Summary: (a) Constitution of Pakistan – Art. 212 – Jurisdiction of Service Tribunal – Obligation to Adjudicate Service Matters on Factual and Legal Grounds Failure to adjudicate relevant facts—Scope—Held, Service Tribunal is the primary fact-finding forum for adjudication of service matters and is duty-bound to consider material on record and claims of similarly placed employees—Petitioners asserted inclusion in a previously scrutinized and judicially acknowledged group of 166 appointees whose appointments had been regularized—Tribunal dismissed appeals without addressing whether petitioners fell within that protected category—Supreme Court held this omission constituted failure to discharge judicial function—Tribunal must evaluate records and recruitment process fairly and not disregard relevant reports and past judicial findings while dismissing service appeals. (b) Civil Servants – Appointment and Termination – Validity of Recruitment Process and Scope of Judicial Review Recruitment against 289 advertised posts—Petitioners alleged lawful appointments through merit-based selection in 2011—Service books prepared but salaries withheld and appointments subsequently terminated without establishing personal fault—Scrutiny committee’s 2016 report acknowledged that fault lay with the Director (Colleges), not the appointees—Held, blanket termination without verifying individual credentials and documentary compliance amounts to arbitrary exercise of power—Right to fair adjudication includes opportunity to produce evidence and have claims assessed on merit—Court directed formation of scrutiny committee to verify petitioners’ inclusion in protected group and compliance with codal formalities. (c) Administrative Law – Executive Oversight and Committee-Based Review – Validity and Binding Nature Constitution of verification committee—Held, where large-scale terminations arise from administrative irregularities not attributable to individual employees, a fact-based assessment is essential to distinguish bona fide appointees—Supreme Court directed formation of a high-level three-member committee to scrutinize individual claims of petitioners—Committee to assess inclusion in prior approved list of 166 employees, verify documents, and restore service accordingly—Exercise to be completed within two months independently and without being influenced by impugned judgment of Tribunal. (d) Principles of Natural Justice – Right to be Heard – Due Process in Service Terminations Lack of meaningful hearing prior to removal—Held, issuance of show cause notices followed by perfunctory hearings without individualized assessment violates the right to due process—Where petitioners’ service credentials were previously accepted and appointments documented, department was required to prove specific irregularity in each case—Blanket removal, particularly after Tribunal’s directions for scrutiny, is unsustainable in law—Judicial review warranted to ensure compliance with principles of fairness and non-discrimination. (e) Precedent and Consistency – Judicial Endorsement of Similarly Placed Employees Previous judgments and departmental reports—Effect—Held, earlier Service Tribunal judgments dated 29.05.2018 and 11.05.2015, and Supreme Court orders dated 24.01.2019 and 08.04.2021 upheld appointments of similarly situated employees based on departmental scrutiny—Petitioners were entitled to parity of treatment if found within same factual matrix—Tribunal failed to consider binding precedents and prior factual findings—Reassessment directed to ensure consistent application of law. Disposition: Civil Petitions converted into appeals and disposed of with directions to constitute a verification committee within ten days. Committee to complete scrutiny within two months and reinstate petitioners found covered under previously approved category of 166 employees, subject to document verification.

