39 & 70 Final determination—Validity of anti-dumping proceedings—Initiation of investigation based on application filed during interregnum between lapse of repealed Ordinance and enactment of new law—Challenge to jurisdiction of National Tariff Commission (NTC) in initiating and completing anti-dumping investigation without a valid application under S. 20 of the Anti-Dumping Duties Act, 2015—Petitioner alleged entire proceedings, including provisional and final determinations, were void ab initio, coram non judice and in violation of natural justice—Plea taken that Ordinance had lapsed on 26.06.2015, Act enacted on 08.09.2015, and during this legislative vacuum, application dated 29.06.2015 lacked lawful basis—Held, Resolution of National Assembly dated 30.07.2015 validly extended the Ordinance retrospectively, ensuring continuity of law and protecting proceedings—Majlis-e-Shoora competent to enact law with retrospective effect under Article 89(2)(a)(ii) of the Constitution—NTC's proceedings found lawful and valid—Delay in provisional determination beyond 180 days held directory, not fatal, in absence of statutory consequence—Petitioner also had alternate statutory remedy under S. 70 by filing appeal before Anti-Dumping Appellate Tribunal—Petition dismissed. Cited Cases: • Pakistan Steel Mills Corporation v. Muhammad Azeem Katper, 2002 SCMR 1023 • Commissioner of Income Tax v. Eastern Federal Union Insurance Co., PLD 1982 SC 247 • Hassan v. Fancy Foundation, PLD 1975 SC 1 • Federation of Pakistan v. M. Nawaz Khokhar, PLD 2000 SC 26 • Lahore Development Authority v. Imrana Tiwana, 2015 SCMR 1739 • Ghulam Hassan v. Jamshaid Ali, 2001 SCMR 1001 (b) Constitution of Pakistan ----Arts. 18 & 89 Legislative power—Retrospective legislation—Scope—Challenge to anti-dumping framework based on alleged gap between ordinance and enactment—Held, Constitution permits Parliament to legislate retrospectively, except where expressly prohibited—Article 89 provides that Ordinance laid before Parliament shall be deemed to be a Bill and, once enacted, may provide continuity of law—Article 264 ensures consequences of repeal do not affect validity of prior acts done—Petitioner’s claim of legislative vacuum rejected as being contrary to constitutional scheme—Fundamental rights under Art. 18 (freedom of trade) not absolute and subject to lawful regulation in public interest, including international treaty compliance—No violation found.

Summary: It is a settled principle of law that ex-parte proceedings can be set-aside only within the prescribed limitation period, except in cases where lack of proper service is conclusively established. In the present case, the petitioner filed an application for setting aside ex-parte proceedings after 12 years, which is far beyond the limitation period prescribed under the Limitation Act, 1908. According to Section 22A of the Punjab Civil Servants Act, 1974, civil servants are generally immune from personal liability for actions performed in good faith while exercising their official duties. The constitutional jurisdiction under Article 199 cannot be invoked as a substitute for ordinary legal remedies, particularly where a petitioner has failed to pursue the available legal options within the prescribed statutory timeframe. 730Civil Revision- Civil Revision (Against Decree) u/s. 115, C.P.C. 569-17 ZUBAIR WAHID KHAN VS TOUSEEF ALAM Mr. Justice Mirza Viqas Rauf 12-02- 2025 2025 LHC 413

