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R.A (Civil Revision) 196/2025 (S.B.) Sindh High Court, Karachi - Syed Najam Raza Naqvi (Applicant) — 2025 SHC 953

Official Citation: 2025 SHC 953

Court / Jurisdiction: Sindh High Court

Petitioner: R.A (Civil Revision) 196/2025 (S.B.) Sindh High Court, Karachi - Syed Najam Raza Naqvi (Applicant)

Legal Principle & Question Decided

Ruling Summary: This decision was rendered by the Sindh High Court, officially reported as 2025 SHC 953. In this matter between R.A (Civil Revision) 196/2025 (S.B.) Sindh High Court, Karachi - Syed Najam Raza Naqvi (Applicant) and the Respondent, the court adjudicated key questions of statutory construction, procedural regularity, and legal precedent under Pakistani law.

Core Holding: The honorable bench evaluated governing statutory provisions and judicial authorities to establish the rights of the parties, delivering the binding reasoning set out below.

Full Judgment Text & Judicial Ruling

COURT: Sindh High Court CASE NO: R.A (Civil Revision) 196/2025 (S.B.) Sindh High Court, Karachi CITATION: 2026 SHC KHI 953 PARTIES: Syed Najam Raza Naqvi (Applicant) ORDER DATE: 21-FEB-26 BENCH: Hon'ble Mr. Justice Muhammad Abdur Rahman(Author) A.F.R: Yes ------------------------------------------------------------ 1 IN THE HIGH COURT OF SINDH AT KARACHI C.R.A. No. 196 of 2025 __________________________________________________ DATE ORDER WITH SIGNATURE OF JUDGE ____

1. For orders on office objection a/w. reply at A. 2. For hearing of CMA No.9199/2025. 3. For hearing of Main Case. 4. For orders on Nazir’s Report dated 05.01.2026.

Applicant : through Mr. Muhammad Ali Lakhani, Advocates

Respondent No.1 : Through Mr. Mohammad Haseeb Jamali, Advocate

Respondents No.3 to 6 : Through Mr. Ahmed Khan Khaskheli, AAG Sindh along with Anwer Ali Panhwar, Survey Superintendent.

Respondent No.7 : Through Mr. Sarmad Khan , Barrister -at - law

Respondents No.8 to10 : Nemo.

Date of Hearing : 6 January 2026, 17 January 2026 and 24 January 2026 and 7 February 2026

Date of Decision : 21 February 2026

O R D E R

MOHAMMAD ABDUR RAHMAN, J This Order will decide a Revision Application, maintained under Section 115 of the Code of Civil Procedure, 1908, seeking to revise an Order dated 2 December 2025 that had been passed by the IVth Senior Civil Judge Malir, Karachi in Suit No. 2756 of 2025 on two applications maintained under Rule (1) and (2) of Order XXXIX of the Code of Civil Procedure, 1908 and under Section 94 of the Code of Civil Procedure, 1908 by the Respondent No. 1

A. Facts

(i) The Pleadings of Mst. Badar Jahan

2. Mst. Badar Jahan, the Respondent No.1, contends that she was initially allotted 16 Acres of land and 10 Acres of land, each in Na Class No. 26, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi, in the year 1994. Both the parcels of land

2 were surveyed in the year 1 996 and demarcated as Survey No. 145, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 10 Acres and Survey No. 146, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 16 Acres.

3. Mst. Badar Jahan submits that thereafter through a Sale Agreement dated 22 June 2009 she agreed to sell Survey No. 145, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 10 Acres to the brother of one Muhammad Rashid Qureshi. She contends that after the execution of the Agreement of Sale dated 22 June 2009 , Muhammad Rashid Qureshi encroached on Survey No. 146, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 16 Acres and which led to criminal proceedings bearing FIR No. 88 of 2016 being instituted at PS Ibrahim Hyderi but which subsequently, by an order dated 23 September 2016, was disposed of in “A” Class by the concerned Magistrate.

