Summary: (Appeal against conviction) (a) Criminal Procedure Code, 1898….S.302 PPC—re-appraisal of evidence— According to prosecution story, the occurrence was reported by the deceased then injured and the incident was witnessed by Muhammad Abid PW-9, while the appellant was singularly charged for effective firing at the deceased and ineffective firing at PW-9. There was contradiction between the complainant and PW-9 qua deboarding from the motorcycle at the time of occurrence. PW-9 did not mention the time of their departure to village Parova, nor he mentioned the purpose of their visit to said village. According to PW-9, his clothes were besmeared with blood of the injured at the time of shifting to the hospital, however, he had not produced the same to the local police. In view of glaring infirmities, the ocular account furnished by PW-9 was disbelieved. (b) Criminal Procedure Code, 1898…S.302 PPC—re-appraisal of evidence—Shifting of the deceased then injured from the place of occurrence to the hospital was not established. (c) Criminal Procedure Code, 1898…S.302 PPC—re-appraisal of evidence— As per prosecution version, the occurrence allegedly took place at 4:00 p.m, whereas the matter was reported at about 4:35 p.m, meaning thereby that the injured was examined 15 minutes before lodging the report. (d) Criminal Procedure Code, 1898.…S.302 PPC—re-appraisal of evidence—The supplementary statement of the deceased then injured was recorded on 27.11.2022 i.e. on the following day of the occurrence. The only inference which could be drawn there from that he was in senses and capable to talk, then why his statement was not recorded on 26.11.2022 and even no fitness certificate was obtained from the concerned Medical Officer. (e) Criminal Procedure Code, 1898. .…S.302 PPC—re-appraisal of evidence—The number of the motorcycle allegedly used by the complainant party was not known and even the same was neither taken into possession in support of the prosecution story. (f) Criminal Procedure Code, 1898. .…S.302 PPC—re-appraisal of evidence—Once the ocular account was disbelieved, the same being corroboratory in nature, would not be sufficient for recording conviction on a capital charge. (g) Criminal Procedure Code, 1898. .…S.302 PPC—re-appraisal of evidence—Motive was not established through independent evidence. The motive once alleged and not proved, it is for the prosecution to suffer. (Appeal was allowed, conviction awarded to the appellant was set aside and the appellant was acquitted in the circumstances).

Summary: In the case of Muhammad Shakeel and others v. Federation of Pakistan and others, the High Court dismissed a petition filed by employees of the National Bank of Pakistan (NBP) who challenged the legality of a clause in the bank`s promotion policy. The petitioners specifically contested Paragraph 4.4, which mandated an aptitude test for promotions to grades OG-III and above, arguing it was illegal, ultra vires, and discriminatory. The court first overruled the bank`s preliminary objection on the petition`s maintainability, affirming that the NBP is governed by the statutory Service Rules of 1973, making its actions subject to judicial review under Article 199 of the Constitution. On the merits, the court held that formulating promotion criteria is a core policy matter within the Management`s exclusive domain, empowered by the National Bank of Pakistan Ordinance, 1949, and its subsequent bye-laws. The court found that introducing the uniform aptitude test for a specific cadre of officers was a valid exercise of this power aimed at ensuring meritocracy and transparency, and the petitioners failed to demonstrate it was arbitrary or violated their rights. Furthermore, the court rejected the discrimination claim under Article 25, ruling that officers (OG-III and above) and clerical staff constitute distinct classes with different responsibilities, and the differential treatment was based on a reasonable and intelligible classification. Consequently, finding no merit in the petition, the court dismissed it, upholding the validity of Clause 4.4 of the promotion policy.

Summary: (Writ Petition under Article 199 of the Constitution of Pakistan) 1. Petitioner, Associate Professor(B-20) of Gomal University, removed from service by the University Syndicate vide its decision in 98th meeting held on 23 rd & 24th April 2019. His appeal to the Chancellor was allowed and he was reinstated into service, however, minor penalty was awarded to him. Petitioner then preferred the constitutional petition to set aside the minor penalty. --- Held --- According to Khybe Pakhtunkhwa Universities Act, 2012, only the Syndicate is having powers to initiate inquiry proceedings and issue show cause notice to the petitioner being an employee in BPS-20, whereas, the said proceedings were conducted by the Vice Chancellor under the powers delegated to him by the Syndicate through its 96th meeting. However, such delegation of powers by the Syndicate to the Vice Chancellor had been declared illegally by this Court vide Judgment dated 22.03.2021 in Writ Petition No.564-D/2018, as result thereof, all the departmental proceedings conducted against petitioner had become void ab-initio. The Chancellor, while reinstating the petitioner, has noted this fact in the impugned order but erred in passing the minor penalty. 2. When the basic order is without lawful authority and void ab initio, then the entire superstructure raised thereon falls to the ground automatically. PLD 2008 Supreme Court 663, PLD 2022 Supreme Court 574 and 2021 SCMR 637 relied. (The constitutional petition filed by petitioner was allowed and minor penalty imposed by the Chancellor was set aside.)

