07/04/2026
A Case Study of Jhika Gali and Kotli Sattian in Light of PLD 2024 Lahore 379
Introduction
Recent incidents in Jhika Gali (Murree) and the broader Kotli Sattian region have once again exposed the fragile relationship between development, environmental mismanagement, and state responsibility in Pakistan. The reported landslides at Jhika Gali, which forced emergency evacuations and rendered homes structurally unsafe, are not isolated occurrences but symptomatic of a deeper governance failure.
These developments must be examined through the jurisprudential lens of PLD 2024 Lahore 379, authored by Mr. Justice Ch. Abdul Aziz, which lays down critical principles regarding environmental protection, administrative responsibility, and citizens’ fundamental rights.
Para of judgement is reproduced as under
“ Such construction is jaw dropping when seen in the context that Murree and Kotli Sattian are situated on fault line/seismic zone, thus their vulnerability to earthquake needs no discussion”
Recent Incidents: A Brief Overview
In April 2026, a significant landslide struck Jhika Gali Chowk, damaging infrastructure, uprooting trees, and causing cracks in residential buildings. Authorities were compelled to order evacuations through mosque announcements as the ground continued to shift, threatening further destruction.
Simultaneously, the Punjab Government has been pursuing an ambitious development plan to transform Kotli Sattian into a tourism hub, including construction projects such as chairlifts, resorts, and road expansion.
The juxtaposition is striking: on one hand, aggressive infrastructural expansion; on the other, ecological instability and risk to human life.
PLD 2024 Lahore 379 — Legal Framework
The judgment in PLD 2024 Lahore 379 is a landmark pronouncement in Pakistani environmental and administrative law. Justice Abdul Aziz emphasizes:
1. Right to Life under Article 9 includes the right to a safe and healthy environment.
2. The State acts as a trustee of natural resources and must ensure sustainable use.
3. Development projects must comply with Environmental Impact Assessments (EIA) and precautionary principles.
4. Authorities may be held accountable for negligence, omission, or regulatory failure leading to environmental harm.
Application to Jhika Gali Incident
Applying the principles of PLD 2024 Lahore 379:
1. Failure of Preventive Regulation
The landslide raises serious questions about whether:
• Proper geological and environmental assessments were conducted prior to the remodeling project.
• Authorities adhered to zoning laws and construction limits in a sensitive hill ecosystem.
Under the judgment, failure to anticipate such risks constitutes administrative negligence.
2. Violation of Fundamental Rights
Residents forced to evacuate their homes due to unsafe conditions may invoke Article 9 (Right to Life) and Article 14 (Dignity of Man).
Justice Abdul Aziz’s reasoning clearly establishes that environmental degradation leading to displacement is a constitutional violation, not merely an administrative lapse.
PLD 2024 Lahore 379 provides a powerful framework to:
• Hold authorities accountable,
• Protect citizens’ fundamental rights,
• And ensure that development does not come at the cost of human safety.
Unless the principles laid down by Justice Abdul Aziz are strictly implemented, the cycle of development-induced disasters will persist, undermining both governance and public trust.
fansAdil Aziz QaziAdil Aziz Qazi AdvocateAdil QaziAdil Qazi Law FirmIslamabad NewssAdil Aziz Qazi - UC 11Malik Ikhlaq Ahmed AwanAnjum Aqeel KhanSyed Yawar AbbasRaja Khurram ShahzadAdv Khan SahifaaRaja Khurram NawazIDI International Dispute Resolution Institute Rizwan Law Associates.Prime Minister’s Youth ProgrammeDr. Tariq Fazal ChaudhryGm Shah AdvJawad Aadil
