Figure 1.1: Taken from ARGO (Geopolitical Analysis and Research on the Middle East, Central Asia and South Asia)
It is evident that Pakistan has never been politically stable or democratic in its 60 years of
independence. However, 2007 and 2008 have been crucial years in which Pakistan seems to be
developing an inclination toward civil-led democratic government and an independent and strong
judicial system to complement it. Even though it is impossible to predict whether the obvious
signs will lead the country in the imagined direction, the possibility of such an event is extremely
high. With the reinstatement of Supreme Court Justices and the adoption of a somewhat
democratic form of government and a considerably stable Constitution, Pakistan seems to have
returned some power and faith into the Judiciary.
The Structure of Courts
Delving deeper into the judiciary and law and courts of Pakistan, it is important to
understand the structure of the court system in the country. A basic overview of the court system
will make it easier to understand the changes that have come about, the hierarchy within the
judiciary and the reasons why the judiciary, especially the Supreme Court, is being entrusted
with more power.
The judiciary of Pakistan according to the Constitution of 1973, includes the Supreme
Court, provincial high courts and other lesser courts exercising civil and criminal jurisdiction.
The Chief Justice of the Supreme Court is appointed by the President of Pakistan while other
Supreme Court judges are appointed by the President in consultation with the Chief Justice. In
this way, the basic court system of Pakistan seems to be somewhat similar to the court system in
the United States of America with a Supreme Court at the centre and several state courts in the
different states.
The Supreme Court has original, appellate and advisory jurisdiction and the judges
remain in office until the age of sixty five. High courts at the provincial level also have original
and appellate jurisdiction. High Court judges are appointed by the President after consultation
with the Chief Justice of the High Court to which the appointment is being made.
Besides the main Supreme Court and High Courts, there exists a Federal Shariat Court
comprising eight Muslim judges, which includes a Chief Justice appointed by the President.
Three of the judges are Islamic scholars (Ulema) and are well-versed in Islamic code and law.
The Federal Shariat Court also exercises original and appellate jurisdiction. It decides whether
any laws are inconsistent with the laws of Islam. When a law is deemed repugnant to Islam, the
President or the Governor is given the responsibility to bring the law into conformity with the
injunctions of Islam. The court can also hear appeals from decisions of criminal courts under
laws relating to the enforcement of hudood law i.e. laws pertaining to offences like intoxication,
theft and unlawful sexual intercourse.
In addition to these courts, there are several special courts and tribunals that deal with
specific types of cases. E.g. Drug Courts, Commercial Courts, Labor Courts, Traffic Courts,
Insurance Appellate Tribunals, Income Tax Appellate Tribunals, courts for bank offences and
courts to try terrorists. Appeals from special courts may be taken to the High Courts while
appeals from the special tribunals are taken to the Supreme Court.
Another integral part of the judicial system is the Law and Justice Division. This is an
advisory and consultative body to the Federal Government. Similarly, the Law Department in
each province deals with provincial legal matters. During the period from January, 1993, to June,
1994, the Law and Justice Division was called upon, from time to time,to tender advice on
various important and controversial constitutional and legal issues. Legislative Drafting Drafting
of Ordinances and Bills is a major function and responsibility of the Law and Justice Division
which is looked after by the Drafting Wing. The other major function and responsibility of the
Division is to look after the litigation on behalf of the Government of Pakistan. The Law and
Justice Division is also involved in the appointment of Law Officers including Attorney General,
Deputy Attorney General and Standing Councils. It also approves the appointment of legal
advisers for which purpose there is a committee comprising the Attorney General, Law and
Justice Minister and the Law and Justice Secretary. The Federal Judicial Academy was set up by
the Law and Justice Ministry in September, 1988 for the adequate training of Judges,
Government law officers, police officers and doctors dealing with medical legal cases.
A unique feature of the Pakistani judicial system is the existence of the office of Wafaq
Mohtasib. This is an office that existed in all early Muslim states and has been provided for in
the Constitution of Pakistan. This office was established to ensure that no wrongs were done to
the citizens, in other words, it safeguarded the rights of the people against the ruler. The
Mohtasib is appointed by the President and holds office for a non-renewable term of four years.
