Summary: Summary pending

Summary: Though a statement can be recorded by a Magistrate under Section: 164 Cr.P.C. yet during the course of an investigation under Chapter XIV of Cr.P.C. or at any time thereafter, but before commencement of an inquiry or trial and it goes without saying that investigation always commences after registration of the case. However, under Section: 174-A Cr.P.C., statement of a person, who has sustained grievous burn injuries, can be recorded immediately even before registration of case or commencement of the investigation.

Summary: It is observed with all clarity that a decree for declaration is not executable in terms of Order XXI CPC. It is trite law that whenever a Civil Court passes a decree for declaration, the revenue authorities are under obligation to act upon the same while considering it as a primary obligation. A decree for declaration cannot be put to execution in ordinary manner as prescribed under Order XXI CPC and instead such a decree is to be presented to the revenue officer for attestation of mutation and its incorporation in the revenue record in the mode prescribed under section 42 of the Punjab Land Revenue Act, 1967.

Summary: Summary pending

Summary: Summary pending

Summary: For an agreement required to be proved by the parameters of section 68 of the Evidence Act-1872, one witness would have sufficed to support the Seller, provided the Seller's own evidence is credible and plausible, and then the produced marginal witness has some logical flow and consistency; otherwise, it militates against the proof of disputed documents.

Summary: (a) Criminal Procedure Code (V of 1898)---Case property---Interim release of mobile phone---Digital evidence---Mobile phone recovered during investigation, documented through recovery memo and subjected to forensic examination---Forensic report disclosed relevant defamatory and incriminating material---Device consequently assumed character of case property as well as material piece of evidence for investigation and trial---Release before determination of its evidentiary value could create reasonable apprehension of tampering, alteration, deletion or loss of digital evidence. (b) Criminal procedure---Electronic device---Positive forensic report---Effect---Where incriminating material was recovered from a digital device during lawful forensic examination, mere claim of ownership did not entitle claimant to immediate return of device---Requirement to preserve integrity and availability of electronic evidence prevailed until Trial Court had examined its relevance and evidentiary worth. (c) Criminal procedure---Interim custody of property---Claim of lawful ownership---Ownership and evidentiary necessity---Even where petitioner asserted that recovered property belonged to him or his family, release could be declined where article had direct relevance to pending criminal proceedings and constituted material evidence---Temporary retention of such property did not amount to permanent deprivation of ownership. (d) Criminal revision---Scope of revisional jurisdiction---Order refusing release of case property---Revisional Court would not interfere unless impugned order suffered from illegality, material irregularity, jurisdictional defect or perversity---Trial Court had considered nature of recovered mobile phone, positive forensic result and relevance of device to pending proceedings---No ground warranting revisional interference was established. (e) Digital evidence---Preservation---Chain of custody---Where electronic device was retained as case property, Investigating Officer was under obligation to preserve both physical device and its digital contents in accordance with law---Proper chain of custody was required to be maintained so that integrity of evidence remained intact and no prejudice was caused to either prosecution or accused during trial. (f) Criminal procedure---Gold ornaments and cash allegedly taken by investigating agency---Absence of recovery record---Petitioner sought release of five tolas of gold and cash amounting to Rs.350,000, but record did not establish that such articles had been recovered by Investigating Officer during investigation---No direction for their release could be issued in absence of documented recovery or custody. Disposition---Criminal revision dismissed as devoid of merit---Order declining release of iPhone 13 Pro Max maintained---Investigating Officer directed to preserve mobile phone and its digital contents in accordance with law and maintain proper chain of custody. Humayun Rind Baloch v. The State, Criminal Revision No.44 of 2026, Islamabad High Court, decided on 08.06.2026.

