Case Details

Citation(s)
2026 SLG 2272 2026 SLD 2272 = 2026 SHC 381
Sindh High Court
C.P No.D-1701 of 2025
Presented By: Mr. Justice Adnan-ul-Karim Memon Mr. Justice Zulfiqar Ali Sangi
Date of hearing and order:- 18.02.2026 Mr. Ali Asadullah Bullo, Advocate for the petitioner. Mr. Malik Altaf Hussain, Advocate for
Respondents No.2 to 8. Mr. Riaz Alam Khan, Advocate for
Respondent No.8. Mr. Muhammad Nasir, Advocate for respondent No.10. Mr. Ali Safdar Depar, A.A.G. Mr. Saleem Khan, Senior Law Officer, CPSP.

(Dr. Maliha Muhammad Ali Hasan Patel

VS

Province of Sindh & others )

Law: Constitution of Pakistan, 1973

Section: 199,4,9,18,25

📌 Summary of Case The petitioner, an FCPS-II Internal Medicine trainee at Abbasi Shaheed Hospital, challenged the hospital's actions of removing her from the duty roster, discontinuing biometric attendance, and pressuring her to resign or change her supervisor without any show-cause notice or disciplinary proceedings. She argued that these actions violated CPSP regulations and her fundamental rights. The Court held that although supervision and discipline fall within the hospital's domain, any action affecting a trainee's continuation in a postgraduate program must follow due process and principles of natural justice. Since no formal termination order existed and the petitioner remained a registered trainee, the Court directed restoration of her training status, processing of a supervisor change according to CPSP rules, and allowed her to complete her residency without unlawful interference. 📌 Sections / Laws Used Article 199 Constitution of Pakistan, 1973 Articles 4, 9, 18, 25 Constitution of Pakistan, 1973 Ordinance XX of 1962 (College of Physicians and Surgeons Pakistan) Pakistan Medical Commission (Enforcement) Regulations, 2021 CPSP Training & Supervisor Guidelines 📌 2-WORD CASE DESCRIPTION Medical Residency Due Process         O R D E R The case of the Petitioner is that she is a qualified medical professional who completed her MBBS from Karachi Medical and Dental College (KMDC) in 2019 and is presently enrolled as a postgraduate trainee in FCPS-II Internal Medicine at Abbasi Shaheed Hospital under the administrative control of Karachi Metropolitan Corporation. It is submitted that she joined the four-year paid residency training programme on 27.01.2023 pursuant to an offer issued by the Director of the hospital and has since diligently performed her clinical, academic, and research responsibilities without any complaint or adverse remarks. However, her supervisor had also approved her research synopsis and certified successful completion of various clinical rotations, which demonstrates her satisfactory performance during the training period. She submits that despite the above, Respondent No.6 repeatedly…
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