Case Details

Citation(s)
2026 SLG 4393 = 2026 SLD 4393
Lahore High Court
W.P.No.1185 of 2026
Presented By: (ABHER GUL KHAN) Judge
08.09.2026. Mr. Kamran Ashraf Mughal, Advocate for the petitioner. Mr. Muhammad Nasir Chohan, Addl. Advocate General. Mr. Khalil Ahmed Bhatti, Advocate for respondent No.5.

Mst. Razia Bibi

VERSUS

Additional Sessions Judge, etc.

Law: Code of Criminal Procedure, 1898

Section: 173, 435–439

Law: Police Order, 2002

Section: 155-C

Law: Pakistan Penal Code, 1860

Section: 161, 201, 302

Summary

Case: Constitutional petition against the order dated 17.12.2025 passed by the Additional Sessions Judge, Sheikhupura.

Facts

  • FIR No. 222/2014 dated 04.03.2014 was registered under Section 302 PPC regarding the murder of Muhammad Islam.
  • Police could not trace the culprits and submitted an untraced report.
  • The complainant then filed a private complaint under Sections 302, 201, 161 PPC read with Section 155-C Police Order, 2002.
  • Four accused were summoned in the private complaint on 16.06.2025.
  • During the pendency of the private complaint, the complainant approached the Judicial Magistrate and sought a direction for the police to further investigate the murder case.
  • The Magistrate directed the police to investigate fairly, impartially, honestly and according to law.
  • The petitioner challenged this order through criminal revision.
  • The Additional Sessions Judge dismissed the revision, holding that the Magistrate's order was administrative/supervisory, not judicial, and therefore was not revisable.

Main Legal Issue

Whether a Magistrate's direction to police to conduct investigation fairly and according to law is a judicial order capable of criminal revision.

Court's Finding

No.

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