Summary: (a) Muslim Family Laws---Khula---Dissolution of marriage---Reconciliation---Family Court dissolved the marriage between the petitioner and respondent on the basis of khula in lieu of dower by decree dated 13.09.2014, after recording that pre-trial reconciliation had failed because the respondent harboured extreme hatred towards the petitioner and was unwilling to continue the marital relationship---Held, that khula occupies a well-recognised place in Islamic jurisprudence and in the statutory framework governing Muslim family law, affording a woman a lawful means of exiting a marital relationship she no longer wishes to continue---Once the court is satisfied that reconciliation is not feasible and that the wife's need to dissolve the marriage is genuine and settled, khula operates as a complete and valid mode of dissolution carrying full legal effect, corresponding in its own sphere to the husband's right of talaq---Requirement of reconciliation is not a perpetual or open-ended entitlement in favour of the husband; it is a pre-trial procedural measure that operates only until the court is satisfied that the marriage cannot be sustained---Law does not require a wife to negotiate, justify or temper her aversion in order to make it palatable to the husband---Where hatred and revulsion preclude continuation of marital life, dissolution through khula follows as a matter of legal consequence---Petitioner's assertion that he was not afforded adequate opportunity for reconciliation was contrary to the record and legally misconceived---Question of legality of khula stood decisively answered by courts of competent jurisdiction. (b) Administration of justice---Abuse of process---Criminal process invoked after khula and remarriage---Dignity and autonomy of divorced wife---After observing iddat the respondent contracted a second marriage---Petitioner sought registration of a criminal case under S. 22-A, Cr.P.C., asserting that she was still his lawful wife, after a private complaint on identical allegations had already been dismissed by the Magistrate on 10.02.2016---Writ petitions challenging the Family Court and Justice of Peace orders were dismissed by the High Court---Held, that a woman who has lawfully obtained khula and observed the prescribed period of iddat is fully entitled in law, as a valid realisation of her inherent personal autonomy, to contract a subsequent marriage of her own choosing---That right is neither contingent upon approval of her former husband nor subject to his continuing moral or legal supervision---Allegation that she contracted a second marriage during subsistence of the first, in disregard of an existing decree of khula and undisputed observance of iddat, was capable of conveying an insinuation of moral impropriety and of stigmatising her---Invocation of criminal law to perpetuate such an allegation constituted a clear misuse of legal process---Criminal proceedings and applications initiated on the premise that the khula was ineffective or that the subsequent marriage was unlawful were declared frivolous, vexatious and abusive in nature---Litigation initiated or sustained with the object of gendered harassment, humiliation or reputational harm must be viewed as abuse against women---Frivolous and vexatious litigation pursued to inflict personal or reputational harm shall be met with firm judicial response including imposition of appropriate costs. Disposition: Petition dismissed with costs quantified at Rs.500,000 (five hundred thousand), payable by the petitioner to the respondent within thirty days, failing which the same shall be recoverable through execution proceedings before the Family Court concerned. (C.P. No.303-P of 2018, against judgment dated 08.02.2018 of the Peshawar High Court in W.P. No.3034-P/2014, Supreme Court of Pakistan, judgment dated 04.06.2026, by Yahya Afridi, C.J.; Approved for reporting)

Summary: (a) Constitution of Pakistan----Art. 188---Supreme Court Rules, 2025, Part IV, O. XXVIII---Review jurisdiction---Scope in criminal matters---Not an appeal in disguise---Petitioner, convicted of rape and murder of Noor Mukadam, had been sentenced to death as Ta'zir under S. 302(b), P.P.C., and also convicted under Ss. 364, 342 and 376(1), P.P.C.---Islamabad High Court maintained the convictions and sentences---Supreme Court, by judgment dated 20.05.2025 in Criminal Petition No.467 of 2023, converted the petition into an appeal: maintained conviction and death sentence under S. 302(b), P.P.C.; maintained conviction under S. 376(1), P.P.C., but converted the death sentence thereunder to imprisonment for life; set aside conviction and sentence under S. 364, P.P.C.; and maintained conviction and sentence under S. 342, P.P.C.