4. She further contends, that Muhammad Rashid Qureshi and his brother Muhammad Aslam Qureshi, who had entered into an agreement to purchase Survey No. 145, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 10 Acres, caused to be carried out a sub-division and demarcation of Survey No. 145, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 10 Acres to be and which she contends was carried out by the Survey Superintendent, without causing notice of the Survey to be issued to her and which she contends is illegal. Consequentially, Mst. Badar Jahan maintains that, Survey No. 145, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 10 Acres was reconstituted as Survey Nos., 166, 167, 184,185, 186, 187, 188, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi and the location of which overlaps with her land i.e., Survey No. 146, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 16 Acres

5. After the creation of Survey No., 166, 167, 184, 185, 186, 187, 188 Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi, Mst. Badar Jahan contends , that a fraud took place in the record of the Board of Revenue and as a consequence of which the following sale deeds were executed and on the basis of which mutations were recorded in the record of rights:

(i) a Sale Deed dated 24 July 2018 and on the b asis of which Mohammad Rashid Qureshi acquired Survey No. 166, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 3 Acres and Survey No. 16 7, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 1 Acre;

(ii) a Sale Deed dated 24 July 201 8 and on the basis of which Mohammad Rashid Qureshi acquired Survey No. 185, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 2 Acres and

3 Survey No. 186, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 2 Acres; and

(iii) a S ale De ed dated 24 July 2018 and on the basis of which Mohammad Rashid Qureshi acquired Survey No. 187, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 2 Acres and Survey No. 188, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 2 Acres.

Mst. Badar Jahan contends that the location of Survey No. 166, 167, 184, 185, 186, 187, 188, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi overlaps with the location of Survey No. 146, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 16 Acres, that is owned by her , and has instituted Suit No. 2756 of 20251 seeking a declaration in respect of her ownership over Survey No. 146, Na Class No. 26, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 16 Acres, challenging the creation of Survey No. 184, 166, 167, 185, 186, 187, 188 Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi and seeking the cancellation of each of the Sale Deeds mentioned hereinabove.

(ii) The Pleadings of Syed Najam Raza Naqvi

6. Syed Najam Raza N aqvi, the Applicant herein, contends that Survey No. 184 (out of NC 126), Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 4 Acres was never created through the sub-division of Survey No. 145, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi ad measuring 10 Acres but was initially allotted to one Muhammad Anwar Samoo. This allotment in favour of Muhammad Anwar Samoo was cancelled under the Sindh Urban State Land (Cancellation) of Allotments, Conversions and Exchanges) Ordinance, 2000 and subsequently regularised thereunder . It is contended by Syed Najam Raza Naqvi, that Muhammad Anwar Samoo regularised Survey No. 184 (out of NC 126), Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 4 Acres and thereafter he, through a registered Sale Deed dated 8 February 2016, acquired Survey No. 184 (out of NC 126), Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 4 Acres. Syed Najam Raza Naqvi contends that he has, since then, caused for Survey No. 184 (out of NC 126), Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 4 Acres to be further sub-divided and allotted plots carved thereon to third parties some of whom are residing thereon.

1 Originally instiuted as Suit No. 741 of 2022 before the High Court of Sindh at Karachi.

4 (iii) Pleadings of Mohammad Rashid Qureshi

7. Mohammad Rashid Qureshi, the Respondent No. 6, contends that:

(i) Survey No. 185, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 2 Acres and Survey No. 186, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 2 Acres were originally allotted to one Ghulam Hussain as un-surveyed land in Na Class No. 26, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi and which after being regularised under the Sindh Urban State Land (Cancellation) of Allotments, Conversions and Exchanges) Ordinance, 2000 were surveyed and assigned the aforementioned Survey numbers and thereafter were purchased by him through a registered Sale Deed dated 23 July 2018;

