Law: Qanun-e-Shahadat Order, 1984

Section: 129(e),144,145,146,148

Law: Code Of Civil Procedure, 1908.

Section: XVII,115,151,114,XLVII

Summary In CPLA No.1078-L of 2025 (Munir Ahmad Bhatti v. Mehmood Ahmad Tahir Bhatti etc.), the Supreme Court held that the trial court rightly closed the petitioner’s further cross-examination of PW-1 after seven opportunities and about thirty pages of questioning, as it had become an abuse of process and harassment of the witness. The Court also affirmed that the High Court could, with parties’ consent, structure and limit one final opportunity for cross-examination at a fixed date and time, and that judicial record of such consent carries a strong presumption of correctness which was not rebutted. It further ruled that the High Court’s dismissal of review was proper because no error apparent on the face of the record or other legitimate ground for review under Section 114 and Order XLVII Rule 1 CPC was established.- Core points  Respondent No.1 filed a civil suit for declaration, cancellation of sale deeds, possession and injunction regarding land at Mohlanwal, Lahore; petitioner contested and PW-1 was examined.- Petitioner cross-examined PW-1 on seven different dates over nearly two months, resulting in extensive cross-examination of around thirty pages and multiple adjournments.- Trial court, upon objection that questions were irrelevant, repetitive, scandalous and harassing, held that further cross-examination would be abuse of process and closed petitioner’s right to further cross-examine PW-1.- Lahore High Court, in revision under Section 115 CPC, upheld the trial court’s discretion to regulate proceedings and prevent harassment, but with parties’ consent granted one final, time-bound opportunity to cross-examine PW-1 on a specific date and during court hours.- In review, High Court again declined interference, finding no error apparent on the face of the record and rejecting the petitioner’s allegation that no consent had been given for the limited opportunity.- Supreme Court reaffirmed that cross-examination is not unlimited or unbridled and courts must stop prolonged, irrelevant, scandalous or harassing questioning, relying on Articles 144, 145, 146 and 148 QSO and earlier precedents (Muhammad Shafi, Mir…

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