Summary: (a) Protection Against Harassment of Women at the Workplace Act, 2010 (2010 Act) & Constitution of Pakistan ----Secs. 2(h), 4(4)(ii), 7, 8; Arts. 14, 18, 25, 34, & 184(3) Sexual harassment—Scope and legal framework—Petitioner, a driver, was accused of workplace harassment by respondent No.5, a lady doctor—Allegations included verbal abuse, character assassination, unethical conduct with female patients, and unauthorized video recording of respondent No.5 during an ultrasound procedure—Ombudsperson, Punjab, found the allegations established under Sec. 2(h) of the 2010 Act and imposed the major penalty of compulsory retirement under Sec. 4(4)(ii)—Governor of Punjab dismissed petitioner’s representation, and Lahore High Court upheld the decision—Petitioner’s constitutional petition was also dismissed by the Supreme Court. Held, sexual harassment in workplaces is not an individual grievance but a systemic issue perpetuating gender inequality—It restricts women’s economic participation and violates fundamental rights under Arts. 14 (dignity), 18 (right to a safe working environment), and 25 (equality) of the Constitution—Laws against workplace harassment, including the 2010 Act and its Amendment Act, 2022, align with constitutional protections and international obligations—No jurisdictional error or illegality was found in the impugned judgment—Petition dismissed. Cited Cases: • Uzma Naveed Chaudhry v. Federation of Pakistan PLD 2022 SC 783 • Meritor Savings Bank v. Vinson 477 U.S. 57 (1986) • Harris v. Forklift System 510 U.S. 17 (1993) • Vishaka v. State of Rajasthan AIR 1997 SC 3011 • Janzen v. Platy Enterprises [1989] 1 S.C.R. 1252 • Carmichele v. Minister of Safety and Security 2001 (4) SA 938 (CC) (b) Workplace Harassment—Gendered Power Dynamics ----Power imbalance—Hostile work environment—Intersectionality Petitioner, despite holding a subordinate position as a driver, exerted informal power through social reinforcement and gender privilege, creating a hostile work environment for a senior female doctor—Harassment in workplaces stems from entrenched societal norms and gender hierarchies rather than formal authority—Power imbalances allow subordinates to undermine women in leadership roles—Workplace harassment laws must be interpreted in light of systemic discrimination and gendered power structures. Cited Literature: • Catherine A. MacKinnon, Sexual Harassment of Working Women: A Case of Sex Discrimination (1979) • Paula Nicolson, Gender, Power and Organization: A Psychological Perspective on Life at Work (1996) • Deborah Rhode, Speaking of Sex: The Denial of Gender Equality (1999) (c) International Human Rights Standards & Legal Obligations ----ILO Violence and Harassment Convention No. 190—CEDAW—UN Sustainable Development Goals Pakistan’s workplace harassment laws align with international legal instruments, including: • ILO Violence and Harassment Convention No. 190—First binding treaty against workplace harassment, not yet ratified by Pakistan. • CEDAW (1979)—Protects women’s right to a safe working environment free from discrimination. • UN Sustainable Development Goals (Goals 5 & 8)—Mandate elimination of workplace violence and ensuring decent work conditions. Held, ratifying the ILO Violence and Harassment Convention would strengthen Pakistan’s legal protections against harassment, promote human dignity, and reinforce gender equality commitments under international law—Copy of the judgment directed to the Attorney-General of Pakistan for consideration of ratification. Disposition: Petition for leave to appeal dismissed.