(ii) Survey No. 187, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 2 Acres and Survey No. 188, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 2 Acres were originally allotted to one Pervez Ahmed as un-surveyed land in Na Class No. 26, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi and which after being regularised under the Sindh Urban Stat e Land (Cancellation) of Allotments, Conversions and Exchanges) Ordinance, 2000 were surveyed and assigned the aforementioned Survey numbers and thereafter were purchased by him through a registered Sale Deed dated 24 July 2018; and

(iii) Survey No. 166, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 3 Acres and Survey No. 167, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 1 Acre were originally allotted to one Masood Ahmed Khan as un-surveyed land in Na Class No. 26, Deh Rehr i, Taluka Ibrahim Hyderi, Malir, Karachi and which after being regularised under the Sindh Urban State Land (Cancellation) of Allotments, Conversions and Exchanges) Ordinance, 2000 were surveyed and assigned the aforementioned Survey numbers and thereafter were purchased by him through a registered Sale Deed dated 24 July 2018.

He contends that these properties are not overlapping with Survey No. 145, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 10 Acres or with Survey No. 146, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi admeasuring 16 Acres.

5

(iv) The Survey Superintendent

8. The Respondent No. 6, i.e., the Survey Superintendent, had submitted his written statement and therein pleaded that Survey No. 166, 167, 184, 185, 186, 187, 188 Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi do not overlap with the location of Survey No. 146, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi. These pleadings are however contradicted by the Survey Superintendent in a report dated 16 May 2023 wherein it was contended that these Survey No. 166, 167, 184, 185, 186, 187, 188 Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi do overlap with the locatio n of Survey No. 146, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi and wherein it was concluded that:

“ … From perusal of facts discussed above/ record available in this office and detailed report furnished by the field Survey Staff, it reveals that th e owner Khatedar Attempted to change the locations of Survey Number 166 & 167 on his own will illegally with the illegal support of field survey staff of this office several times. However, Survey Number 184, 185, 186, 187 & 188 of Deh Rehti a re created by the field survey staff without confirmation of possession at site and without getting the original sketch prepared at the time of allotment. It is pertinent to mention that Survey no 145 & 146 were created adjacent to one another in the year 1996 and the newly Created Survey Nos. 184, 185, 186, 187, 188, 166 & 167 are shown to have been created adjacent to Survey no. 145 of Deh Rehri, ovetlapping the old Survey Number 146. But the location of Survey Number 145 & 146 has been changed on Deh Map as well as in Demarcation Plan issued by this office vide letter No: SS/KYC/(F -1176)/2022/218, dated: 07 -04-2022 (copy letter & demarcation plan is attached at Annexure-F).

Keeping in view of report furnished by the field survey staff (copy enclosed at Annexure-G) and facts discussed, it is requested that the Survey Numbers 166, 167, 184, 185, 186, 187 & 188 of Deh Rehri may be cancelled from the Deh Map only and the demarcation plan issued vide this office letter dated: 07.04.2022, may also be cancelled. and Survey No 145 & 146 may be corrected on Deh Map after verification of current physical position at site.

Brief facts are submitted for kind perusal and orders.

(Anwar Ali Panhwar) Ex-Pcs Survey Superintendent, Karachi”

(v) Applications maintained by Mst. Badar Jahan and orders passed by the IVth Senior Civil Judge, Malir Karachi in Suit No. 2756 of 2025.

9. Mst. Badar Jahan maintained two applications seeking injunctive relief as against the construction that was ongoing on Survey No. 166, 167, 184, 185, 186, 187, 188 Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi.

10. The IVth Senior Civil Judge Malir Karachi, primarily on the averments made by the Survey Superintendent in his report dated 16 May 2023 has allowed the applications and against which this Revision Application has been maintained.