Summary: (a) Constitution of Pakistan – Art. 190 & Constitutional Duty of Compliance Failure of executive authorities to act upon binding remand orders of the High Court—Scope and implications—Held, a remand order by a superior court is not optional or subject to indefinite administrative suspension—Such orders must be complied with promptly and faithfully—Failure to do so violates the constitutional duty imposed by Art. 190, which mandates all executive and judicial authorities to act in aid of the decisions of the Supreme Court and other superior courts—Unjustified administrative inaction in the face of a valid remand order amounts to systemic non-compliance with judicial authority and undermines the rule of law. (b) Supreme Court Rules, 1980 – O. XX, R.1 – Effect of Pendency of Appeal/Petition Pendency of an appeal, revision, or constitutional petition—Effect on execution of impugned order—Held, mere pendency of proceedings before any court, including the Supreme Court, does not operate as a stay unless an express injunctive order is issued—Reference made to Supreme Court Rules, 1980, O.XX, R.1 and reaffirmed in Rashid Baig v. Muhammad Mansha (2024 SCMR 1385)—Administrative refusal to act on judicial orders citing pendency alone is impermissible and without lawful justification. (c) Administrative Law – Duty of Revenue Authorities to Comply with Judicial Remand Conduct of revenue authorities following remand by High Court—Delay of over a decade in implementation—Held, administrative inertia and disregard of clear judicial instructions constitute a disturbing pattern of non-compliance—Such conduct, especially in absence of any lawful restraint, amounts to a systemic failure in public administration—Court observed with concern that such dereliction continues despite clear judicial pronouncements against it. (d) Public Administration – Institutional Reform and Policy Measures Remedial action—Senior Member, Board of Revenue, Punjab appeared in Court and undertook to issue province-wide policy guidelines directing prompt implementation of remand orders, subject only to valid injunctive orders—Further assured the Court of regular monitoring and submission of compliance status for all pending remanded cases—Court directed finalization and circulation of such policy and required a compliance report with an updated status of all pending remanded matters to be submitted to the Registrar within three months—Held, such institutional reform is essential to uphold lawful governance and the administration of justice. (e) Civil Procedure – Disposition of Infructuous Petitions Remanded matter ultimately decided during pendency of petitions—Order dated 05.11.2024 passed by Deputy Commissioner/District Collector, Bahawalpur placed on record—Held, petitions rendered infructuous—Disposed of accordingly, with binding directions to ensure future compliance in similar cases. Cited Case: • Rashid Baig v. Muhammad Mansha 2024 SCMR 1385 Disposition: Petitions disposed of as infructuous with mandatory direction to issue and enforce policy guidelines for implementation of judicial remand orders and submit compliance report within three months.