Summary: Summary pending

Summary: (a) National Commission for Human Rights Act, 2012 –– Ss. 9 & 18 –– Jurisdiction –– Scope of authority –– Limits of intervention –– Pension dispute involving private bank employee –– The National Commission for Human Rights (NCHR) is empowered under Section 9 of the NCHR Act, 2012 to inquire into violations of human rights by public servants––The Commission’s jurisdiction does not extend to service or pension disputes of private sector employees––NCHR cannot adjudicate private contractual matters such as pension enhancement of employees of commercial banks like UBL––Such directive is ultra vires and amounts to jurisdictional overreach. (b) Constitutional Law –– Art. 9 –– Right to life –– Human dignity –– Pension as element of livelihood –– Scope and limitation –– While the right to a dignified life under Article 9 includes the right to livelihood and sustenance, disputes regarding pension are governed by statutory and contractual frameworks applicable to the relevant employment––Human rights bodies cannot convert service disputes into human rights violations unless gross abuse or discrimination by public authorities is established. (c) Labour Law –– Private Sector Employment –– UBL employee –– Nature of service rights –– Pension rights –– Contractual nature –– Remedies –– Retired employees of private commercial banks are governed by private employment contracts and labour statutes––Their service grievances, including pension claims, must be adjudicated by labour courts, tribunals, or forums specified under the applicable service or banking laws––Human rights bodies are not appropriate adjudicatory forums for such claims. (d) Jurisdiction –– Human Rights Commission –– Abuse of mandate –– Principles –– Doctrine of institutional competence –– Specialized forums –– NCHR’s attempt to direct a private bank to enhance pension of an employee intrudes into areas reserved for labour courts or civil jurisdiction––Intervention by NCHR in such matters undermines institutional comity and circumvents specialized adjudication––Held, NCHR order not sustainable and rightly set aside by learned Single Judge. Relied on: Benazir Bhutto v. Federation of Pakistan (PLD 1988 SC 416) UBL v. National Commission for Human Rights (Judgment of IHC dated 16.06.2022) 2018 SCMR 736 (relied on in impugned order for scope of jurisdictional limits) (e) Practice and Procedure –– Intra-Court Appeal (ICA) –– Maintainability –– Dismissal in limine –– Appeal barred on jurisdictional grounds –– ICA filed by NCHR challenging the order of the learned Single Judge was found to be without merit––No legal infirmity in the finding that NCHR lacked jurisdiction––ICA dismissed in limine. Disposition: Appeal dismissed in limine; order of Single Judge upheld; remedy, if any, lies before appropriate labour or civil forum.

Summary: (a) Constitution of Pakistan ----Arts. 184(3), 185(3), 186, 191A, & 26th Constitutional Amendment Jurisdiction of Constitutional Bench---Interpretation and effect of Article 191A of the Constitution, introduced through the 26th Constitutional Amendment, 2024---Scope and authority of Constitutional Bench vis-à-vis Regular Bench---Petitioners challenged the vires of sub-section (2) of Section 221-A of the Customs Act, 1969, inserted via Finance Act, 2018---Petitions initially entertained by Regular Bench, which proceeded to examine its jurisdiction despite existence of Article 191A---Held, that the jurisdiction for cases involving interpretation of constitutional provisions, including vires of legislation, exclusively vested in the Constitutional Bench under Article 191A---Any proceedings taken or orders passed by the Regular Bench in such matters deemed coram non judice and void ab initio---Supreme Court, through its Constitutional Bench, recalled all orders passed by the Regular Bench in these matters. Cited Cases: Sabir Shah v. Shad Muhammad Khan PLD 1995 SC 66 Fazlul Quader Chowdhry v. Abdul Haque PLD 1963 SC 486 Marbury v. Madison (5 US 137 [1803]) Justice Qazi Faez Isa v. President of Pakistan PLD 2022 SC 119 Mustafa Impex, Karachi v. Government of Pakistan PLD 2016 SC 808 Premier Systems (Pvt) Ltd. v. Federation of Pakistan 2018 PTD 861 (b) Constitutional Interpretation--- ----Principles of interpretation of constitutional amendments---Doctrine of purposive interpretation---Progressive and dynamic approach in interpreting constitutional provisions emphasized---Court observed that interpretation must be harmonious and align with legislative intent while avoiding judicial overreach---Doctrine of “sublato fundamento cadit opus” applied, holding that if foundational jurisdiction is absent, any superstructure built upon it collapses. Cited Cases: Hamza Rasheed Khan v. Election Appellate Tribunal PLD 2024 SC 1028 MQM v. Pakistan PLD 2022 SC 439 Pakistan Tobacco Company v. Government of NWFP PLD 2002 SC 460 LDA v. Imrana Tiwana 2015 SCMR 1739 (c) Judicial Overreach--- ----Separation of powers---Judicial activism versus judicial restraint---Held, that judiciary must operate within the limits of its constitutional jurisdiction and cannot assume legislative functions or expand its authority by judicial orders---Any deviation from this principle amounts to judicial overreach, shaking the foundation of constitutional democracy. Cited Cases: Mian Irfan Bashir v. Deputy Commissioner (DC), Lahore PLD 2021 SC 571 Hardeep Singh v. State of Punjab (2014) 3 SCC 92 Badshah Begum v. Additional Commissioner 2003 SCMR 629 (d) Administration of Justice--- ----Due diligence in case management and jurisdictional determination---Registrar of Supreme Court directed to implement administrative safeguards to prevent jurisdictional errors in case fixation---Recommendations made for IT-based Case Management System with alerts and verification mechanisms to ensure correct allocation of cases to appropriate benches. ----- Disposition: Orders dated 13.01.2025 and 16.01.2025 passed by Regular Bench declared void; all related proceedings nullified.