---Petitioner sought review, confining submissions to sentence and urging mental illness, denial of counsel of choice, and inadmissibility of forensic reports as mitigating circumstances warranting conversion of death to life imprisonment---Held, that Art. 188 of the Constitution, read with Part IV, O. XXVIII of the Supreme Court Rules, 2025, vests the Court with jurisdiction to review its judgments or orders, but that jurisdiction is neither appellate in nature nor exercisable as a matter of course---Review is not, and cannot be permitted to be, an appeal in disguise---It does not provide a forum for rehearing, for re-arguing matters already canvassed and decided, for reappraisal of evidence, re-evaluation of ocular testimony, or for reopening concluded questions of fact---In criminal matters, review is circumscribed within narrow contours and can be invoked only where an error apparent on the face of the record is demonstrated, or where interference is warranted in the interest of justice or to prevent abuse of the process of the Court---Error contemplated must be patent, manifest and self-evident from the record itself; it must not require elaborate argumentation, detailed scrutiny of evidence, or a process of reasoning akin to appellate adjudication---Any attempt to invite the Court to reassess evidence or revisit findings of fact is clearly beyond the scope of review jurisdiction. Cited Cases: • Ghulam Sarwar v. The State 1979 SCMR 43 • Yaqoob Khan v. The State PLD 1996 SC 97 • Ayyaz Baig alias Bau Chuhanwala v. The State 2002 SCMR 380 • Naseer Ahmed v. The State 2006 SCMR 942 • Khan v. The State 2008 SCMR 880 • Sikandar Hayat v. The State PLD 2020 SC 559 (b) Penal Code----S. 302(b)---Criminal Procedure Code, Ss. 342 & 465---Plea of mental illness as mitigating circumstance on sentence---Letter of a foreign psychiatrist relating to a drug-induced psychotic episode in 2015---Occurrence of 20.07.2021---Held, that the plea did not find favour with the Trial Court, the High Court, or the Supreme Court at the stage of deciding the criminal petition---Statement of the petitioner recorded under S. 342, Cr.P.C. showed that he responded to questions in a coherent and detailed manner as a normal individual; nothing suggested that he was unable to comprehend the nature of the proceedings, understand the questions, or effectively participate in his defence---Principal document relied upon was a letter dated 14.01.2022 issued by Dr. Philip Hopley, MRCPsych, Consultant Psychiatrist, Harley Street, London, recording examination on 21st April, 2015 and a drug-induced psychotic episode, but further recording that the petitioner was referred for psychological treatment, remained in therapy for approximately six months, and made a full recovery---Occurrence took place on 20.07.2021; the letter was issued subsequently---Apart from that letter, no contemporaneous, continuous or independent medical record was produced to establish that the petitioner remained under psychiatric treatment, suffered from any mental disorder, or was experiencing mental incapacity at or around the time of the occurrence or during trial---Reliance upon a solitary document pertaining to a remote period, particularly one not proved through its author or any other competent witness, cannot by itself constitute sufficient proof of legal unsoundness of mind or diminished responsibility---No material was brought before the Trial Court indicating that the petitioner was incapable of understanding the proceedings or instructing counsel; neither his conduct during trial nor his interaction with the Court disclosed abnormality warranting inquiry into mental incapacity---In the absence of cogent, reliable and contemporaneous medical evidence establishing mental incapacity at the relevant time, and having regard to the manner in which he participated in the proceedings and responded under S. 342, Cr.P.C., the Court was unable to conclude that he was suffering from any mental illness of such a nature as would impair his ability to understand the proceedings, instruct counsel, or defend himself---Plea of mental incapacity did not constitute a mitigating circumstance warranting interference in the sentence. (c) Constitution of Pakistan----Arts. 4, 9 & 10-A---Fair trial---Representation by counsel appointed at State expense---Petitioner was represented by counsel throughout proceedings before the Trial Court, the High Court, and the Supreme Court at the leave stage---Counsel was appointed at State expense because the petitioner did not engage counsel of his own choice despite being afforded the opportunity to do so---Co-accused, his parents, who were being tried jointly, had engaged private counsel at their own expense---Mere fact that the petitioner was represented by a State-appointed counsel cannot, by itself, be construed as a denial of the constitutional right to a fair trial, particularly when nothing on record suggested that the counsel so appointed lacked competence or failed to safeguard his interests---Counsel appointed at State expense remained present throughout and actively participated, along with another senior counsel who also joined the trial---All prosecution witnesses were thoroughly