Summary: (a) Evacuee Trust Property (Management & Disposal) Act, 1975 — Ss. 14, 17, 21 & 23 — Constitution of Pakistan, Art. 10-A — Cancellation of lease — Registered 99-year lease — Fraud allegation — Fair trial — Jurisdictional error Lease cancelled without due process — Authority acted without evidence or proper hearing — Jurisdictional overreach — Violation of fair trial rights — Petitioners acquired evacuee trust property through public auction in 1974; lease registered for 99 years in 1992 — ETPB issued notice dated 17.09.2020 alleging fraud and forgery in lease approval — Petitioners challenged cancellation in High Court, which dismissed petition on ground of alternate remedy under S.17 of ETP Act — Supreme Court held that cancellation order dated 14.09.2020 passed by Chairman ETPB was issued without affording proper opportunity of hearing, no evidence was recorded, and adjournment requests due to medical reasons were arbitrarily denied — Court ruled that such serious matters must not be decided summarily without trial — Chairman ETPB did not exercise appellate or revisional jurisdiction under Ss.16 & 17, and acted under Clause 23 of the 1977 Scheme — Nevertheless, power under Clause 23 requires “reasonable opportunity of being heard” — Held, violation of natural justice and Art.10-A occurred. Cited Cases: Junaid Wazir v. SP (2024 SCMR 181) Federation v. Zahid Malik (2023 SCMR 603) Usman Ghani v. GPO Karachi (2022 SCMR 745) Muhammad Yaseen v. Province of Sindh (2024 PLC(CS) 111) Govt. of Balochistan v. Ghulam Rasool (2024 SCMR 1155) (b) Evacuee Trust Property Act, 1975 — Ss. 14, 21 — Exclusion of civil court jurisdiction — Scope and limitations — Special jurisdiction under statute Bar on civil court jurisdiction does not imply unbridled powers — Procedural safeguards and due process mandatory — Court reiterated that exclusion of civil court jurisdiction under S.14 imposes greater responsibility on statutory forums to act judicially — Power under S.21 confers civil court-like powers to ETPB officials for conducting enquiries, recording evidence, and deciding disputes — Any deviation from procedural fairness undermines justice — In the instant case, Chairman ETPB failed to fix date for decision, kept order in limbo, and denied proper hearing, thus violating settled principles of quasi-judicial decision-making. (c) Contract Act, 1872 — Ss. 13, 14 — Lease — Void agreement — Consent and fraud Lease cannot be cancelled for fraud without affording full opportunity to rebut — Allegation of forged approval must be judicially established — Petitioners claimed valid lease under due process; ETPB alleged fake approval for 99-year term — Court held that cancellation of lease requires strict proof of fraud, proper enquiry, and fair opportunity — Summary decision based solely on document verification, without confrontation or trial, was invalid — Chairman ETPB exceeded lawful authority. Final Disposition: Petition converted into appeal and allowed. Impugned High Court judgment dated 08.12.2022, cancellation order dated 14.09.2020, and notice dated 17.09.2020 set aside. Matter remanded to Chairman ETPB for fresh decision after full hearing within 3 months.

Summary: (a) Constitution of Pakistan—Art. 188—Review jurisdiction of Supreme Court—Error apparent on face of record—Per incuriam judgment—Principles—Scope—Supreme Court allowed review petition where statutory service rules providing right of appeal were not considered either by the High Court or by the Supreme Court in earlier proceedings—Such omission constituted an error apparent on the face of record resulting in miscarriage of justice—Judgment dated 16.03.2020 passed in Civil Appeal No. 353 of 2010, and judgment of Peshawar High Court dated 06.03.2009, were set aside to the extent of petitioner and matter remanded to Chief Justice of Peshawar High Court for re-decision of petitioner’s appeal by a Bench to be nominated. The Court reaffirmed that a reviewable error includes failure to consider applicable statutory provisions which have a material bearing on the outcome—In the present case, Rule 12 of the Peshawar High Court Ministerial Establishment (Appointment and Conditions of Service) Rules, 1989, read with Rule 3 of the Khyber Pakhtunkhwa Civil Servants (Appeal) Rules, 1986, conferred a right of appeal to a civil servant aggrieved by an order of removal, even when passed by the Chief Justice—Said Rules, though repealed by the 2020 Rules, were applicable at the time of removal and their repeal did not affect accrued rights—Failure of both the Peshawar High Court and Supreme Court to consider these rules constituted a legal error justifying review. Cited Cases: Government of Punjab v. Aamir Zahoor ul Haq (PLD 2016 SC 421) Nadia Naz v. The President of Islamic Republic of Pakistan (PLD 2023 SC 588) (b) Service matters—Departmental appeal—Right of appeal against order passed by Chief Justice of High Court—Applicability of statutory rules—Peshawar High Court Ministerial Establishment Rules, 1989, read with Civil Servants (Appeal) Rules, 1986—Scope—Where removal order is passed by Chief Justice, appellate authority is Bench of two judges nominated by Chief Justice—Such right of appeal held to be available to the petitioner—Subsequent repeal by 2020 Rules does not extinguish rights already accrued under repealed rules—Supreme Court directed Chief Justice, Peshawar High Court to place matter before appropriate Bench for decision afresh. The Court interpreted the Rules of 1989 in conjunction with the 1986 Rules and Appendix to the High Court of West Pakistan (Civil Services) Delegation of Powers Rules, 1960, to conclude that petitioner had a statutory right of appeal—Despite Rule 22 of the 2020 Rules repealing the 1989 Rules, the repeal could not retrospectively extinguish rights already accrued—Proper forum for appeal in cases of removal by Chief Justice is a Bench of judges nominated by him. (c) Constitution of Pakistan—Art. 208—Power of High Court to make rules for its establishment—Effect—Rules framed under Art. 208 and approved by provincial Governor are binding in administrative and disciplinary matters of court employees—Failure to adhere to such rules while deciding constitutional petition and civil appeal constitutes miscarriage of justice—Petitioner’s removal from service without availing appeal process under said rules held unlawful—Matter remanded. (d) Limitation—Delay of one day in filing review petition—Condonation—Supreme Court condoned delay on account of genuine grounds supported by affidavit—Petition not dismissed on technical ground where merits justified consideration—Petition allowed. Disposition: Review petition allowed; judgments of Supreme Court dated 16.03.2020 and Peshawar High Court dated 06.03.2009 set aside to petitioner’s extent; matter remanded to Chief Justice, Peshawar High Court for placing appeal before nominated Bench for decision in accordance with law; delay in filing review petition condoned.