Summary: (a) Constitution of Pakistan––Art. 199 & Art. 212; Law Reforms Ordinance, 1972, S. 3(2)––Service matters––Termination of probationer under R.12.21, Police Rules, 1934––Maintainability of constitutional petition and intra-court appeal––Bar under Art. 212 of the Constitution and S. 3(2) of the Ordinance. Respondent, initially rejected for the post of Constable due to impersonation and facing criminal proceedings, was later appointed as Traffic Assistant from the waiting list pursuant to High Court’s earlier direction. Appointment was subsequently rescinded under R.12.21 of the Police Rules, 1934 for alleged concealment of pending FIR––Respondent filed constitutional petition under Art.199, which was allowed by learned Single Judge––Intra-Court Appeal filed by the Police Department held not maintainable in light of bar under S.3(2) of the Law Reforms Ordinance, 1972, as constitutional petition arose from an order against which a statutory remedy under S.4 of the Punjab Service Tribunals Act, 1974 was available––Held, constitutional petition itself was not maintainable due to the bar under Art.212 of the Constitution, and since proceedings were procedurally flawed, intra-court appeal was also not maintainable. Disposition: Intra-Court Appeal dismissed. (b) Punjab Service Tribunals Act, 1974, S. 4 & S. 2(b)––Civil servant––Probationer––Right of appeal before Punjab Service Tribunal––Scope––Distinction between departmental and judicial remedies. Respondent was a probationer under Rule 12.21 when services were rescinded––Court held that a probationer is a civil servant within the meaning of S.2(b) of the Act and is entitled to file an appeal before the Punjab Service Tribunal––While Rule 12.21 bars departmental appeal against discharge for inefficiency, this does not preclude the statutory right of judicial appeal under S.4 of the Act––Such appeal lies against final orders of departmental authorities even in the absence of internal departmental remedies––Rule 12.21 cannot override a statutory and constitutional judicial remedy––Tribunal’s jurisdiction, deriving from Art.212, remains unaffected by the internal rules of the department. Cited Statutes: • Police Rules, 1934, R.12.21 • Punjab Service Tribunals Act, 1974, S.4 • Law Reforms Ordinance, 1972, S.3(2) • Constitution of Pakistan, 1973, Arts. 199, 212 (c) Service law––Misconduct v. fitness––Scope of judicial review––Whether termination of probationer due to concealment of criminal case pertains to fitness or misconduct. Rescission of appointment under R.12.21 of Police Rules was not a neutral determination of fitness, but based on allegations of deceit and concealment of pending criminal case––Court held such rescission constitutes misconduct, not mere unsuitability––Hence, S.4(b) of the Punjab Service Tribunals Act, 1974 (barring appeals on fitness assessments) does not apply––Misconduct falls within the terms and conditions of service and is appealable before the Tribunal. (d) Judicial forums––Distinction between departmental authority and service tribunal––Scope and nature of jurisdiction. Court elaborated the distinction between administrative (departmental) remedies and judicial remedies under special law––Rule 12.21's bar on departmental appeals pertains to internal administrative hierarchy and cannot be construed to exclude judicial review under a statutory appellate forum such as the Punjab Service Tribunal––Tribunal functions as a judicial body created under Art.212 of the Constitution and cannot be ousted by executive rules or departmental notifications. Disposition: Intra-Court Appeal dismissed as not maintainable in view of statutory bar; remedy before Punjab Service Tribunal advised.

Summary: (a) Penal Code (XLV of 1860) ---- S. 302(b); Criminal Procedure Code (V of 1898) ---- Ss. 374 & 544-A Appreciation of evidence --- Conviction based on unreliable ocular account and inconclusive corroborative evidence --- FIR allegedly promptly lodged but record showed a significant unexplained delay in recording the complainant’s statement by the investigating officer --- Time gap used to introduce planted witnesses and fabricate roles of accused --- Eyewitnesses gave contradictory statements and failed to justify their presence at the scene --- Complainant and other eyewitness did not identify the dead body, which undermined their claimed presence at the scene --- Held, that case was of an unseen occurrence and eyewitnesses were introduced after deliberation to falsely implicate the accused --- Prosecution failed to establish guilt beyond reasonable doubt --- Conviction and death sentence of appellant set aside; benefit of doubt extended to accused --- Murder Reference answered in negative; sentence of death not confirmed. Cited Cases: • Ghulam Abbas v. The State 2021 SCMR 23 • Iftikhar Hussain alias Kharoo v. The State 2024 SCMR 1449 • Ayub Masih v. The State PLD 2002 SC 1048 (b) Qanun-e-Shahadat Order (X of 1984) ---- Art. 27 Admissibility of first version of accused --- Statement of accused recorded at the time of arrest wherein he denied role in the crime and blamed another person --- Statement held admissible under Article 27 