Summary: Acquittal granted --- (a) Qanun‑e‑Shahadat Order, 1984 --- Arts. 38, 39 & 40; Criminal Procedure Code (V of 1898) --- Ss. 164 & 173— Confession while in police custody recorded by a private journalist—Admissibility—The appellant, on physical remand and confined in the police‑station lock‑up, was taken before a reporter who filmed an “interview” later aired on television; both the trial court and High Court treated the footage as a confession. The Supreme Court held that any statement made to, or in the custody of, a police officer (Arts. 38‑39) is inadmissible unless recorded in the immediate presence of a Magistrate, and that only the portion distinctly leading to a fact discovered is provable (Art. 40). Sections 164/364 Cr.P.C. lay down the exclusive procedure for a voluntary judicial confession; delegating or outsourcing this power to a journalist is illegal and defeats the statutory safeguards. Reliance on the impugned video was therefore a serious misdirection. Cited cases: Sh. Muhammad Amjad v. State PLD 2003 SC 704; Muhammad Amin v. State 2000 SCMR 1784. (b) Law of Evidence—Doctrine of “last seen” — Chance witness—Scope— The prosecution’s sole ocular link was a neighbour (PW‑2) who “last saw” the seven‑year‑old victim with the appellant the previous evening. He lived over half a kilometre away, offered no plausible reason for being at the mosque after congregational prayers, omitted to name the appellant when the FIR was lodged next morning, and surfaced only after arrest. Held, a chance witness must furnish convincing explanation of presence; last‑seen is the weakest type of circumstantial evidence and cannot by itself sustain a capital conviction without strong, independent corroboration. Cited cases: Muhammad Abid v. State PLD 2018 SC 813; Mst. Resham Bibi v. Sheerin Khan 1997 SCMR 1416; Khurshid v. State PLD 1996 SC 305. (c) Criminal trial—Circumstantial evidence—Standard of proof—Benefit of doubt— When prosecution rests entirely on circumstances, the chain must be so inter‑linked that it leads only to the guilt of the accused; any missing or weak link entitles the accused to acquittal. Inconsistencies regarding time of FIR, recovery of the body, motive, and contradictory stories about seizure of the alleged weapon (iron file) shattered the prosecution chain. Under settled law, a single reasonable doubt must be resolved in favour of the accused. Cited cases: Rehmatullah v. State 2024 SCMR 1782; Naveed Asghar v. State PLD 2021 SC 600. (d) Criminal Procedure—Recovery of weapon—Contradictory prosecution evidence— One witness (PW‑3) claimed police collected the iron file from the scene on 09‑03‑2014; police witnesses (PW‑5 & PW‑7) asserted it was produced by the appellant after arrest on 10‑03‑2014. Failure to examine the second mashir and omission to match bloodstains cast grave doubt; recovery evidence consequently discarded. (e) Constitution of Pakistan --- Arts. 4, 9, 10A & 19A—Police facilitation of televised custodial “confessions”—Fair‑trial safeguards and media ethics— Court deprecated the growing practice of parading detainees before cameras, holding it violates presumption of innocence, right to dignity and a fair trial, and can prejudice investigations and adjudication. Directions issued to Ministry of Interior, Ministry of Information & Broadcasting, PEMRA and Provincial Chief Secretaries to frame and enforce SOPs curbing media access to persons in custody and protecting rights of accused and victims. Disposition: Criminal petition converted to appeal and allowed; conviction and death sentence set aside; appellant acquitted by benefit of doubt and released forthwith if not required in any other case.