cross-examined; no specific instance of prejudice was pointed out---Record depicted that the petitioner was afforded full opportunity to defend himself and that all procedural safeguards contemplated by law were duly observed---No violation of the right to a fair trial and due process was established. (d) Criminal Procedure Code----S. 510 [as amended by the Code of Criminal Procedure (Amendment) Act, 2022]---Report of Forensic Scientist---Admissibility without calling the maker as a witness---Procedural amendment---Retrospective operation---Pending appeal as continuation of trial---Contention that DNA and video forensic reports were inadmissible because the Forensic Scientists who prepared them were not produced as witnesses---No such objection was raised when the reports were tendered and exhibited before the Trial Court, or at the stage of final arguments, or before the Appellate Court, or before the Supreme Court at the hearing of the criminal petition---At the time of trial, S. 510, Cr.P.C., as then in force, did not expressly include a "Forensic Scientist" amongst experts whose report could be read in evidence without calling its maker---During pendency of the petitioner's appeal, S. 510 was amended through the Code of Criminal Procedure (Amendment) Act, 2022, expressly including "Forensic Scientist" within that class---Amended S. 510 neither creates a new offence nor enhances punishment, nor alters essential ingredients of an offence; it imposes no additional burden upon the prosecution and takes away no substantive right or defence of an accused---It concerns only the mode of proof, the manner of taking evidence and the procedure governing reception of expert reports, and is in substance procedural---Procedural provisions ordinarily operate retrospectively and apply to proceedings pending when they come into force, unless the legislature expressly provides otherwise or their application would impair an accrued or vested right, which was not the case---Matters relating to the remedy, mode of trial, manner of taking evidence and forms of action fall within the domain of procedural law and therefore operate retrospectively---A criminal appeal is a continuation of the trial; the Appellate Court was competent to apply the procedural law prevailing at the time of adjudication of the appeal---In the absence of any express or implied legislative intent to exclude pending proceedings, and there being no vested or substantive right of the accused adversely affected, the amendment governed the pending appeal, notwithstanding that the trial had concluded before the amendment came into force---Proviso to S. 510 empowers the Court, if it considers necessary in the interest of justice, to summon and examine the person by whom such report has been made; the petitioner submitted no application before the Trial Court or the Appellate Court for summoning the Forensic Expert, and those Courts did not consider it necessary to do so---Having failed to question admissibility of the forensic reports at the appropriate stages, the petitioner could not raise the issue for the first time in review---To entertain such an objection at that belated stage would amount to reopening an issue which had neither been raised nor canvassed when the matter was finally adjudicated, which is impermissible within the limited scope of review---Maxim vigilantibus non dormientibus jura subveniunt applied. Cited Cases: • Adnan Afzal v. Capt. Sher Afzal PLD 1969 SC 187 • Muhammad Afzal v. Karachi Electric Supply Corporation 1999 SCMR 92 • State v. Muhammad Akram 1987 PCr.LJ 1728 (e) Penal Code----S. 302(b)---Death sentence---Mitigating circumstances---Heinous and gruesome offence---Rape followed by murder of a young woman---Record, as concurrently appreciated by the Courts below and affirmed by the Supreme Court, revealed a shocking degree of brutality---Circumstances attending the occurrence, the manner in which the offence was executed, and the conduct attributed to the petitioner did not disclose any mitigating circumstance capable of diminishing his culpability or warranting a lesser sentence---Aggravating features overwhelmingly outweighed any circumstance urged in mitigation---Case did not fall within any recognized exception warranting interference with the sentence---No error apparent on the face of the record, nor any other ground warranting interference in the limited review jurisdiction---Other grounds in the review petition, in essence, sought reappraisal of matters already considered and adjudicated, which is beyond the permissible scope of review---Review petition dismissed and leave refused. Disposition: Criminal Review Petition No.89 of 2025 in Criminal Petition No.467 of 2023 dismissed and leave refused; judgment dated 20.05.2025 maintaining conviction and death sentence under S. 302(b), P.P.C., left undisturbed. (Supreme Court of Pakistan, judgment dated 4th June, 2026, by Ishtiaq Ibrahim, J.; Islamabad; Approved for Reporting.)

