Law: Pakistan Penal Code (PPC),1860

Section: 302(b),299(ee),311,338E

Law: Code of Criminal Procedure, 1898

Section: 544-A

Summary  The Lahore High Court (Multan Bench) reviewed Muhammad Safdar’s jail petition after a Trial Court verified a voluntary and genuine compromise between the petitioner and the deceased’s legal heirs. Although Safdar had been convicted for the 2013 murder of Ghulam Qadir and originally sentenced to death (later reduced to life imprisonment), the Court found the prosecution’s evidence had established guilt beyond a reasonable doubt. However, because a valid compromise was effected and the offense predated the 2016 amendments to the Pakistan Penal Code (which expanded the doctrine of fasad-fil-arz), the Court accepted the compromise, converted the jail petition into an appeal, allowed it, and acquitted and ordered the petitioner’s release if not detained elsewhere. Core points Case and parties: Petitioner Muhammad Safdar (convicted for murder of Ghulam Qadir); co-accused Muhammad Amin and Muhammad Ajmal (acquitted). Facts: Incident on 10.12.2013 outside the family home; dispute over 4 marlas of land; complainant/witness Muhammad Akbar (son) identified Safdar firing a licensed repeater, causing a fatal chest/abdomen wound. Trial outcome: Trial Court convicted under section 302(b) PPC, sentenced to death and ordered Rs.100,000 compensation under section 544-A Cr.P.C.; co-accused acquitted. High Court previous appeal: Petitioner's death sentence converted to life imprisonment; conviction maintained (impugned judgment dated 24.03.2022). Petition before current bench: Criminal Misc. Application No.1091/2024 alleging a compromise between petitioner and legal heirs; Trial Court verification sought and received (dated 06.02.2026) confirming compromise voluntary and genuine. Evidence and reasoning upheld: Ocular witness (PW-10 Muhammad Akbar) found reliable and prompt FIR, medical evidence corroborated injury location and weapon; solitary credible ocular testimony is sufficient if confidence-inspiring. Main legal argument for acquittal: Counsel relied on compromise and on pre-Amendment interpretation that section 311 PPC applied only to qisas, not ta'zir. Legislative change considered: Amendments by Act No. XLIII of 2016 broadened…