and sufficient to raise reasonable doubt --- Defence also produced the alleged real offender as a witness, who admitted committing the offence --- Held, such version, though not determinative on its own, creates sufficient doubt to undermine the prosecution's case --- Benefit of doubt rightly extended. Cited Case: • Najaf Ali Shah v. The State 2021 SCMR 736 • Qaisarullah v. The State 2009 SCMR 579 (c) Penal Code (XLV of 1860) ---- S. 302(b) Motive --- Prosecution alleged motive based on prior enmity involving co-accused --- Appellant shown to have no prior hostility or involvement in earlier incident --- Investigating Officer and complainant admitted no enmity or previous litigation existed between appellant and deceased --- Held, motive not attributable to appellant, weakening prosecution case --- Motive ascribed to another (acquitted) co-accused cannot be extended to implicate appellant. Cited Case: • Muhammad Ashraf alias Acchu v. The State 2019 SCMR 652 (d) Evidence Act (I of 1872) ---- S. 27; Criminal Procedure Code (V of 1898) ---- S. 103 Recovery of weapon --- Recovery of pistol allegedly at appellant’s instance --- Weapon sent with delay to forensic lab --- Parcels not shown to contain live bullets; mismatch between police memos and PFSA report --- Inquest report did not record presence of any spent shells at crime scene --- Held, forensic evidence not trustworthy due to lack of secure chain of custody and clear procedural irregularities --- Recovery inconsequential and unreliable for conviction. Cited Cases: • Muhammad Saleem v. Shabbir Ahmed 2016 SCMR 1605 • Kamal Din alias Kamala v. The State 2018 SCMR 577 • Mansab Ali v. The State 2024 PCrLJ 617 (e) Criminal Procedure Code (V of 1898) ---- S. 417(2-A) Appeal against acquittal --- Co-accused acquitted on ground of alibi and being uninvolved per police investigation --- Hospital records and verification supported alibi plea --- Courts slow to interfere with well-reasoned acquittals unless perverse or arbitrary --- Held, acquittal based on cogent reasons and credible documentary evidence --- No extraordinary circumstances warranting reversal of acquittal --- Appeal against acquittal dismissed. Cited Cases: • Mst. Anwar Begum v. Akhtar Hussain alias Kaka 2017 SCMR 1710 • Raja Khurram Ali Khan v. Tayyaba Bibi PLD 2020 SC 146 • Nazir v. The State NLR 2002 Cr. 265 • Ashiq Ali v. The State NLR 1996 Cr. 544

Summary: Acquittal granted --- (a) Control of Narcotic Substances Act, 1997 — S. 9(c) — Safe custody and transmission of sample — Mandatory requirement — Benefit of doubt Where the entire prosecution case rested on the recovery of Charas and its forensic analysis, the failure to prove the safe and secure custody and timely transmission of the sealed sample to the Punjab Forensic Science Agency (PFSA) rendered the case unreliable. The record revealed no entries in the daily Police Register (Roznamcha Register No. II) regarding the movement of the police official tasked with delivering the sample. Furthermore, an unexplained delay of 25 days in transmitting the sample undermined the integrity of the prosecution’s version, violating Rule 4 of the CNS (Government Analysts) Rules, 2001. Relied on: Mst. Sakina Ramzan v. The State (2021 SCMR 451) Ahmed Ali and another v. The State (2023 SCMR 781) Mst. Sabiran Bibi v. The State (Crl. P.L.A. No. 379/2025, decided on 30.05.2025) Muhammad Mansha v. The State (2018 SCMR 772) (b) Criminal trial — Standard of proof — Break in chain of custody — Effect The prosecution must establish an unbroken, secure chain of custody for seized narcotics to render the chemical examiner's report credible. Any gap or unexplained delay raises the presumption of possible tampering, contamination, or substitution, which directly impacts the validity of conviction under narcotic laws. In the present case, due to missing links in the chain and admitted discrepancies, the forensic report was deemed unreliable and incapable of sustaining conviction. Followed: Ikramullah and others v. The State (2015 SCMR 1002) Akhtar Iqbal v. The State (2015 SCMR 291) Muhammad Hussain v. The State (2008 SCMR 345) (c) Criminal Procedure Code, 1898 — S. 342 — Statement of accused — Right to remain silent — Prosecution’s burden not discharged The accused’s right to remain silent or refrain from producing defence evidence does not relieve the prosecution from its burden of proof. Mere denial by the accused or absence of independent defence evidence cannot salvage a weak prosecution case, especially where core procedural requirements are disregarded. (d) Benefit of doubt — Principles Even a single doubt in the prosecution’s case, if reasonable and based on record, must be extended to the accused as a matter of right and not as a concession. Where multiple irregularities and contradictions exist—especially regarding vital procedures such as sample custody—the accused cannot be convicted safely. Cited: Tariq Pervez v. The State (1995 SCMR 1345) Muhammad Akram v. The State (2009 SCMR 230) Muhammad Zaman v. The State (2014 SCMR 749) Disposition: Appeal allowed. Conviction and sentence set aside. Appellant acquitted by extending benefit of doubt.