6

B. Contentions on behalf of the Applicant

11. Mr. Muhammad Ali Lakhani has entered appearance on behalf of the Syed Najam Raza Naqvi and after contending that Syed Najam Raza Naqvi has title to his property that is independent of the title of Mst. Badar Jahan and Mr. Mohammad Rashid Qureshi, has pleaded that the only i ssue is with regard to the location of each of their properties. In this context he has contended that the contentions of the Survey Superintendent , in the report dated 16 May 2023, are contrary to his own pleadings in Suit No. 2756 of 2025. He stated that such contradictions warrant that a fresh demarcation should be carried out by the Survey Superintendent, under the supervision of the Court and which would clarify the location of each of the properties owned by Syed Najam Raza Naqvi, Mst. B adar Jahan and Mr. Mohammad Rashid Qureshi and would then permit a proper determination to be made as to whether the location of Survey No. 166, 167, 184, 185, 186, 187, 188 Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi did or did not overlap with the location of Survey No. 146, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi on the basis of which injunctive relief could be properly determined.

12. On a question put by the Court as to the maintainability of this Revision Application against an interl ocutory order passed by the IVth Senior Civil Judge, Malir Karachi in Suit No. 2756 of 2025, Mr. Muhammad Ali Lakhani averred to the provisions of Section 115 of the Code of Civil Procedure, 1908 and contended that the section gave concurrent jurisdiction to the High Court to revise an order passed by any court subordinate to it from which an appeal did not lie to it and which included, but was not limited to, the interlocutory order passed by the IVth Senior Civil Judge, Malir Karachi in Suit No. 2756 of 2025. He relied on case law which is considered hereinbelow.

C. Contentions on behalf of Respondent No. 7

13. Mr. Sarmad Khan entered appearance on behalf of Mr. Mohammad Rashid Qureshi and supported the contentions of Mr. Muhammad Ali Lakhani. While maintaining that the property owned by Mr. Mohammad Rashid Qureshi was distinct from the property owned by the Mst. Badar Jahan, he contended that the contentions of the Survey Superintendent, in the report dated 16 May 2023, are contrary to his own pleadings in S uit No. 2756 of 2025 . He stated that such contradictions warrant that a fresh demarcation should be carrie d out by the Survey Superintendent, under the supervision of the Court and which would clarify the location of each of the properties owned by Syed Najam Raza Naqvi, Mst. Badar Jahan and Mr. Mohammad Rashid Qureshi and would then permit a proper determination to be made as to whether the location of Survey No. 166, 167, 184,

7 185, 186, 187, 188 Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi did or did not overlap with the location of Survey No. 146, Deh Rehri, Taluka Ibrahim Hyderi, Malir, Karachi and on the basis of which injunctive relief could be considered.

D. Contentions on behalf of the Respondent No. 1

14. Mr. Muhammad Haseeb Jamali entered appearance on Mst. Badar Jahan and contended that this Application was not maintainable and relied on numerous orders passed by Learned Single Judges of this Court holding that on account of the amendment made by the insertion of Sub -Section (2) of Section 115 of the Code of Civil Procedure, 1908, concurrent jurisdiction had been given to the High Court and the District Judge to entertain revision applications and which applying the principles of Section 15 of the Code of Civil Procedure,1908 warranted that such applications should be made before the District Judge and not before this Court.

15. On merits he contended that there was no further requirement for a demarcation to be carried out prior as the Survey Superintendent had carried out various demarcations each of which admittedly contradicted the other as admitted by the Survey Superin tendent himself and as such the orders impugned were warranted otherwise the entire land admittedly owned by Mst. Badar Jahan would be encroached. He further contended that the demarcation on record were subject to evidence and which was the proper foru m to consider the location of each of these properties.

E. Order of the Court

16. I have hear d Mr. Muhammad Ai Lakhani, Mr. Sarmad Khan and Mr. Muhammad Haseeb Jamali and have perused the record.

17. The power to revise an order was first conferred on a High Court under Section 622 of the Code of Civil Procedure, 1882 and which read as hereinunder:

“ … The High Court may call for the record of any case in which not appeal lies to the High Court if the Court by which the case was decided ap pears to have exercised a jurisdiction not vested in it by law or to have failed to exercise a jurisdiction so vested or to have acted in the exercise of its jurisdiction illegally or with material irregularity and may make such order in the case as the High Court thinks fit.”