Summary: Acquittal --- (a) Penal Code (XLV of 1860), S. 376(1) — Constitution of Pakistan, Art. 10-A Rape — Allegation of incestuous sexual assault by father — Standard of proof — Reliability of child witness — Right to fair trial — Prosecution case was that the accused, father of the victim, committed rape upon his minor daughter, aged 6/7 years — FIR lodged by the mother after victim disclosed incident to her maternal uncle and mother — Held, case rested primarily on statement of child victim (PW-3), recorded without prior rationality test or judicial satisfaction of her competency under Art. 3 of Qanun-e-Shahadat Order, 1984 — No certification on record that the child was fit to testify — Statement revealed material contradictions and inconsistencies, including contradictions between her version and medical findings — Medical Officer initially opined that rape had occurred, but under cross-examination changed opinion based on Chemical Examiner and DNA reports which did not confirm commission of rape — No eye-witnesses produced; complainant and maternal uncle were hearsay witnesses — Held, allegation of incest required higher standard of proof due to its grave nature and the social implications — In absence of independent corroboration and credible testimony, benefit of doubt must be extended to accused. Cited Case: • Tayyaba Bibi & another v. The State (PLD 2020 SC 146) Disposition: Appeal allowed; conviction and sentence set aside; appellant acquitted. (b) Qanun-e-Shahadat Order, 1984 — Art. 3 Competency of child witness — Duty of trial court — Failure to conduct rationality test — Legal effect — Child victim's testimony formed the sole basis for conviction — Held, trial court failed to put Rationality Test or certify whether the child understood the nature of questions or was competent to testify — Such omission rendered testimony suspect and diminished its evidentiary value — In sexual assault cases, particularly where victim is a minor, trial court must make a recorded observation as to mental maturity and capacity to testify — Failure in this regard impairs the fairness of trial and credibility of evidence. (c) Criminal Procedure Code, 1898 — S. 342 Accused’s explanation — Allegation of false implication due to property dispute and matrimonial discord — Consideration of defence plea — Accused in his statement under S. 342 Cr.P.C. denied allegations and claimed he was falsely implicated due to refusal to transfer ancestral house to complainant, who was his wife and first cousin — He annexed copies of a written agreement and compromise notice from Union Council — Defence witness (DW-1) also supported plea of domestic dispute and failed reconciliation — Held, defence version raised plausible motive for false implication — Prosecution failed to rebut this version through independent corroboration or credible rebuttal — Benefit of doubt warranted. (d) Criminal Trial — Standard of proof — Seriousness of charge — Presumption of innocence High evidentiary threshold for conviction in cases of rape within family — Absence of credible, corroborated testimony fatal to prosecution — Held, prosecution evidence lacked consistency and failed to meet the standard required for sustaining conviction under S. 376 PPC — Serious allegations such as incestuous rape, allegedly committed in presence of other children and aged parents of the accused, demanded strict proof and reliable corroboration — Absence of independent witness, lack of physical evidence, non-recovery of relevant material, and contradictory medical opinion collectively rendered prosecution case doubtful — Conviction based on such deficient evidence not sustainable in law. Final Disposition: Petition converted into appeal and allowed. Conviction and sentence under S. 376(1), PPC set aside. Appellant acquitted and ordered to be released forthwith if not required in any other case.