Summary: (a) Land Revenue Act, 1967 --- S. 36 & West Pakistan Land Revenue Rules, 1968 --- Rr. 17, 18, 19 & 22 --- Appointment of Lambardar --- Scope and discretion of Collector --- Consideration of suitability and disqualifications The office of Lambardar is not a hereditary entitlement but an administrative post to link the villagers with revenue authorities. Under Rule 17 read with Section 36 of the West Pakistan Land Revenue Act, 1967, the Collector is empowered to select the most suitable candidate considering factors such as character, education, personal influence, and freedom from indebtedness. In this case, although the petitioner secured higher marks (75) than the selected respondent (65), the Collector found him unfit due to his involvement in multiple criminal cases, limited landholding, and illegal possession of state land. The selection of respondent No.7 as the more suitable candidate was upheld as legal and reasonable. (b) West Pakistan Land Revenue Rules, 1968 --- R. 19(2)(d) --- Female eligibility for Lambardari --- Constitution of Pakistan, 1973 --- Art. 25(2) --- Gender-based disqualification --- Constitutionality and judicial interpretation Rule 19(2)(d) of the Rules, which discourages female candidates from being appointed as Lambardar except under “special reasons,” has been held to be violative of Article 25(2) of the Constitution, which prohibits discrimination solely on the basis of sex. The High Court reaffirmed that a female cannot be excluded from consideration for Lambardari merely due to gender and cited binding precedent from PLD 1982 SC 271 and PLD 1990 SC 295, declaring gender-based restrictions unconstitutional and void. (c) Revenue proceedings --- Judicial review in writ jurisdiction --- Interference with Collector’s choice --- Scope The appointment of a Lambardar, if made after due consideration by the revenue hierarchy and in accordance with legal criteria, cannot be interfered with in Constitutional jurisdiction unless shown to be perverse, arbitrary, or illegal. The High Court is not to act as an appellate forum in such matters. In this case, the orders of the Collector and appellate authorities were found to be reasoned and based on relevant factors; thus, no interference was warranted. (d) Land grant under Lambardari Scheme --- Ban and withdrawal --- Effect of policy letter lifting ban --- Allotment of state land to permanent Lambardar --- Validity Initially, a ban on allotment of state land under the Lambardari scheme was imposed through a Board of Revenue letter dated 22.06.2018. However, this was lawfully withdrawn by Notification No.144-2020/54-C.V. dated 18.02.2020, restoring the right to receive Lambardari grants upon appointment. The subsequent allotment of 105 kanals 10 marlas of land to respondent No.7 as a permanent Lambardar was held lawful and in line with the revised policy. Disposition: Writ petition dismissed. The appointment of respondent No.7 as permanent Lambardar and the grant of state land were upheld as lawful, constitutional, and based on sound administrative discretion.

Summary: (a) Income Tax Ordinance, 2001 ---- Ss. 2(13AB), 2(22A), 113, 122(1), 122(5A), 177 & Division IX, Part IV of First Schedule --- Fast Moving Consumer Goods (FMCG) --- Definition --- Scope --- Eligibility for reduced minimum tax rate --- Goods not directly consumable by end consumers --- Taxpayer’s eligibility for 0.2% minimum tax under FMCG category denied. The Supreme Court examined whether BOPP composite/plain films, PET films, CPP metalized films, and CPP milky films qualified as “Fast Moving Consumer Goods” under clauses (13AB) and (22A) of section 2 of the Income Tax Ordinance, 2001. The taxpayer, a sole distributor of such films, claimed entitlement to the reduced 0.2% minimum tax rate under Division IX, Part IV of the First Schedule. The Court held that such films, being packaging materials used by manufacturers and not directly purchased by end consumers, did not qualify as FMCG. The judgment clarified that “consumer goods” must be for direct consumption by end users, not intermediate goods used in production. Further, post-Finance Act, 2017, durable goods were explicitly excluded from the FMCG definition. As the films in question were durable and meant for industrial use, they fell outside the ambit of clauses (13AB) and (22A). (b) Appellate jurisdiction --- Misapplication of law by lower fora --- Scope of interference by Supreme Court. The Court held that both the Appellate Tribunal Inland Revenue and the Peshawar High Court erred in treating industrial packaging films as FMCGs without a proper legal evaluation of statutory definitions. The reliance by the Tribunal on a prior judgment defining FMCGs based on criteria like frequent purchase, high turnover, and sales network was found to be misplaced. The Court observed that statutory definitions must prevail, and an incorrect application of legal definitions warranted interference in appellate jurisdiction. Disposition: Petitions converted into appeals and allowed; judgment of the Peshawar High Court dated 22.11.2023 was set aside; taxpayer held not entitled to the reduced minimum tax rate applicable to FMCGs under the Ordinance.

