Summary: (Against judgment/order dated 08.05.2023 and 06.05.2024 passed by the High Court of Sindh, Karachi in Income Tax Cases Nos. 633 to 638 of 2001 and Income Tax Reference Application No. 220 of 2008, respectively). (a) Income Tax Ordinance (XXXI of 1979) [since repealed]--- ----Second Sched., Pt.1, Cl. 93---Income Tax Ordinance (XLIX of 2001), Second Sched., Pt.1, Cl. 59---Constitution of Pakistan, Art.185(3)---Income tax exemptions---Scope and preconditions---Essential elements and components---Charitable purpose---Meaning, extent and application---Pakistan Stock Exchange Limited filed seven connected civil petitions arising from income tax assessments for tax years 1993-94 to 1998-99 under the Income Tax Ordinance, 1979, and tax year 2003 under the Income Tax Ordinance, 2001, in which the appellate tribunal had earlier allowed exemption on income from ‘house property’ under clause (93) of the Second Schedule (1979 Ordinance) and clause (59) (2001 Ordinance), but the High Court later reversed those findings---Core issue befor e the Supreme Court was “whether the petitioner was legally entitled to income-tax exemption by establishing that its income was derived from house property held under legal obligation for charitable purposes and was actually applied or finally set apart for such charitable application”?---Held: Insofar as the first “element” for exemption from tax was concerned, it appeared to be clear that the income in question was derived from “house property”---Therefore it was appropriate to move on to the second “element”, which had been the principal point of dispute between the parties---This itself could be regarded as having two “sub-components”: (i) the income must be held under trust or “other legal obligations”, which must (ii) be “wholly, or in part only, for … charitable purposes” (it being common ground that no “religious” purposes were involved in the case)---It was not enough for the petitioner simply to show that the sub-clause was a “charitable purpose” as the exemption clause required that the sources of income or the income be held under some “legal obligation”, either wholly or in part, for a “charitable purpose”---Sub-clause (2) could be regarded as a “charitable purpose” within the meaning of the definition clause---Therefore, while disagreeing with the High Court, Supreme Court concluded that the petitioner’s situation, in the facts and circumstances of the case, came within the definition clause---An examination of the order of the tribunal showed that there was no affirmative and actual finding of fact that the income in question was either actually applied or “finally” set aside for purposes of achieving the objects set out in sub-clause (2)---The entire discussion related to a matter of law, i.e., whether the sub-clause in question could be regarded as a “charitable purpose”---A finding in favor of the petitioner was recorded in this regard, but that was not enough---The tribunal also had to apply its mind as to whether the third “element” of the exemption clause existed during the periods in question and absent any such finding the benefit of the exemption clause could not be extended to the petitioner---In our view, while the finding of the tribunal might have sufficed for purposes of the second “element” of the exemption clause, it was wholly deficient for the third “element”---The reasoning appeared simply to amount to this: that because the second “element” was found to exist therefore the third was equally found to (or must) exist---But, the tribunal failed to appreciate that while the determination of the second “element” was a question of law (or perhaps a mixed question of law and fact) the third “element” was a separate requirement, which was only a question of fact---The existence of the one could not, and did not, inevitably, as seemed to have been concluded by the tribunal, lead to the other---To conclude that the one existed did not show or mean that the other did as well---The positive obligation that lay on the petitioner in this regard was not discharged---And since the tribunal was the last finder of fact the exercise in relation to the third “element” could not be carried out by either the High Court (which in any case decided against the petitioner) or the Supreme Court---This deficiency was fatal for the petitioner’s case---Even when the exemption clause was viewed in its totality the last portion thereof had to be clearly established, at the latest, by or before the final forum designated to determine questions of fact---This was patently not the situation at hand---Petitioner had failed to make out a case for entitlement to the exemption clause---Leave to appeal was refused and the petitions were dismissed, in circumstances. Cotman v. Brougham [1918] AC 514, [1918-19] All ER Rep 265, [1918] UKHL 358; Re