Summary: (a) Constitutional law – Writ jurisdiction – Maintainability – Premature or speculative petitions – Constitution of Azad Jammu and Kashmir, 1974, Arts. 4, 18 & 25 – A writ petition founded on mere apprehension or speculative harm, without demonstration of an existing or concluded executive action causing legal injury, is not maintainable – The mere constitution of a committee for regularization of ad-hoc or contractual employees does not, in itself, infringe any fundamental or statutory right. (b) Administrative law – Executive discretion – Formation of committees – Scope of judicial review – Administrative authorities may constitute committees to evaluate matters within their domain – Judicial intervention arises only when such action results in contravention of law, arbitrariness, or violation of constitutional or statutory safeguards – Courts must refrain from interfering with preparatory or internal administrative processes not yet culminating in enforceable decisions. (c) Constitutional law – Writ of prohibition – Preventive jurisdiction – Though preventive in nature, the writ cannot be invoked on the basis of abstract or hypothetical injury – It lies only where a judicial, quasi-judicial, or statutory body is imminently assuming jurisdiction not vested in it or acting contrary to law – Speculative challenges to anticipated actions do not warrant constitutional intervention. (d) Separation of powers – Judicial restraint – Premature interference with administrative deliberations undermines executive autonomy and the constitutional doctrine of separation of powers – Courts must exercise writ jurisdiction to redress concrete violations, not potential or contingent grievances. (e) Precedents followed – Umar Shehzad v. Azad Government (2023 SCR 879); Bashir Ahmed Badini v. Hon’ble Chairman (2022 SCMR 448; 2022 PLC (C.S.) 610) – Relief under writ jurisdiction lies only where there is a demonstrable violation of law or a manifest breach of a legal or fundamental right causing tangible harm. Disposition: – Appeal dismissed. – High Court judgment dated 13.12.2024 upheld. – No order as to costs.

Summary: Acquittal granted --- (a) Criminal Procedure Code (V of 1898) – S. 342 – Judicial Confession – Retraction – Evidentiary Value Held, a retracted judicial confession, although admissible, must be corroborated by independent and trustworthy evidence—In the present case, the confession allegedly made by the accused was later retracted, and no independent, confidence-inspiring corroboration was available—Medical and forensic evidence was insufficient to sustain conviction—Confession recorded under pressure or in the presence of hostile parties cannot form the basis for conviction—Conviction based solely on a retracted confession, without credible supporting evidence, is unsustainable—Principles reiterated from Obaidullah v. The State (2025 SCP 177), Aala Muhammad v. The State (2008 SCMR 649), Muhammad Ismail v. The State (2017 SCMR 898), and Daniel Boyd v. The State (1992 SCMR 196). (b) Penal Code (XLV of 1860) – Ss. 302(b), 377 – Circumstantial Evidence – Standard of Proof – Benefit of Doubt Held, prosecution case was entirely based on circumstantial evidence—There were significant doubts including unexplained delay in lodging FIR, interested witnesses, lack of direct evidence, and belated introduction of last-seen witness—Recovery of weapon and forensic evidence not sufficient to conclusively link accused to the offence—Medical opinion regarding sodomy was inconsistent and not corroborated by initial postmortem—Held, in cases based on circumstantial evidence, each link in the chain must be unbroken and incapable of any other explanation than guilt of accused—Failure of one link destroys entire case—Principles reiterated from Siraj v. The Crown (PLD 1956 FC 123), Ch. Barkat Ali v. Major Karam Elahi Zia (1992 SCMR 1047), and Altaf Hussain v. Fakhar Hussain (2008 SCMR 1103). (c) Criminal Law – FIR – Delay in Lodging – Effect on Prosecution Credibility Held, FIR was registered approximately 47 hours after discovery of deceased—No