His purpose is to institutionalize a system that enforces administrative accountability, through
investigation and rectification of any injustice to a person through maladministration by a federal
agency or a federal government official. The Mohtasib is empowered to award compensation to
those who have suffered loss or damage as a result of maladministration. However, foreign
affairs, national defense and the armed services are excluded from the Mohtasib’s jurisdiction.
This institution seems to have been a well-meaning, well thought out idea that almost mirrors
present day Constitutional courts in its duties and functions. It was designed to bridge the gap
between the common people and the administrators and curb the misuse of discretionary powers.
This idea seems extremely forward and democratically inclined even though Pakistan’s history
reflects its inclination towards military dictatorship. As a result, it is not hard to imagine that the
Islamic laws that influence the law of the land are not holding the country back in any way but in
fact provided ideas that were far ahead of their times. The existence of this office also inspires
hope in the future of Pakistan as a democratic and judicially active nation. (Government
Structures, “Judiciary”)
Islamic (Sharia) Law
Before moving into further details of the application of Sharia Law in Pakistan and its
influence on judicial decision making, it is important to understand the basic concept of what
Sharia Law is and how it can influence a country and to what extent. A general idea of Islamic
Law will make it easier to grasp its role in Pakistan and the degree of power it exercises in the
country.
Most lay men and several academics have preconceived notions about Islamic (Sharia)
Law and those who practice it. Most believe that Islamic law judges are bound by ancient and
outdated rules of fixed punishment for all crimes, no matter how serious or simple. This is,
however, not true at all.
In order to protect the five important indispensables in Islam (religion, life, intellect,
offspring and property), Islamic Law has provided a worldly punishment in addition to that in the
hereafter. Islam has, in fact, adopted two courses for the preservation of these five
indispensables: the first is through cultivating religious consciousness in the human soul and the
awakening of human awareness through moral education; the second is by inflicting deterrent
punishment, which is the basis of the Islamic criminal system. Therefore "Hudud," Retaliation
(Kisas) and Discretionary (Tazir) punishments have been prescribed according to the type of the
crime committed.
To understand this complex system of Islamic law, it is necessary to understand the
nature of Islam and its basic religious tenets. The meaning of the word ‘Islam’ translates to
submission or surrender to Allah’s will. Therefore, it is required for Muslims to first obey and
submit to Allah’s will and then to the will of the State. Therefore, it is not surprising that most
Islamic states choose to adopt Sharia Law besides the law of their land. In Islam, the law, the
government and religion are considered one and the same. There may exist varying degrees of
this concept in different nations but all law, government and civil authority rests upon it.
However, this does not mean that every citizen in a Muslim state, whether Muslim or Non-
Muslim is subject to Sharia. In fact, according to Islam, Sharia is applicable only to Muslims.
Sharia law essentially controls, rules and regulates all public and private behavior for
followers of Islam, whether enforced by the state or not. It has regulations for personal hygiene,
diet, sexual conduct and even elements of parenting. It also prescribes specific rules for prayers,
fasting, giving to the poor and many other religious matters.
Crimes under Islamic Law can be broken down into three major categories. Each will be
discussed in greater detail with some common law analogies. The three major crime categories in
Islamic Law are:
1. Hadd [plural Hudud] Crimes (most serious).
2. Tazir Crimes (least serious).
3. Qesas Crimes (revenge crimes restitution).
Hadd crimes are the most serious under Islamic Law, and Tazir crimes are the least serious.
(Al-Afi, 227-236)
Islamic law though different from the Common law and Civil law traditions, cannot be
considered any less legitimate or authoritative in an Islamic state. All Muslims are bound by its
provisions and punishments. This has been clearly established in the Pakistani court system
through the existence of Federal Shariat Courts and Ulemas. The power of Sharia law cannot be
underestimated or considered any less than that of the Constitution and the Common Law system
in Pakistan.
Constitutional Status of Islamic Law in Pakistan
Pakistan has been recognized as the largest Islamic state in the world. With this
recognition comes the acceptance of a prevalent Islamic code in the country’s legal system.
Therefore, it is hardly surprising to see the intervention and inclusion of Islam in the modern
Constitution of Pakistan.