Introductions Ltd. [1968] 2 All ER 1221; [1969] 1 All ER 887; Anglo Overseas Agencies Ltd. v. Green and another [1960] 3 All ER 244 and Commissioner of Income Tax v. Merchant Navy Club 2004 PTD 1304 ref. Commissioner of Income Tax v. Muhammad Abdur Rauf Khan PLD 1963 SC 209; Hamdard Dawakhana v. Commissioner of Income Tax PLD 1980 SC 84 and Fauji Foundation v. Shamimur Rehman PLD 1983 SC 457 rel. (b) Interpretation of statutes--- ----Fiscal statute---Exemption clause---Application and interpretation---Firstly, the onus lies on the taxpayer to show that his case comes within the exemption---Secondly, if two reasonable interpretations are possible the one against the taxpayer will be adopted---But, thirdly, if the taxpayer’s case comes fairly within the scope of the exemption then he cannot be denied the benefit of the same on the basis of any supposed intention to the contrary of the legislature or authority granting it. Oxford University Press v. Commissioner of Income Tax 2019 SCMR 235 rel. (c) Income Tax Ordinance (XXXI of 1979) [since repealed]--- ----Second Sched. Pt.1, Cl.93---Income Tax Ordinance (XLIX of 2001), Second Sched., Pt.1, Cl.59---Income tax---Exemption---Essential elements / components---The exemption clause can be said to contain three “elements”---The income for which exemption is sought (i) must be from “investments in securities of the Federal Government and house property”; (ii) either the said sources of income or the income itself must be “held under trust or other legal obligations wholly, or in part only, for religious or charitable purposes”; and (iii) the income must be “actually applied or finally set apart for application thereto”. Abdul Ghaffar Khan, Advocate-on-Record for Petitioner (in all cases via video-link, Karachi). Munawar Ali Memon, Advocate Supreme Court, Mrs. Abida Parveen Channar, Advocate-on-Record, M. Masood, Additional Commissioner, (via video-link, Karachi) and Dr. Ishtiaq, D.G. (Law) for Respondents. Date of hearing: 21st April, 2025.

Summary: 177ITR (Income Tax Reference) 41034/17 COMMISSIONER INLAND REVENUE Vs MS. M. FAISAL LAHORE Mr. Justice Hassan Nawaz Makhdoom 24- 10- 2025 2025 LHC 6475

Summary: (a) Specific Relief Act (I of 1877)--- ----Ss.42, 8, 54 & 39---Suit for declaration, possession, mesne profit, permanent injunction, cancellation of document and partition---Islamic law---Will deed---Legality---Respondents/plaintiffs claimed their share in the ownership/inheritance of their ancestor---Applicants/defendants took a plea the a will deed had been executed in favour of their father qua the whole inherited property---Trial decreed the suit while cancelling the will deed and referring the matter to revenue hierarchy for partition---Appellate court upheld the findings of the trial court---Validity---Muslim may validly bequeath only up to one-third of his estate, and such bequest in favour of a legal heir shall not take effect without the consent of the remaining heirs after the death of the testator---Right to execute a will cannot be exercised to the detriment or exclusion of other legal heirs, as such a disposition would directly infringe upon their vested rights of inheritance---Co-owner or co-sharer cannot alienate or transfer more than his own entitlement in a joint property---Other legal heirs neither assented to the will nor accepted its validity, thus, the estate of the deceased was rightly ordered by the courts below to devolve upon all heirs under the principles of inheritance, rendering the alleged will deed ineffective in law beyond one-third of the property---Trial court had already referred the matter to revenue authorities for effecting partition of the property in accordance with law, thus, once the jurisdiction of the revenue hierarchy had already been invoked through the judgment of the Trial Court, there remained no necessity for High Court to render any further findings on the question of jurisdiction or partition---Civil revision was dismissed, in circumstances. PLD 1977 SC 220; 1968 SCMR 214; PLD 1989 SC 568; PLD 1986 Kar. 73; 2021 MLD 531; 2007 CLC 1790; PLD 1967 SC 200; 2007 SCMR 497; 1999 SCMR 971; 1992 SCMR 2182; 2022 CLC 1700; 2002 CLC 808; 2015 CLC 298; 2001 CLC 1323; 1988 CLC 931; 1997 CLC 2012; 1991 MLD 145; 1995 SCMR 1489; 2022 CLC 692; 2004 SCMR 877; 2010 SCMR 1868; 1991 MLD 145 and PLD 2023 Sindh 231 ref. Rab Nawaz and another v. Akbar Ali and others 1989 SCMR 93; Ali Gohar v. Sher Ayaz 1989 SCMR 130; Muhammad Hussain v. Wahid Bux 2004 SCMR 1137; Muhammad Shamim through legal heirs v. Nasir Fatima through legal heirs and others 2010 SCMR 18; Mahomed Hussain Haji Ghulam Mahomed Alam v. Alshabai and others AIR 1935 Bombay 84; Muhammad Aslam Rashid and 2 others v. Dr. Muhammad Anwar Saeed and 4 others 1997 CLC 2012; Ihsan Ilahi and others v. Hukam Jan PLD 1967 SC 2000; Abdul Razzaq and 8 