plausible explanation provided—Complainant had ample opportunity to lodge FIR, but chose to wait until after burial and consultations—Such delay casts serious doubt on credibility and spontaneity of prosecution version—Cited: Altaf Hussain v. The State (2019 SCMR 274), Amir Muhammad Khan v. The State (2023 SCMR 566). (d) Constitutional Criminal Jurisprudence – Benefit of Doubt – Standard of Acquittal Held, where doubt exists in a prosecution case, no matter how minor, it must be resolved in favour of accused—It is the duty of the court to ensure that no innocent person is convicted based on assumptions, conjecture or interested testimony—Where multiple factors (retracted confession, inconsistent medical findings, delayed FIR, biased witnesses) raise serious doubt, acquittal is the only lawful outcome—Reaffirmed: “Benefit of doubt is not a concession but a legal right of the accused.” Disposition: Appeal allowed—Judgments of the Trial Court dated 02.01.2017 and High Court dated 30.09.2020 set aside—Appellant Manzoor Ahmed acquitted of all charges by extending benefit of doubt—To be released forthwith unless required in another case. Cited Authorities & Cases: Constitution of Pakistan, Art. 10-A Criminal Procedure Code (V of 1898), Ss. 342, 164 Penal Code (XLV of 1860), Ss. 302(b), 377 Obaidullah v. The State (2025 SCP 177) Altaf Hussain v. The State (2019 SCMR 274) Amir Muhammad Khan v. The State (2023 SCMR 566) Ch. Barkat Ali v. Major Karam Elahi Zia (1992 SCMR 1047) Siraj v. The Crown (PLD 1956 FC 123) Aala Muhammad v. The State (2008 SCMR 649)

Summary: (a) Contract Act, 1872 ----S. 70—Quantum meruit—Void appointment—Recovery of salary—Petitioner served for 15 years before appointment was found void for failure to meet minimum educational criteria—No allegation of fraud or concealment—Services rendered were accepted and remunerated without objection—Supreme Court held that doctrine of quantum meruit applied—Labor rendered in good faith and accepted by employer over extended period entitled to reasonable compensation—Retrospective recovery of salary impermissible in absence of fraudulent intent. References: Craven-Ellis v. Cannons Ltd (1936) 2 KB 403; Benedetti v. Sawiris [2013] UKSC 50; State of West Bengal v. M/s B.K. Mondal and Sons AIR 1962 SC 779. (b) Administrative Law ----Doctrine of acquiescence—Delayed departmental inquiry—Appointment made in 2003, scrutinized only after 15 years—No timely verification or oversight by department—Supreme Court held that institutional silence and prolonged acceptance of service created bar to retrospective recovery—Department estopped from invoking punitive financial measures for its own negligence—Termination for ineligibility upheld, but financial restitution disallowed. References: Ramsden v. Dyson (1866) LR 1 HL 129; Sardar Ali Khan v. State Bank of Pakistan 2022 SCMR 1454; Market Committee, Multan v. Additional Commissioner (Consolidation), Multan 2023 SCMR 1683. (c) Constitutional Law ----Equity and fairness in public service—Public authority benefiting from 15 years of continuous, satisfactory service cannot unjustly enrich itself by recovering past salary—Employee not shown to have committed fraud or willful misconduct—Supreme Court held that retrospective recovery was disproportionate, inequitable, and legally untenable—Order for recovery set aside, though dismissal for ineligibility remained intact. (d) Service Law ----Irregular appointment—Termination justified—Recovery not justified—Where appointment is found to be void due to non-fulfillment of eligibility criteria, termination of service is legally sustainable—However, Supreme Court clarified that in absence of deceit or malpractice, recovery of salary already paid for duties actually performed violates settled principles of law and equity. References: Shams ur Rehman v. Military Accountant General, Rawalpindi 2020 SCMR 188; Engineer-in-Chief v. Jalaluddin PLD 1992 SC 207. Disposition: Petition converted into appeal and partially allowed—Impugned judgment set aside to the extent of salary recovery—Dismissal from service maintained.