Article 1 of the Constitution of 1973, which is the Constitution in force today in Pakistan,
states that Pakistan shall be known as “the Islamic Republic of Pakistan” and Article 2 declares
Islam as the state religion. In 1985, the insertion of Article 2A of the Constitution included that
all laws had to be brought into consonance with the Quran and sunnah. Chapter 3A establishes
the Federal Shariat Court and stipulates that the court shall take up the examination of any law or
provision of law that may be repugnant to the “injunctions of Islam as laid down in the Holy
Quran and the Sunnah.” The Court may also examine any decisions of criminal courts relating to
the application of the hudud penalties.
The Supreme Court also has a Shariat Appellate Bench empowered to review the
decisions of the Federal Shariat Court and consisting of three Muslim Supreme Court judges and
up to two ulema. Part IX of the Constitution is entitled ‘Islamic Provisions’ and provides for the
Islamization of all existing laws, reiterating that no law shall be enacted which are repugnant to
the injunctions of Islam.
The Islamic Provisions also provide for the creation of an Islamic Ideology Council of 8
to 20 members appointed by the President. They may have “knowledge of the principles and
philosophy of Islam as enunciated in the Holy Quran and Sunnah, or understanding of the
economic, political, legal or administrative problems of Pakistan.” The Islamic Council is meant
to represent various schools of thought and at least one woman must be appointed to the council.
Its function is to make recommendations to the Parliament and the Provincial Assemblies “as to
the Holy Quran and Sunnah.” The Council also determines for the federal and provincial
government whether or not proposed laws are repugnant and compiles “such injunctions of Islam
as can be given legislative effect.”
Therefore, it is extremely evident that Islam plays a major role not only in the legal
system of Pakistan but also in the political scenario. Islamic law can determine whether certain
laws may be enacted or not much like the role of the Constitution in most common law nations.
Laws are reviewed by religious leaders and tested for consistency on religious bases rather than
Constitutional ones. This simple difference is in itself a huge statement for the role of Islam in
politics and jurisdiction. (Lau, 5-10 & 47-72)
Islamization of Laws in Pakistan
Islamization of law in Pakistan seems to be a judge-led process which was first initiated
to enhance the power of the judiciary and to expand the scope of constitutionally guaranteed
fundamental rights. It is, however, possible to overlook the role of the judges in Islamization of
the legal system in lieu of the more visible manifestations, namely the promulgance of the
infamous Hudood Ordinances and other isolated pieces of Islamic legislation, such as the
Enforcement of Sharia Act in 1991. (Lau, 1-3)
However, the judicial appropriation of Islam and its integration into the vocabulary of
courts has been a conscious process aimed not only at the fulfillment of a general desire to
indigenize and Islamize the legal system after the end of colonial rule but it has also been a way
of enhancing judicial power and independence. The most important example of this was the
introduction of Islamic laws during and following Zia-ul-Haq’s martial law. However, the
Islamization of law did precede Zia-ul-Haq’s regime and was actually also used to challenge
him. (Lau, 5-39)
The judge-led Islamization of Pakistan continues to this day. It is no longer confined to a
few distinct areas of law but has become an integral part of the legal discourse being relied on in
the context of a wide range of issues, from the permissibility to erect high rise buildings in
Karachi to the dismissal of the Prime Minister under Article 58(2)(b) of the 1973 Constitution.
(Lau, 47-88)
The role of Islam in the legal system of Pakistan is marked by diversity, complexity and
uncertainty. There is no doubt that Islam has become an important factor in judicial decision-
making. For example, in the case of Aijaz Haroon v. Inmam Durrani Justice Wajihuddin Ahmad
held that Article 2-A was introduced into the 1973 Constitution as a panacea to remedy the
defects inherent in the other parts of the Constitution concerned with the Islamization of the legal
system:
“[…] I am of the view that all laws whether they be constitutional or sub-constitutional must
yield to the Sovereignty of Allah as reflected in the Holy Quran and Sunnah and if there to be a
clear command in that behalf it is that command alone which has to be given effect to and all
other legislation applicable in this Islamic Republic of Pakistan must be construed as
subordinated thereto.” (Lau, 56)
Pakistan’s superior courts have been willing to depart from the country’s colonial legacy
of inherited statutes and legal concepts in favor of an approach that is more in line with
indigenous, Islamic values. There was no single event that triggered the adoption of Islam as an
alternative to Western jurisprudence. Islamic jurisprudence was embraced by judges either
because their personal beliefs dictated such an approach or because Islamic values could offer
support for judicial explorations into untested areas of law. In case of the former, Justice Afzal
Zullah is considered the most important contributor to the expanding role of Islam in the legal
system. (Lau, 131-138)
The role and importance of Islam in the legal system of Pakistan has increased steadily.