After the repeal of the Code of Civil Procedure, 1882, the power of the High Court. to revise was found in Section 115 of the Code of Civil Procedure, 1908 and which

8 was slightly different to the provisions of Section 622 of the Co de of Civil Procedure, 1882 and which read as hereinunder:

“ … The High Court may call for the record of any case which has been decided by any Court Subordinate to such High Court and in which not appeal lies thereto, and if such subordinate court appears:

(a) to have exercised a jurisdiction not vested in it by law, or

(b) to have failed to exercise a jurisdiction so vested,

(c) or to have acted in the exercise of its jurisdiction illegally or with material irregularity

and may make such order in the case as the High Court thinks fit.”

Amendments were made in the years 1972, 1980, 1992 and 1994 to this Section and whereafter Section 115 of the Code of Civil Procedure, 1908 now reads as hereinunder:

“ … 115.-(1) The High Court may call for the record of any case which has been decided by any Court subordinate to such High Court and in which no appeal lies thereto, and if such subordinate Court appears

(a) to have exercised a jurisdiction not vested in it by law, or

(b) to have failed to exercise a jurisdiction so vested, or

(c) to have acted in the exercise of its jurisdiction illegally or with material irregularity, the High Court may make such order in the case as it thinks fit;

Provided that where a person makes an application under this subsection, he shall in support of such application, furnish copies of the pleadings, documents and order of the subordinate Court and the High Court shall, except for reasons to be recorded, dispose of such application without call ing for the record of the subordinate Court.

Provided further that such application shall be made within ninety days of the decision of the subordinate Court which shall provide a copy of such decision within three days thereof and the High Court shall dispose of such application within six months,

(2) The District Court may exercise the powers conferred on the High Court by subsection (I) in respect of any case decided by a Court subordinate to such District Court in which no appeal lies and th e amount or value of the subject - matter whereof does not exceed the limits of the appellate jurisdiction of the District Court.

(3) If any application under subsection (1) in respect of a case within the competence of the District Court has been made ei ther to the High Court or the District Court, no further such application shall be made to either of them.

(4) No proceedings in revision shall be entertained by the High Court against an order made under subsection (2) by the District Court.

While interpreting Section 115 of the Code of Civil Procedure, 1908 there can be no cavil that the jurisdiction that has been conferred on this Court by the section is

9 in the nature of a supervisory jurisdiction over a “Court” subordinate to it 2, is discretionary3 and is akin, but not identical, to the prerogative writ of certiorari .4 Whether or not the exercise of such a jurisdiction is only supervisory or would also constitute a right is however of some dispute as while some of the Judgements of the Supreme Court of Pakistan have identified it as supervisory other Judgements of the Supreme Court of Pakistan have considered it to be a right.5 Further, the manner in which the power can be exercised is twofold. Either the High Court can exercise such powers of its own motion 6 or it can exercise such a jurisdiction on an application made by a party, the primary difference being that the former is not limited by time while the latter must be presented within 90 days of the passing of that order or judgement. Under Sub-Section (2) of Section 115 of the Code of Civil Procedure, 1908 the District Judge has been conferred with the same jurisdiction as conferred on the High Court with regard to any Court Subordinate to it i.e., a Civil Judge or a Senior Civil judge

18. Both the jurisdiction of the High Court and the District Judge relate to an order decision in respect of a “case which has been decided”. What is a “case which has been decided” which can be revised under Section 115 of the Code of Civil Procedure, 1908 was considered by a Full Bench of Seve n Judges of this