others v. Shah Jehan and 5 others 1995 SCMR 1489 and Zakirullah Khan and others v. Faizullah Khan and others 1999 SCMR 971 rel. (b) Islamic law--- ----Execution of will contrary to Muhammad Law or the statutory requirements---Duty of Court---Scope---Once the will deed is brought on record and it appears to be contrary to the principles of Muhammad Law or the statutory requirements, it becomes the judicial duty of the court to examine its legality, as the same directly affects the rights of other legal heirs---Any outlook that seeks to deprive lawful heirs of their rightful shares under a void or invalid will cannot be overlooked or allowed to stand. Akram v. Vakeel Muhammad and others 2022 CLC 1700 rel. (c) Islamic law--- ----Will---Nature and scope---Will, according to various schools of thought, is indeed a recognized instrument through which a person expresses his intention regarding the disposition of his property, however, such intention and disposition are not absolute in nature but are subject to certain legal limitations prescribed by the law, therefore, while interpreting or relying upon a will deed, it must be examined strictly within the framework of the legal and religious parameters governing testamentary disposition. Ghulam Dastagir A. Shahani and Abdul Rehman A. Bhutto for Applicants. Muhammad Qasim Khan and Abdul Waris Bhutto, Assistant Advocate General, Sindh for Respondents. Date of hearing: 20th October, 2025.

Summary: Constitution of Pakistan--- ----Art. 199---Constitutional jurisdiction of a High Court, invoking of---Territorial incompetency---Scope and effect---Federation of Pakistan, impleading of---Scope---Whether Islamabad High Court possessed the territorial jurisdiction to adjudicate upon the present constitutional petition emanating from a matter that occurred in territorial jurisdiction of Sindh High Court?---Held: The gravamen of the petitioner's grievance stems from the impugned confiscation order, passed by the respondent (an authorized officer of Department of Plant Protection -Samples Collector at Karachi), which mandated the confiscation and destruction of the imported consignments---Impugned order revealed that it was issued from and signed by the authority situated in Karachi, Sindh---The entire chain of events, from the physical inspection of the consignments at the Karachi port, the drawing of samples, the issuance of the remedial directive, to the final confiscation order, transpired exclusively within the territorial limits of Karachi---Petitioner itself lodged its application for clearance with the office of respondent (Department of Plant Protection) in Karachi---Consequently, the cause of action, in its entirety, arose within the Jurisdiction of the High Court of Sindh---Petitioner, in an attempt to bridge said jurisdictional gap, had impleaded the Federation of Pakistan as respondent (No. 1)---However, a scrutiny of the petition revealed a conspicuous absence of any substantive allegations, overt acts, or specific pleadings of mala fide against the Federation---It was manifest that respondent No. 1/Federation had been made a party merely as a proforma respondent, a tactic that could not be permitted to confer jurisdiction upon this (Islamabad High) Court when the root of the dispute and the party against whom the primary relief was sought were squarely located elsewhere---Mere impleading of the Federation, without any specific allegations or cause of action against it, was insufficient to invoke the jurisdiction of a court when the real dispute and the effective authority resided in a different Province---Rationale underpinning said principle was to prevent the abuse of the judicial process and to ensure that constitutional petitions were adjudicated by the High Court within whose territory the aggrieved person resided or the cause of action substantially arose---In the present case, the inclusion of the Federation was a colourable device that did not vest this (Islamabad High) Court with jurisdiction---Petitioner's recourse, if any, laid before the competent Court in Karachi, where real respondent (Department of Plant Protection -Samples Collector) was located and where the entire cause of action had crystallized---Islamabad High Court refrained from commenting on the merits of the substantive legal arguments raised by the petitioner regarding the validity of the impugned confiscation order---Constitutional Petition, solely on the ground of territorial incompetence, was dismissed. Messrs Sethi and Sethi Sons through Humayun Khan v. Federation of Pakistan through Secretary, Ministry of Finance, Islamabad and others 2012 PTD 1869 ref. Barrister Qaim Ali Chohan for Petitioner. Raja Zamir ud Din Ahmed, A.A.G. for Federation of Pakistan. Ms. Huma Nazir Kayani, Entomologist for Respondent No. 2. Date of hearing: 23rd October, 2025.