Summary: (a) Islamic law --- Gift (Hiba) --- Essentials --- Offer, acceptance, and delivery of possession --- Proof --- Failure to prove valid oral gift --- Effect. Petitioners, legal heirs of deceased Imdad Ali, claimed title to inherited property through alleged oral and registered gift deeds. Supreme Court reaffirmed that a valid gift requires: (i) offer by the donor, (ii) acceptance by the donee, and (iii) delivery of possession. Petitioners failed to plead or prove these elements. Neither the date, time, nor place of the alleged oral gift was provided, nor were any attesting witnesses of the gift transaction produced. No cogent or confidence-inspiring evidence was led to establish offer and acceptance. The petitioners also failed to produce key evidence such as the scribe, marginal witnesses, stamp vendor, sub-registrar, or Patwari to prove the execution and attestation of the registered gift deeds. Consequently, the gift was held to be invalid, and the petitioners' claim was rejected. Cited Cases: • Bilal Hussain Shah v. Dilawar Shah PLD 2018 SC 698 • Khalid Hussain v. Nazir Ahmad 2021 SCMR 1986 • Faqir Ali v. Sakina Bibi PLD 2022 SC 85 • Mst. Ramzanu Bibi v. Ibrahim 2025 SCMR 955 • Barkat Ali v. Muhammad Ismail 2002 SCMR 1938 (b) Law of evidence --- Qanun-e-Shahadat Order, 1984 --- Arts. 129(g) & 133 --- Best evidence rule --- Withholding material witnesses --- Adverse inference --- Application. Petitioners failed to produce essential witnesses, including the scribe, attesting witnesses, and relevant revenue officials, raising an adverse presumption under Art. 129(g) of the Qanun-e-Shahadat Order, 1984. Court held that in cases where a party fails to present the best available evidence, the court is justified in drawing a presumption against that party. Oral claims of gift unsupported by credible documentary or witness testimony were held insufficient. (c) Succession --- Inheritance --- Gift by ancestor to exclusion of daughters --- Burden of proof --- Reason for exclusion must be shown --- Presumption against disinheritance. The Court noted that no reason was given by the petitioners for the exclusion of daughters from the inheritance. In cases involving alleged gifts by a deceased ancestor in favour of male heirs to the exclusion of female heirs, courts must scrutinize the claim with greater care. Absence of evidence showing affection or reward-based motivation for the gift raised strong suspicion. Petitioners bore the heavy burden to justify exclusion, which they failed to discharge. (d) Pleadings and evidence --- Relief beyond pleadings --- Impermissibility --- Case to be proved within bounds of pleadings. Supreme Court reiterated that no party may lead evidence beyond its pleadings. Petitioners did not clearly plead the particulars of the alleged oral gift in their written statements and thus were barred from leading evidence in that regard. Courts below correctly refused to entertain unpleaded facts. Cited Cases: • Zulfiqar v. Shahdat Khan PLD 2007 SC 582 • Combined Investment Ltd. v. Wali Bhai PLD 2016 SC 730 • Saddaruddin v. Sultan Khan 2021 SCMR 642 (e) Limitation Act, 1908 --- Art. 120 --- Declaratory suits --- Right to sue --- When accrues --- Continuing right in suits based on inheritance. Court held that in inheritance-based declaratory suits, the right to sue is a continuing right so long as the plaintiff retains a claim over the property. Where fraud or concealment is alleged, limitation begins from the date of knowledge. Respondents in this case only discovered the fraudulent gift when attempting to obtain a revenue extract in 2009. All three courts below rightly held the suit within time under Art. 120 of the Limitation Act. Cited Case: • Mst. Ramzanu Bibi v. Ibrahim 2025 SCMR 955 (f) Civil procedure --- Concurrent findings of fact --- Scope of interference by Supreme Court --- Principles. The Supreme Court declined to interfere in concurrent findings of three courts below, holding that the judgments were based on proper appraisal of evidence and application of settled legal principles. The petitioners had failed to dislodge those findings through any legal or factual error warranting interference under Article 185(3) of the Constitution. Disposition: Leave refused. Petition dismissed. Judgments of trial court, appellate court, and High Court upheld concurrently.