Case Details

Citation(s)
2026 SLG 1195 2026 SLD 1195 = 2026 LHC 2571
Lahore High Court
Crl. Misc. No.2105-B of 2026
Presented By: (Muhammad Tariq Nadeem) Judge
15.04.2026 Mr. Muhammad Arshad Khawaja, Advocate for the petitioners Ch. Muhammad Sadiq Rehman, Additional Prosecutor General with Bilal S.I. Mr. Muhammad Khan Langah, Advocate for the complainant.

Muhammad Zakariya and another

VERSUS

The State and another

Law: Criminal Procedure Code, 1898

Section: 497(1), 497(2)

Law: Pakistan Penal Code (PPC),1860

Section: 302, 365, 201, 114, 148 & 149

 Summary

The petitioners sought post-arrest bail in a murder case under multiple provisions of PPC.

The Court held that:

  • The case is based primarily on a belated extrajudicial confession, which is weak and unreliable evidence.
  • The incident was unwitnessed, and no direct evidence links the petitioners to the crime.
  • One petitioner was not even nominated in the FIR.
  • The supplementary statement introducing confession was delayed and doubtful.
  • Mere gravity of offence (murder) is not sufficient to deny bail.
  • The case falls within further inquiry (Section 497(2), Cr.P.C.).
  • Investigation is complete; continued detention would be unjustified pre-trial punishment.

 Result: Post-arrest bail granted.

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