Summary: (Against the judgment dated 15.03.2016 passed by the Punjab Service Tribunal, Lahore Multan Bench in Appeal No. 1221 of 2014). Punjab Employees Efficiency, Discipline and Accountability Act (XII of 2006)--- ----Ss. 13(4)(a), 13(4)(b), 13(5) & 13(6)---Constitution of Pakistan, Arts. 10A & 212(3)---Authoritative dominance in disciplinary proceedings---Scope---Natural justice---Violation of right of fair trial---Non-fulfillment of procedural formalities---In post remand joint inquiry proceedings allegations against the petitioner remained unproved, however, minor penalty was recommended by inquiry officer due to slackness---Competent authority disagreed with such findings at the final order stage and imposed major penalty without prior assigning any reason for such disagreement at the review stage giving opportunity to the petitioner to show cause thereof---Petitioner remained unsuccessful in departmental appeal and appeal before Service Tribunal---Validity---Scenarios where the inquiry is deemed not to have been conducted per the legal framework, the Competent Authority, under Section 13(6) of PEEDA, has the responsibility to remand the inquiry back to the Inquiry Officer or Inquiry Committee---This may involve rectifying identified lapses or procedural formalities, or it may necessitate ordering a de novo inquiry to ensure compliance with legal standards---Such structured and detailed approach is vital in safeguarding the rights of the accused and ensuring that disciplinary proceedings are conducted with fairness and in adherence to the law---Dissection of the PEEDA, particularly its Section 13, shows that the legislation does not promote a culture of despotic use of authority within disciplinary proceedings, rather in its preference, it seeks to strike a balance between the imperative of safeguarding employee rights and the necessity of maintaining an efficient disciplinary framework within the service---Such objective has been sought to be achieved by instituting a system of accountability rooted in the principles of fairness, sound reasoning and justifiable decision-making---Law envisages that every step undertaken in disciplinary proceedings must align with the foundational principles of natural justice and procedural fairness and any deviation from these principles risks undermining the validity of the final order, thereby calling into question the integrity and legitimacy of the entire disciplinary process---In the absence of clearly articulated grounds or specific reasons within the show-cause notice, the petitioner was positioned precariously and at a significant disadvantage---Such omission transformed the notice into a mere formality, stripped of meaningful content, cultivating an unwholesome culture of authority while inflicting considerable prejudice on the petitioner and leading to substantial injustice---Competent authority in its final order, under Section 13(5) of the PEEDA, tried to fill in the lacuna in the proceedings and provided its reasons based on which it differed with the inquiry report and imposed a major penalty of forfeiture of one-year regular service---Such post-hoc reasoning could not rectify the initial shortcomings---Punishment order drawn under Section 13(5) of the PEEDA was an outcome of excessive authoritative dominance in the disciplinary proceedings---Such overreach undermined the very essence of fair treatment and compromised the petitioner's fundamental rights---Such a disregard for due process and procedural impropriety rendered the entire process flawed, devoid of any legal validity and could not be upheld in a legal framework that protects the right to a fair trial---Civil petition was converted into appeal and allowed and resultantly all impugned orders were set aside, with a direction to start proceedings afresh from the stage when inquiry report was received and order was passed thereon. Mahmood Ahmad Qazi, Advocate Supreme Court via video link from Branch Registry Lahore for Petitioner. Sana Ullah Zahid, Additional Advocate General Punjab for Respondents. Date of hearing: 16th May, 2025.

Summary: Summary pending

Summary: In a complaint filed under Section 25 of the Punjab Consumer Protection Act, 2025 ("the Act"), objection of limitation was taken in terms of Section 28(4) of the Act and application under Section 35 of the Act was filed for summary dismissal of the complaint, which was dismissed by the Trial Court through impugned order. Held that there is no cavil to the legal position that the limitation period provided under Section 28 (4) of the Act, for filing a claim, is 30 days from the date of accrual of cause of action. However, the said period of limitation is not so absolute as to leaving no room for filing claim beyond the stipulated period of 30 days as evident from the first proviso to Section 28(4) of the Act, which vests discretion within the Court to allow a claim to be filed within such time as the Court may allow if it is satisfied that there was sufficient cause for not filing the complaint within the specified period. Similarly, the second proviso lays down an upper ceiling of 60 days from the expiry of warranty or guaranty and if no period is specified one year from the date of purchase of the product or providing of services. Thus, the legislature in its wisdom has conferred discretion for extending the limitation for filing of a claim beyond the stipulated period of 30 days. Suffice to observe that such discretion is to be exercised in judicial manner. In the present case, it is not denied that a contractual warranty clause existed. The case of Pak Suzuki Motors Company Limited through Manager v. Faisal Jameel Butt and another (PLD 2023 SC 482) relied upon by the petitioner is hardly of any help to the case of the petitioner as the August Supreme Court while upholding the view of this Court rendered in case reported as Muhammad Ashraf v. Sheikh Muhammad Akram etc. (2022 CLD 638) enunciated that the statutory period of 30 days is to run from the date of accrual of cause of action. However, the said case, by no means denuded the Trial Court from its discretionary power of extension of limitation period vested under the law. Further held that Section 35 of the Act pertains to summary dismissal of the frivolous and vexatious claims and a complaint that is barred by time may ultimately fail on legal grounds, but it does not, on that count becomes frivolous or vexatious when relationship of customer-service provider is admitted. 472Review Application (Civil) R.A 25308/25 Munir Ahmad Bhatti Vs Mehmood Ahmad Tahir Bhatti etc Mr. Justice Sultan Tanvir Ahmad 14- 05- 2025 2025 LHC 3300