Summary: Summary pending

Summary: (a) Family law—Dissolution of Muslim Marriages Act, 1939 (DMMA) ----S. 2(ii), (ii-a), (viii); Muslim Family Laws Ordinance, 1961 (MFLO), S. 6; Constitution, Arts. 14, 25 & 35 Dissolution—Grounds—Second marriage without permission—Admitted second marriage contracted by husband during subsistence of first marriage, without consent of first wife or permission of Arbitration Council—Conviction under S. 6(5), MFLO remained unchallenged—Held, contravention of S. 6, MFLO squarely attracts S. 2(ii-a), DMMA and, by itself, furnishes a complete ground to dissolve the marriage—Marriage dissolved on this ground. (b) Family law—Khula v. statutory dissolution ----DMMA, S. 2; MFLO, S. 6 Whether Family Court may convert a suit for dissolution on statutory grounds into khula without wife’s consent—Held, No—Khula is a distinct remedy premised on the wife’s informed, voluntary consent; it cannot be imposed to replace a failed statutory ground—Family Court erred in granting khula suo motu and in forfeiting dower on that basis. (PLD 2024 SC 645 ref.) (c) Evidence—Standard of proof in DMMA proceedings ----DMMA, S. 2; QSO, 1984, Art. 117 (general burden) Standard—Balance of probabilities applies; insistence on FIRs, medical certificates or documentary corroboration to prove cruelty is misconceived—Courts must assess the woman’s testimony and surrounding circumstances, including mental and emotional abuse often occurring in private (“bedroom crime”)—High Court’s reliance to avoid re-appraisal in constitutional jurisdiction is inapt where the legal standard applied below is erroneous. (PLD 2022 SC 353; 2024 SCMR 1271; 2021 SCMR 1986; PLD 1996 SC 267; 1995 SCMR 955; 2022 CLC 974; 2023 SCMR 1434 distinguished) (d) Cruelty—Scope and assessment ----DMMA, S. 2(viii) Cruelty includes physical, mental and emotional abuse; may consist of patterns of conduct rendering marital life intolerable; focus is the impact of the husband’s behavior on the wife—Courts below erred by treating absence of eyewitnesses and documents as fatal and by ignoring the cumulative effect of conduct pleaded and deposed. (PLD 1963 Dacca 947; 2015 MLD 1623; 2013 CLC 1203; 2023 SCMR 246 ref.) (e) Maintenance during subsistence of marriage ----Nikahnama (cl. 17); MFLO; Constitution, Arts. 14, 25 & 35 Obligation—Payment of Rs.10,000 per month stipulated—Unrebutted evidence of non-payment—Alleged “disobedience” is not a lawful ground to deny maintenance—Findings to contrary set aside; maintenance payable for the subsistence period of marriage. (PLD 2022 SC 686 ref.) (f) Dower (mehr) ----Khula not granted—Effect—Where dissolution is decreed on a statutory ground (here, illegal second marriage), wife is not required to return dower—Petitioner entitled to retain plot (200 sq. yds., FES Jinnah Garden Phase-I, Islamabad), 30 tolas gold, and Rs.500,000/-; amount not earlier paid remains payable. (g) Judicial reasoning—Gender-sensitive adjudication & language ----Constitution, Arts. 14, 25 & 35 Courts must eschew patriarchal stereotypes and moralistic terminology (“disobedient/self-deserting wife”, “compelled to contract second marriage”) that stigmatize women and obscure legal standards—Judicial language must reflect dignity, equality and non-discrimination; findings must be evidence-based, not presumption-driven. (h) Case law distinguished / affirmed ----Rashid Ali Shah v. Haleema Bibi, PLD 2014 Pesh 226, and similar views—Not good law post-PLD 2025 SC 262; clause (ii-a) of S. 2, DMMA remains a subsisting ground—Hamad Hassan v. Mst. Isma Bukhari, 2023 SCMR 1434, distinguished on scope (standard of proof issue, not re-appraisal of facts). (PLD 2025 SC 262 ref.) Cited Cases: • Ibrahim Khan v. Mst. Saima Khan, PLD 2024 SC 645 • Faryal Maqsood v. Khurram Shehzad Durrani, PLD 2025 SC 262 • Haseen Ullah v. Mst. Naheed Begum, PLD 2022 SC 686 • Hamad Hassan v. Mst. Isma Bukhari, 2023 SCMR 1434 (dist.) • Muhammad Shariful Islam v. Suraya Begum, PLD 1963 Dacca 947; Shahana Bibi v. Nadeem Shah, 2015 MLD 1623; Rabia Rasheed v. Faisal Mir, 2013 CLC 1203; Tayyeba Ambareen v. Shafqat Ali Kiyani, 2023 SCMR 246 • Salamat Ali v. Muhammad Din, PLD 2022 SC 353; Nazeeran v. Ali Bux, 2024 SCMR 1271; Khalid Hussain v. Nazir Ahmad, 2021 SCMR 1986; Muhammad Amir v. Khan Bahadur, PLD 1996 SC 267; Begum Hamid Mehmood v. Muhammad Masood, 1995 SCMR 955; Meezan Bank Ltd. v. WAPDA First Sukuk Co., 2022 CLC 974 Disposition: Civil petition converted into appeal and allowed—Judgments of Family Court, Appellate Court and High Court set aside to the extent of khula, dower and maintenance—Marriage dissolved on ground of second marriage in violation of law (DMMA S. 2(ii-a) read with MFLO S. 6)—Petitioner retains dower (plot, gold, Rs.500,000/-) and is entitled to maintenance at Rs.10,000 per month for the period the marriage subsisted—Approved for reporting.