However, this rise in the importance of Islam is a result of judicial self-determination rather than
that of deliberate governmental policies. The appropriation of Islam has amplified the power of
the judiciary. Under the mantel of Islam, Pakistan’s shariat courts have been able to circumvent
virtually all constitutional mechanisms which protect legislation against judicial review. Thus,
the role of Islam in the legal system can be regarded as essentially an enhancement of judicial
powers. The flexibility of Islamic law in the hands of Pakistan’s higher judiciary has ensured and
fostered the role of Islam in the legal system. However, flexibility brings legal uncertainty and it
is this aspect which has been identified as the most problematic facet of the judiciary’s use of
Islam as a tool for enhancement of judicial power. (Lau, 199-209)
No firm predictions can therefore, be made about the future role of Islam in Pakistan’s
legal system. However, it can be concluded that irrespective of government intervention the
future role of Islam lies in the hands of the Pakistani judiciary. (Lau, 209-211)
Growing Judicial Activism in Pakistan
As is evident from the application of Islamic law, the Pakistani judiciary is now
becoming more aware of its powers and is headed toward a stronger and more independent
judiciary. Judicial activism is finally gaining momentum in Pakistan long after its counterpart,
India. Instead of cowering behind military generals, the judges have decided to take matters into
their own hands and judicial empowerment is no longer a mere dream. However, it took several
long years and close to six decades for this change to actually come about. In these years judges
in Pakistan have, on the one hand, at times struck down a law on the ground that it was
repugnant to the Constitution or to Islamic law or have voided specific actions of government
agents, because these violated the Constitution or a relevant law. While on other, they have
validated not merely violations but abrogation and suspension of the Constitution in accordance
to the government’s will simply because they chose to follow the government blindly rather than
uphold the Constitution. Often times, the Court tried to put on a grand show of its judicial power
by granting the government rights it had not asked for and putting up a strong public front but in
reality, the courts were more or less inactive until a few years ago.
In 1954, Pakistan’s governor-general dismissed the constituent assembly. The federal
court upheld his action for reasons of “state necessity,” but in reality, it merely followed the
governor-general because he was in power.
In 1958, 1977 and 1999, the military seized the government, abrogated the Constitution
on the first occasion and put it in abeyance on the next two. The president of Pakistan dismissed
the National Assembly, and with it the prime minister, in 1988, 1990, 1993, and 1996. The
Supreme Court validated all of these actions except the Assembly’s dismissal in 1993. It
validated the army’s coup by invoking the “doctrine of necessity.” This doctrine is not a part of
the law but a rationale for evading or defeating the law.
The Supreme Court exists and functions under the authority of the Constitution. After a
general has abrogated or suspended the Constitution, it exists and functions at his sufferance or
under his mandate. In none of the afore-mentioned cases did the general ask the judges to
validate his action. Each time, a third party posed a challenge to the abrogation and even though
the Supreme Court could have declined to hear it for lack of jurisdiction they heard the case, and
put their seal of approval upon the coup instead. Then in a dramatic display of activism, they
went out of their way to confer upon the general the authority to amend the Constitution even
though he hadn’t asked for it.
They did not call upon the general’s spokesman to spell out the nature and degree of the
necessity that had compelled him to overthrow a duly constituted government even though his
allegations that the previous government had been corrupt and incompetent was not a good
enough reason. Instead of asking him to establish that Pakistan would’ve befallen a crisis if not
for the coup, the court chose not to raise the issue.
When the president dismissed the National Assembly to get rid of an unwanted prime
minister on charges of corruption and incompetentence, the courts did not question his decision
even though he could have just as easily dissolved the government and called for re-elections.
The court upheld the president in two cases and voided his action in one. In the former two cases
it did not ask him to prove in what way it had become impossible to carry on the government
according to the Constitution. This too was an extreme show of judicial activism while being
simply an act in reality.