Summary: (a) Civil Procedure Code (V of 1908)----S. 12(2) & O. XXIII, R. 3---Compromise decree---Suit for declaration and separate possession of Shari shares by daughters against brothers and legal representatives of deceased defendants---Decree dated 15.06.2021 (drawn 16.06.2021) passed on basis of written compromise---Application under S. 12(2) allowed by Trial Court on 08.11.2022, remanded by Revisional Court on 17.04.2023, remitted by High Court on 29.05.2024, revision dismissed by Revisional Court on 20.08.2024, and finally High Court, in constitutional jurisdiction, reversed the concurrent findings by judgment dated 25.06.2025 and restored the compromise decree---Clause No.2 of the compromise deed purported to relinquish rights in "Ghair Mutadawia" (non-suit/undisputed) properties of the deceased parents, which neither formed part of the suit nor found mention in the plaint or pleadings---Held, stipulation suffered from patent uncertainty and vagueness, being devoid of particulars (description, location, boundaries, survey numbers, title documents, revenue particulars) capable of identifying the subject matter of the alleged relinquishment---Court derives jurisdiction under O. XXIII, R. 3 only in relation to the subject matter of the suit and matters lawfully brought within contemplation of the parties; it must satisfy itself that the compromise is lawful, certain and relatable to the subject matter of the suit; it cannot, under guise of recording a settlement, determine, transfer or extinguish proprietary rights in properties whose identity is unknown or incapable of ascertainment---Compromise decree cannot derive higher sanctity than the agreement on which it rests; Trial Court failed to advert to the lack of certainty in Clause No.2 and to the consequence under S. 29 of the Contract Act, 1872---Decree founded on such compromise, to the extent it purported to affect rights in unspecified and indeterminate properties, was vitiated and could not be sustained. (b) Contract Act (IX of 1872)----S. 29---Agreement void for uncertainty---Immovable property---Certainty of subject matter---Held, in matters relating to immovable property, certainty of subject matter is an indispensable precondition for creation, recognition and enforcement of rights; agreement purporting to create, extinguish, relinquish or regulate proprietary interests in immovable property must describe subject matter with reasonable certainty so as to render property capable of objective identification---Agreements whose meaning is uncertain or incapable of being made certain are void ab initio under S. 29, and uncertainty is not curable by subsequent explanations or unilateral assertions of parties---Expression "Ghair Mutadawia" in Clause No.2 suffered from patent and incurable uncertainty and agreement, to the extent it purported to deal with such unspecified and undisclosed properties, was void for uncertainty and incapable of enforcement, there being no consensus ad idem---Void agreement cannot be transmuted into valid and enforceable instrument by incorporation into a judicial decree. Cited Cases: • Barkat Ram v. Anant Ram AIR 1915 Lahore 328 (uncertainty relating to essential subject matter renders agreement incapable of enforcement) • G.H. Treitel, The Law of Contract (International Student Edition, 1995) (referred) (c) Islamic law---Inheritance rights of female heirs---Compromise, relinquishment and parda nasheen women---Constitution of Pakistan----Arts. 4, 9, 23, 24, 25 & 227---Compromise purportedly divesting daughters of inheritance rights in undisclosed, unspecified and unascertained properties---Record devoid of evidence that any close relative, independent adviser or trusted person was associated with the compromise to explain its nature, scope and consequences to petitioners, or that the attorney through whom compromise was executed disclosed and explained its contents and irreversible consequences---Held, where a transaction concerns a parda nasheen, illiterate, rustic or otherwise vulnerable woman, burden lies heavily on beneficiary to establish through cogent, convincing and unimpeachable evidence that transaction was the product of her free, conscious and informed consent, that she understood its nature and legal effect and rights relinquished, and that she had independent and disinterested advice---Doctrine for protection of parda nasheen women is a substantive safeguard and not a mere technical rule of