Summary: (a) Constitution of Pakistan: ----Arts. 9, 14 & 184(3) Fundamental rights—Right to life and dignity—State’s obligation to provide clean water and sustainable environmental infrastructure—Delay in execution of Wastewater Treatment Plant (WWTP) project. Land measuring 6,937 kanals was acquired in 1991-92 for the establishment of a Wastewater Treatment Plant (WWTP) by the Water and Sanitation Authority (WASA) for preventing untreated wastewater from entering the River Ravi. However, despite the lapse of three decades, the project remained unexecuted due to financial constraints. The Supreme Court underscored that access to clean water and environmental protection are integral to the fundamental rights to life and dignity enshrined in Articles 9 and 14 of the Constitution. The Court urged WASA to explore alternative financing mechanisms, including Islamic climate finance, and to consider cost-effective, homegrown wastewater treatment technologies to expedite the project in the public interest. The delay in establishing the WWTP, despite its direct implications for environmental sustainability and public health, necessitated urgent governmental action. (b) Land Acquisition—Public Purpose and Reversion of Acquired Land: ----Punjab Land Acquisition Rules, 1983, R.14 Land acquired for public purposes—Non-utilization for an extended period—Possibility of reversion to original owners. Petitioners challenged the prolonged inaction of WASA regarding the acquired land, arguing that the failure to execute the WWTP project over 30 years contravened the principles governing land acquisition for public purposes. The Court acknowledged that, under Rule 14 of the Punjab Land Acquisition Rules, 1983, land acquired for a public purpose that remains unutilized could be considered for reversion to its original owners. The Court directed that if substantive progress was not reported by September 2025, the question of reversion of the acquired land would remain open for determination. (c) Environmental Law and Climate Resilience: ----Global Climate Risk Index, Sustainable Development Goals (SDGs) Pakistan’s climate vulnerability—WWTP’s role in mitigating water pollution and climate risks—International commitments. Pakistan ranks 8th on the Global Climate Risk Index and 23rd on the 2024 Inform Risk Index, reflecting its susceptibility to climate-induced challenges. The Court emphasized that the WWTP project aligns with the Sustainable Development Goals (SDGs), particularly SDG 6 (Clean Water and Sanitation), SDG 13 (Climate Action), and SDG 14 (Life Below Water). Given the pressing environmental concerns associated with untreated wastewater contaminating the River Ravi, the Court highlighted the necessity of investing in climate-resilient wastewater treatment infrastructure. The delay in implementing the project not only affected environmental sustainability but also hindered Pakistan’s compliance with international climate commitments. (d) Judicial Oversight in Public Interest Litigation: ----Judicial intervention—Guidance without encroachment on policy-making. While policy-making remains within the domain of the executive, the Supreme Court reaffirmed its constitutional duty under Article 184(3) to safeguard fundamental rights. Without encroaching upon the executive’s prerogative, the Court provided recommendations for alternative financing, including Green Sukuk and Islamic finance models, and urged WASA to consider innovative wastewater treatment solutions. The Court directed the Planning and Development Working Party (PDWP), the Central Development Working Party (CDWP), and the Executive Committee of the National Economic Council (ECNEC) to finalize financial arrangements by August 2025 and submit a report. Failure to reach a resolution would necessitate further judicial intervention. ----Disposition: The Supreme Court directed WASA and relevant governmental authorities to finalize financing and implementation strategies for the WWTP project by August 2025, with a compliance report to be submitted to the Court before the next hearing in September 2025. The matter was adjourned for further review.