In the 1980s and early 1990s the Courts in Pakistan began taking certain measures
towards ensuring human rights. Three young women in Mianwali appealed to the president and
the Supreme Court (through the media) to protect them from persons threatening to hurt them
because they would not marry the men to whom they had been promised by their parents when
they were children or babies. The chief justice of Pakistan read about this affair in the
newspapers and directed the district police officer to protect the girls. A woman alleged that she
had been molested by two police officers, and raped by one of them, in Faisalabad. The Supreme
Court took cognizance of the matter and virtually took charge. It ordered an inquiry and wanted
to know the findings. It directed the police, sequentially, to register a criminal case against the
accused officers, arrest them and place them in jail. It found faults with the inquiry report, told
the investigators to go back and look further, ordered another group of higher-ranking officers to
conduct their own inquiry. Another young woman, a Kashmiri earthquake victim, alleged that a
physician in the hospital to which she had been admitted had raped her, and the court ordered an
inquiry. In some of such cases the court has intervened, suo motu, because a law had been
violated or was about to be violated. Articles 184, 187, and 199 of the Constitution appear to
authorize the court to act in cases of “public importance” involving fundamental rights for the
purpose of securing complete justice.
In certain matters, which were indisputably “matters of national importance,” the court
remained quiescent. For instance, it had validated Ziaul Haq’s coup on the understanding, among
others, that he would hold elections within 90 days of his seizure of the government. He did not
make good of his promise but the court did not take any action against him. Until 2007, General
Musharraf was seen exercising powers that the Constitution and the laws did not allow him to
but the court did nothing to restrain him. The latter, however, can be attributed to Musharraf’s
complete disregard for the Constitution and his growing dictatorial power.
In 2005, Justice Iftikar Chaudhry took over as the Chief Justice of the Supreme Court. He
immediately began taking action on public complaints and incidents brought to public
notice through press reports. Some famous cases which brought the wrath of the present
government included the privatization of Pakistan's largest steel mill, missing persons cases, land
scams in Islamabad and illegal constructions in Karachi and Lahore. However, Justice
Chaudhry’s positive action and his move towards judicial activism looked to be a direct threat to
President Musharraf’s growing power. In March 2007, he suspended Justice Chaudhry and thus,
brought judicial activism to a standstill all over again. Justice Chaudhry’s suspension was met
with severe criticism and lobbying against President Musharraf which led him to dismiss several
other judges on no grounds other than personal reasons. This, however, proved to be the first few
strains of judicial activism in a long time in Pakistan. Later, on July 20, 2007, Justice Chaudhry
and all the other deposed judges were reinstated and this constituted a huge triumph for the
Supreme Court and a huge blow for Musharraf. On August 14, 2008, President Musharraf finally
resigned and Benazir Bhutto’s widower Asif Ali Zardari was democratically elected the
President of Pakistan.
It can, therefore, be seen that in recent times, the court has stepped up and begun to take
charge of situations and make decisions concerning the government as well as the people of
Pakistan. The court’s positive action is a positive sign for the future of judicial activism. Several
cases have been brought forward in which human rights violations are is the key factor. These
cases have been taken up by the court and dealt with in a smooth and efficient manner, leading
one to believe that the courts have indeed been reformed and gained independence of some sort.
However, when the court continues to be inactive in cases involving the administration, it is hard
to continue on the same train of thought. Yet, the future of judicial activism looks bright in
Pakistan with a democratic government and more separation of powers, the judiciary is bound to
blossom into an active organ of the government, sooner or later.
Reforming the Judiciary
Pakistan’s return to civilian government after eight years of military rule and the
sidelining of the military’s religious allies in the February 2008 elections offer an opportunity to
restore the rule of law and to review and repeal any discriminatory Islamic laws that restrict
fundamental rights, fuel extremism and destabilize the country. Judicial reforms would remove
the legal cover under which extremists target their rivals and exploit a culture of violence and
impunity. Even though Islamic law has been lighting the way to an empowered judiciary, not all
of its provisions can be considered beneficiary, therefore, removal of some of these
discriminatory provisions would definitely ensure a brighter future for both Islamic law and the
common law judiciary. Ensuring judicial independence would also strengthen the transition to
democracy at a time when it is being undermined by worsening violence.