Summary: Colonization of Government Lands (Punjab) Act (V of 1912)--- ----Ss. 19, 32 & 34---Allotted land under Cooperative Farming Scheme---Proprietary rights, grant of---Propriety and procedure---Allottee selling/subletting land---Legality---Record (including reports of the revenue field staff) revealed that the predecessor of the respondents was allotted State land in-question owned by the Provincial Government under Cooperative Farming Scheme in 1956---Respondents claimed that the District Collector, in the year 1986, granted the PRs to said predecessor but they could not adduce original orders---In 2008, the revenue fieldstaff without seeking permission from the District Collector, passed the inheritance mutation illegally in favour of the legal heirs of predecessor---The respondents kept silent from 1986 to 2014 which made the case extremely doubtful, and then filed writ petition in pursuance of which proceedings, the District Collector constituted a Committee for probing existence of the allotment order---Said Inquiry Committee recommended that in absence of the original allotment orders and proper advice of the Cooperatives Department, conveyance deed cannot be issued ;accordingly, the ADC (R) on the report of Inquiry Committee and non-availability of original allotment letter and order for grant of PRs, rejected the application of the defendants in the year 2019 after providing opportunities to them (respondents) for provision of evidence or any advice from the Cooperative Society to prove their version and rejected the application of the defendants---Later on, on the application of the appellant, the ADC (R) obtained report from the Colony Assistant, which revealed that the impugned land was not under possession and cultivation of the legal heirs of the allottee--It was also proven, and admitted, by the respondents, that they had sold the State land to the other respondents (Nos.5-11) illegally and in blatant disregard of S.19 of the Colonization of Government Lands (Punjab) Act, 1912 ('the Act 1912') vide which no Government land can be sold without approval of the Commissioner and before issuance of the conveyance deed---The ADC (R), on account of violation of terms and conditions of the allotment, resumed the land in favour of the State with direction to the Assistant Commissioner to retrieve the State land from the illegal encroachers and impose tawan for illicit cultivation upon them---Despite such irregularities, the Additional Commissioner while issuing the ex-parte impugned order, wrongly presumed that the Act, 1912 was not applicable in the instant case---Not affording hearing opportunity to the person who provided all proofs, and challenged illegalities committed by the respondents in collusion with field staff was questionable---The legal position was also checked from the Colonies Department, Board of Revenue, which had underscored that all such lands fell, and were allotted, under the Act 1912; hence, the provisions of the Act 1912 were equally applicable---Thus, the allottees could not sell or sublet the land allloted under Cooperatives Department Societies before issuance of PRs and conveyance deed and without approval of the Commissioner---Respondents could not point out any infringement of their rights nor could rebut the facts and legal position---Member-Board of Revenue set-aside the impugned orders passed by the Additional Commissioner (Revenue) being not sustainable in the eyes of law; resultantly, the orders passed by the Additional Deputy Commissioner (Revenue) were upheld with the direction to the District Collector to resume the State land in favour of the state and retrieve the same from illegal encroachers imposing maximum tawan----Revision was accepted. Qamar Khurshid Ahmad Bhatti for Appellant. Ch. Saeed Ahmad for Defendants Nos. 5 and 7. Ch. Asghar Saeed Anwar for Defendants Nos. 4(i-ix), 6 and 8 to 11.