evidence---Shares of inheritance of a deceased Muslim are prescribed by the Holy Qur'an (Surah An-Nisa, 4:7 and 4:11) and legal heirs acquire vested proprietary rights by operation of law; right of women to inherit is divinely ordained and constitutionally guaranteed---No female legal heir can be deprived of inheritance merely on basis of relinquishment deed, compromise, gift, maintenance allowance, payment of money, customary understanding or similar arrangement unless transaction satisfies strict legal requirements and is proved to have been executed voluntarily, consciously and with full understanding of its implications---Where relinquishment or compromise is executed by a female residing under influence, authority or dependence of male relatives, Court must exercise exceptional caution and instrument cannot be accorded unquestioning sanctity merely because it bears signatures or thumb impressions---State and its instrumentalities are under constitutional obligation to establish effective, accessible and proactive mechanisms whereby women are informed of and enabled to secure their inheritance rights; courts must ensure substantive rights are not sacrificed to procedural formalism. Cited Cases: • Ghulam Muhammad v. Zohran Bibi and others 2021 SCMR 19 • Phul Peer Shah v. Hafeez Fatima 2016 SCMR 1225 (d) Muslim Personal Law (Shariat) Application Act, 1937, West Pakistan Muslim Personal Law (Shariat) Application Act, 1962, Muslim Family Laws Ordinance, 1961 and international and comparative instruments---Protection of women's property and inheritance rights---Court surveyed the statutory framework in Pakistan, international instruments (UDHR, CEDAW, ICCPR, ICESCR and others) and comparative constitutional jurisprudence of India, South Africa, Bangladesh and Turkey, and referred to Radmacher v. Granatino [2010] UKSC 42 and Stack v. Dowden [2007] UKHL 17, as persuasive interpretative guidance---Held, such framework collectively affirms equal proprietary rights of women and obliges the State, including Pakistan, to ensure their effective protection through domestic legal and judicial measures; female heirs are often deprived of inheritance through fabricated documents, fraudulent statements and engineered settlements, which cannot be countenanced by a court of law. Cited Cases: • Radmacher v. Granatino [2010] UKSC 42 • Stack v. Dowden [2007] UKHL 17 (e) Evidence---Compromise deed---Unsigned pages---Authentication---Notary Public---Notaries Ordinance, 1961 (XIX of 1961), S. 8---Pages 1 and 2 of three-page compromise deed bore no signatures or thumb impressions of parties, counsel, witnesses or identifiers, though the pages bore seal and signatures of Notary Public---Held, where a document consists of multiple pages, absence of signatures on some pages creates legitimate apprehension of interpolation, substitution or manipulation, and burden lies heavily on propounder to establish through cogent and convincing evidence that all pages formed one indivisible transaction and were duly executed or acknowledged with knowledge of contents---First page being unsigned by any person was by itself devoid of evidentiary value---Notary Public is a statutory functionary and S. 8 of the Ordinance requires verification, authentication, certification or attestation of execution under signature and official seal; Notary must satisfy himself that every page is duly subscribed and no blank, unsigned or unauthenticated page forms part of the instrument---Mechanical stamping and attestation by Notary, without ensuring due execution, amounted to failure to discharge obligations of the office and rendered genuineness and reliability of the compromise highly doubtful---Court observed that such laxity is increasingly prevalent and warrants serious introspection by concerned regulatory authorities, and that page-wise authentication and certification of total number of pages is a safeguard in other jurisdictions. (f) Civil Procedure Code (V of 1908)----S. 12(2)---Fraud, misrepresentation and want of jurisdiction---Maintainability---Qanun-e-Shahadat Order (10 of 1984), Art. 114---Estoppel---Fraud is seldom susceptible of direct proof and manifests through surrounding circumstances and attendant conduct---Respondents made no prayer before executing Court for transfer of "Ghair Mutadawia" properties, maintained silence during execution proceedings which culminated in order dated 30.11.2021 recording that decree was implemented in letter