Motivated by self-preservation and self-interest, Pakistan’s superior judiciary has not just
failed to oppose Islamic legislation that violates fundamental rights but has also repeatedly failed
to uphold the constitution. While superior courts have validated military interventions, military
regimes have manipulated judicial appointments, promotions and removals, steadily purging
higher court benches of independent-minded judges. This has pushed the judiciary further to the
ideological right. Today, judicial independence is hampered not only by the state but also by
right-wing religious groups.
If democratic functioning is to be truly restored, the military’s politically motivated
constitutional and legal changes that have radicalized Pakistani society must be reversed. If the
democratic transition is to be sustained and strengthened, the freely elected government must
respect judicial independence, and the judicial arm of the state must live up to its responsibility
to protect and preserve the constitution.
Pakistan’s two largest national-level parties, the Pakistan People’s Party (PPP), now in
government, and the Pakistan Muslim League-Nawaz (PML-N), the main opposition party, have
pledged to undo the legacy of military rule. Upon assuming power in March, the PPP and PML-
N, then coalition partners, released scores of political detainees, including lawyers and judges
arrested during Musharraf’s November 2007 martial law. They also lifted the military regime’s
ban on labour and student unions, and committed to enforcing basic human rights. The coalition
government has since unravelled, primarily over disagreements on mechanisms to restore over
50 higher court judges, including the Supreme Court chief justice, illegally dismissed during
Musharraf’s emergency. Nevertheless, both parties remain committed to restoring
constitutionalism, the rule of law and judicial independence. Their ability to reach consensus on
the necessary constitutional changes to remove the military’s political distortions will determine
the future of the democratic transition.
Aside from reintroducing constitutionally sanctioned checks and balances between the
executive, legislature and judiciary, the present democratic government needs to focus on
judicial reform. An independent, reformed judiciary will not only help underpin
constitutionalism and the rule of law but could also play a crucial role in preventing another
direct or indirect authoritarian intervention. The government’s democratic credentials and the
country’s political stability would also be best served with the ruling and opposition parties
reaching agreement in parliament on reversing repealing the laws that empower Islamist radicals
at the cost of the moderate majority.
The international community, also, needs to avail itself of the opportunity the new
democratic government presents. By unconditionally supporting Musharraf’s military regime in
the belief that this relationship would deliver counter-terrorism dividends, the international
community, the Bush administration in particular, shied away from supporting democratic
reform, until Musharraf’s illegal martial law of November 2007. With a liberal government now
in place, the international community could help reverse the tide of radicalism in Pakistan if it
fully supports a sustained democratic transition, including an independent judiciary.
Conclusion
In 61 years of freedom, Pakistan has yet to see an era of political stability and peaceful
democratic rule yet it has come a long way from the throws of complete political chaos to a state
of transitional democracy. With the political system, the legal system has also grown and
changed and transformed into a far more liberal, independent and powerful organ of the
government. The once suppressed courts are no longer afraid to express their views and do not
blindly support the government and validate their actions without reason. It took 61 long years to
reach this point and it will take even longer for this system to actually stabilize and become a
power to contend with, yet Pakistan’s future looks bright in the event of its transitional
democratic status. Until 2007, the courts had little or no voice in political issues and legislations
especially because of military rule and martial law in the country. At most times, courts chose to
voice the same opinions that the government did and were seen as weak and controlled.
However, after Justice Iftikar Chaudhry’s dismissal, the uproar caused by the courts proved that
they would no longer lay low and accept their fate but would take positive action to secure their
role in the government. In self-preservation interests, the courts have often given in to Sharia law
which almost provides a platform to base their judgment of the government on. It is far easier for
courts to declare laws as inconsistent with the Quran than it is for them to do it with respect to
the Constitution. Thus, Islamic law and judicial activism seem to go hand in hand with one
legitimizing the others claim to power. Thus, it seems like Pakistan is definitely moving towards
a more liberal, democratic future but even so, it will not lose its Islamic character and Islamic
laws.
Work Cited
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Lau, Martin. The Role of Islam in the Legal System of Pakistan. Leiden: Martinus Nijhoff
Publishers. 2006.
“Reforming the Judiciary in Pakistan.” International Crisis Group. October 16, 2008.
“The Islamic Republic of Pakistan.” Emory Law School. 2002.
<>
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