Summary: Judicial Commission of Pakistan (Appointment of Judges) Rules, 2024- -R.6-Constitution of Pakistan, Art.175-A-Minority quota in superior judiciary-Petition for fixation of 5% representation-Constitutional scheme of judicial appointments-Non-applicability of quota system in superior judiciary-Petitioner filed a constitutional petition seeking directions for fixation of a 5% quota for minorities in the superior judiciary-The High Court examined whether such a quota could be constitutionally mandated, considering the framework of Art.175-A of the Constitution, which governed judicial appointments through the Judicial Commission of Pakistan based on merit and diversity considerations-The core issue in the present matter was-whether quota-based appointments could be introduced in the superior judiciary?-Held: Petitioner mainly focused on the 5% quota for minorities-The judicial service was not a traditional form of employment and was separate from other services-Members of other services could not be equated with members of the judiciary, either constitutionally or functionally-Therefore, the 5% quota could not be considered to prioritize the judiciary or the High Court-It was, hence, not appropriate to compromise on merit-Present petition, being devoid of any merits, was dismissed, in circumstances. Petitioner in person.

Summary: Summary suit----Order XXXVII Rule 1 & 2 C.P.C. Ex-parte proceedings ? Setting aside ? Defendant detained in jail ? Service of summons through Jail Superintendent under Order V. Rule 24 C.P.C.? Duty of Court to ensure access to justice ? Failure to summon incarcerated defendant amounts to denial of fair trial ? Trial Court erred in proceeding ex-parte despite knowledge of detention ? Revision accepted, ex-parte proceedings set aside. 186First Appeal Against Order- First Appeal against order (Order

Summary: Educational institution--- ----Admission, cancellation of---Cancellation of admission secured by misrepresenting the marks/percentage, challenge to---False declaration in admission form---Consequences---Admission cancelled due to ineligibility---No vested right would accrue due to continued attendance and payment of fee---Illegality cannot mature into a legal entitlement---Constitutional jurisdiction of the High Court, invoking of---High Court’s limited interference in academic and administrative decisions of universities---Scope---Brief facts were that the petitioner secured admission in BS International Relations (Fall 2018) at the respondent university after submitting an online admission form in which he declared securing 443/950 marks, whereas his actual result was 443/1100, making him ineligible under the university’s criteria, and his admission was cancelled though he continued attending classes due to procedural lapses---After a previous writ petition was treated as a representation which was decided against him, he filed the present petition challenging that decision---Issue requiring determination before the High Court was as to “whether the petitioner, having obtained admission through misrepresentation of academic marks and having continued his studies for several semesters, was entitled to constitutional relief against cancellation of admission under Article 199 of the Constitution”?---Held: Under constitutional jurisdiction, interfere in academic, disciplinary, or administrative policy matters of educational institutions, particularly where no violation of any fundamental or statutory right was established, was not warranted---The petitioner’s own conduct was tainted with misrepresentation and concealment---In his admission form, he categorically declared that “The information furnished in the application form is correct and nothing has been concealed in this regard”---Moreover, all the attached documents i.e. Matric/ Intermediate/ Bachelor/Master/ MS/ MPhil/ equivalent results were complete, correct and meet the eligibility criteria as per advertisement---If the information provided or the documents attached were found deficient/incorrect/false/fake/or tampered at any stage, the university had the right to cancel the admission without any refund---Having voluntarily and consciously executed such an undertaking, the petitioner stood precluded, under the well-established doctrine of estoppel, from invoking the constitutional jurisdiction of the High Court to seek protection against the very consequence that lawfully emanated from his own false declaration---The petitioner, regrettably, chose to begin his academic journey on a false foundation, and having done so, he could not later invoke equity to validate that which was void from inception---As regards the contention that the petitioner’s continued attendance in classes and regular payment of fees created a vested right under the principle of locus poenitentiae, it sufficed to observe that an illegality could not ripen into legitimacy merely through the passage of time or by continued participation in an unlawful arrangement---No benefit could flow from a fraudulent or deceitful act---The petitioner, being the architect of his own wrong, could not claim equity or protection from the High Court---The equitable maxim “he who seeks equity must come with clean hands” squarely applied---A structure founded upon falsehood could not be sustained in law; therefore, any claim erected upon such a defective foundation must collapse under its own weight, and the petitioner alone must bear responsibility for the consequences of his own misconduct---Constitutional petition was devoid of merit and was dismissed, in circumstances. Umair Mahmood for Petitioner. Nauman Munir Paracha for Respondents Nos. 1 to 6. Date of hearing: 16th October, 2025.