and spirit and nothing further remained to be executed, and subsequently procured Mutation No.217 dated 01.07.2022 behind the back of the Court nearly eight months after closure of execution---Held, such conduct gave rise to strong inference of fraudulent concealment, attracted principle embodied in Art. 114 of Qanun-e-Shahadat Order, 1984 and disentitled respondents from asserting rights inconsistent with the executing Court's declaration---Words "decree" and "final order" in S. 12(2) cannot be construed in a pedantic or restrictive manner; order terminating execution and recording satisfaction of decree possessed attributes of a final order and matter fell within S. 12(2)---Contention that Trial Court misapplied S. 29 of Contract Act was devoid of substance as decree founded on agreement vitiated by uncertainty, fraud or misrepresentation is a decree suffering from inherent jurisdictional defect and is amenable to challenge under S. 12(2). (g) Constitution of Pakistan----Art. 199---Constitutional jurisdiction of High Court---Interference with concurrent findings of Trial and Revisional Courts---Held, High Court's jurisdiction is supervisory in nature and is not intended to function as a court of appeal for reappraisal of evidence or substitution of factual findings, particularly where based on lawful exercise of discretion and supported by record---High Court proceeded on premise that compromise was an admitted fact and that petitioners had not specifically denied its terms or the attorney's authority, thereby failing to apply heightened scrutiny required in cases of alleged relinquishment or compromise of women's inheritance rights---Orders of Trial Court, being discretionary and founded on proper appreciation of material, were not amenable to interference in writ jurisdiction in absence of jurisdictional defect, perversity or misreading of evidence; Revisional Court had rightly affirmed them---High Court erroneously substituted its own view without demonstrating any illegality or material irregularity in concurrent findings; impugned judgment not sustainable in law. (h) Directions for safeguards in matters affecting inheritance rights of women---All courts, revenue authorities and other forums, while examining any compromise, relinquishment, family arrangement, settlement, gift, mutation, consent statement or other instrument affecting inheritance rights of women, directed to apply heightened judicial scrutiny treating such matters as involving vulnerable class protection; no presumption of validity to arise merely from execution, attestation, registration, mutation or appearance of consent unless supported by strict proof of voluntariness and informed understanding; burden to remain heavily on beneficiary; courts to ensure proof of executant's clear knowledge of transaction and exact rights affected, access to independent, competent and disinterested advice, absence of coercion, fraud, misrepresentation, undue influence or familial or social domination, strict proof of lawful, real, adequate consideration actually received where alleged, that contents were read over, explained and translated in language understood, reasonable opportunity for reflection and consultation, and satisfactory explanation of suspicious circumstances failing which adverse inference follows; prima facie unconscionable, one-sided or disproportionately prejudicial transactions to be strictly disapproved unless fully justified; courts to record affirmative finding of voluntariness and informed consent before upholding any deprivation of inheritance rights; revenue authorities to exercise similar caution at stage of mutation---Failure to establish the requirements deprives beneficiary of presumption of validity ordinarily attached to formally executed instruments. Disposition: Petition converted into appeal and allowed; impugned judgment dated 25.06.2025 of the High Court of Balochistan, Quetta in Constitutional Petition No.1263 of 2024 set aside as not sustainable in law; suit revived and parties at liberty to file amended plaint, if so advised, incorporating all other properties belonging to both propositi so that the entire controversy may be finally adjudicated in accordance with law; directions in para. 52 (safeguards in matters affecting women's inheritance rights) issued to all courts, revenue authorities and other forums. C.P.L.A.143-Q of 2025, judgment dated 04.06.2026 (Amin-ud-Din Khan, CJ.). Approved for Reporting.