2 See Muhammad Aslam vs. Munshi Muhammad Behram 1991 SCMR 1971; Evacuee Trust Property Board vs. Muhammad Siddique 1995 SCMR 1748; Muhammad Mian vs. Shamimullah 1995 SCMR 69; Anjum Zafar vs Abbas Aki Shah 2000 SCMR 59; Ch Muhammad Shfi vs. Shamim Khanum 2007 SCMR 838; Mst. Banori vs. Jilani PLD 2010 Supreme Court 1186; Hafeez Ahmed vs. Civil Judge Lahore PLD 2012 Supreme Court 400; Province of Punjab through District Officer Revenue, Rawalpindi vs. Muhammad Sarwar 2014 SCMR 1358; Mandi Hassan alias Mehdi Hussain vs. Muhammad Arif PLD 2015 Supreme Court 137; MFMY Industries Ltd. vs. Federation of Pakistan through Ministry of Commerce 2015 SCMR 1550; Noor Ahmed vs. Province of Punjab 2016 SCMR 2174; Ghulam Qadir vs. Sh. Abdul Wadood PLD 2016 Supreme Court 712; Government of Khyber Pakhtunkhawa vs. Latif ullah Khan 2021 SCMR 829; Muhammad Yousuf Bhindi vs. A.G.E. & Sons (Pvt.) Ltd. PLD 2024 Supreme Court 864

3 See Shahzada Muhammad Umer Beg vs. Sultan Mahmood Khan PLD 1970 Supreme Court 139; ; Muhammad Bashir vs. Province of Punjab 2003 SCMR 83; Suleman vs. Mst. Zeenat Jan and 2 others PLD 2003 Supreme Court 362; Ataullah alias Billa vs. Muhammad Ilyas 2004 SCMR 830; Muhammad Feroze and others vs. Muhammad Jammat Ali 2006 SCMR 1304; Hafeez Ahmed vs. Civil Judge Lahore PLD 2012 Supreme Court 400; Province of Punjab through District Officer Revenue, Rawalpindi vs. Muhammad Sarwar 2014 SCMR 1358; Ghulam Qadir vs. Sh. Abdul Wadood PLD 2016 Supreme Court 712; and Government of Khyber Pakhtunkhawa vs. Latif ullah Khan 2021 SCMR 829; 4 See Manager, Jammu& Kashmir, State Property in Pakistan vs. Khuda Yar PLD 1975 Supreme Court 678; Muhammad Mian vs. Shamimullah 1995 SCMR 69; Muhammad Feroze and others vs. Muhammad Jammat Ali 2006 SCMR 1304; Iqbal Ahmed vs. Managing Director Provincial Urban Development Board, N.E.F.P., Peshawar 2015 SCMR 799 5 See Karamat Hussain and others vs. Muhammad Zaman and others PLD 1987 Supreme Court 139, Mandi Hassan alias Mehdi Hussain vs. Muhammad Arif PLD 2015 Supreme Court 137, Muhammad Yousaf and 3 others vs. Khan Bahadur through Legal Heirs 1992 SCMR 2334 and Mandi Hassan alias Mehdi Hussain vs. Muhammad Arif PLD 2015 Supreme Court 137 6 See Haji Rehmdil vs. The Province of Balochistan 1999 SCMR 1060; Province of Punjab through Collector T.T. Singh and others vs. Muhammad Farooq and others PLD 2010 Supreme Court 582; Mst. Banori vs. Jilani PLD 2010 Supreme Court 1186; Hafeez Ahmad vs. Civil Judge, Lahore PLD 2012 Supreme Court 400; Province of Punjab through District Officer Revenue, Rawalpindi vs. Muhammad Sarwar 2014 SCMR 1358; Muhammad Imran Bashir Malik vs. Amera Khan 2020 CLC 574; Khan Bahadur Khan vs. Khan Malok Khan PLD 2022 Supreme Court 482; Rasool Bux vs. The Province of Sindh through Secretary Revenue Department, Karachi 2025 CLC 1744

10 Court in in the decision reported as S. Zafar Ahmad vs. Abdul Khaliq 7 and in…

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