15/08/2025
Important Judgements of Supreme Court on Service/ Labour Matters (SCMR 2025).
2025 SCMR 819
(1) Section 9 (1) of the CSA, 1973
(2) Effect of F.R 17 for proforma promotion
(3) Under Section 5 of the STA, 1973, the Tribunal is deemed to be a Civil Court and under Section 8 of the CSA, the Federal Government may frame the rules including ex*****on of decision
(4) If rules are not framed for ex*****on, even then, the Tribunal can execute its judgments in terms of Section 5 of the STA as civil court.
C.P.L.A.44/2022
Ahmed Owais Peerzada v. Principal Secretary
2025 SCMR 532
(1) Point-to-point pay fixation formula
(2) Method of arithmetic rounding off as per IFRS
(3) Article 189 of the Constitution vis-à-vis the doctrine of Stare Decisis and per incuriam
(4) Section 21 of the General Clauses Act, 1897.
Federation of Pakistan through Secretary Finance Division and another v. Abdul Rasheed Memon
2025 SCMR 632
(1) Rule 7 of Punjab Civil Servants (E&D) Rules, 1999
(2) Punjab Estacode, 2013, for Departmental Inquiries
(3) Procedure to be followed by the Inquiry Officer/Committee
(4) Consequences of non-recording evidence and denial to the right of cross-examination
(5) Distinction between discreet & regular inquiry
(6) Purpose of holding de novo inquiry.
C.P.L.A.921-L/2017
Aamir Akbar v. Additional Superintendent of Police
2025 SCMR 656
(1) Rule 3 of Baluchistan Civil Servants (APT) Rules, 1979, laid down the method of promotion, transfer, and initial appointment
(2) The Recruitment Committee cannot act beyond its mandate
(3) It cannot add or subtract any post beyond the sanctioned or advertised posts
(4) The recruitment process was scrapped on valid reasons.
2025 SCMR 453
(1) Rule 2 (4), 3 (a) & (b), 5, 6 & 7 of E&D Rules, 1973
(2) Procedure of inquiry and powers of the Inquiry Officer
(3) Right of cross-examination is a fundamental limb of fair trial
(4) De novo inquiries directed due to serious procedural lapses and irregularities.
C.P.L.A.3463/2021
Tariq Khan v. Additional Director General
2025 SCMR 206
(1) Effect of a judgment of the PST based on a wrongly published version of Section 8(5) of the Punjab Civil Servants Act, 1974
(2) Nobody should become a victim of injustice due to a mistake of the court
(3) The principle of actus curiae neminem gravabit to safeguard individuals from judicial errors.
C.A.2013/2022
Bashir Ahmed Anjum v. Province of Punjab
2025 SCMR 612
(1) Effective implementation of laws relating to disabled/differently-abled persons for protection of their rights
(2) UN Convention on the Rights of Persons with Disabilities
(3) Implementation of Regularization policy
(4) Equal protection without discrimination
(5) Elimination of exploitation.
C.P.L.A.6059/2021
Chairman, NADRA v. Abdul Majeed
2025 SCMR 434
(1) The essence of the upgradation policy is to rationalize the administrative structure for bringing uniformity in the pay scales of similar posts in different organizations
(2) If the Government announces an upgradation policy, it is responsible to enforce it across the board without any discrimination.
C.A.1671/2021
Secretary to the Government of Pakistan, Establishment Division, Islamabad and another v. Muhammad Ahmed Khan and others
2025 SCMR 570
(1) Section 3, 4, 5, 6 & 31 of the Gas (Theft, Control & Recovery) Act, 2016
(2) Interpretation of preamble and statutory provisions
(3) Rule of purposive interpretation
(4) Application of special law and general law.
C.P.L.A.3589/2022
Sui Northern Gas Pipelines Ltd (SNGPL), Islamabad v. M/s S.K. Pvt. Limited
2025 SCMR 415
(1) Applicability of Career Structure for Health Personnel Scheme Ordinance, 2011
(2) Exercise of powers of judicial review
(3) According to intelligible differentia, the persons may be classified into groups and may be treated differently on reasonable basis
(4) No case of discrimination made out.
C.P.L.A.1925/2024
Gul Zarif Khan v. Government of Khyber Pakhtunkhwa
2025 SCMR 489
(1) Misconduct under Punjab Employees Efficiency, Discipline and Accountability Act, 2006
(2) As a fact-finding forum, the Service Tribunal cannot decide the case without touching upon its merits
(3) The willful absence or travelling without approval of ex-Pakistan leave cannot be treated lightly.
C.P.L.A.2330-L/2019 Secretary to Government of the Punjab Law & Parliamentary Affairs Department, Lahore, etc v. Ali Ahmad Khan
2025 SCMR 395
(1) Order IX, Rule 8 & 9 of CPC
(2) The function of the court is to administer substantial justice, every procedure is to be understood as permissible until it is shown to be prohibited by law
(3) Article 202 & 203 of the Constitution (4) Provisions for Case Management may be inserted in C.P.C and Cr.P.C for early disposal of backlog of cases.
C.P.L.A.3597-L/2023
Mrs. Faryal Arif Latif v. Arif Latif
2025 SCMR 353
(1) Distinction between criminal trials and departmental inquiries
(2) Balance of probabilities as standard of proof in inquiries
(3) Violation of due process and natural justice in ex-parte inquiries during incarceration of employee.
C.P.L.A.281-K/2022
The Director General, Intelligence Bureau Government of Pakistan & others v. Babar Ali Solangi
2025 SCMR 14
(1) Sections 2 (c) & (f), 3, 4, 5, 11 & 12 of Punjab Regularization of Service Act, 2018
(2) Regularization of service of contractual employees protected in the Act
(3) Public functionaries are bound to ensure equal treatment under Articles 3, 4, and 38 of the Constitution
(4) Implementation of beneficial statutes.
C.P.L.A.3520/2020
Province of Punjab thr. Chief Secretary, Lahore & others v. Qasim Mehmood & others
2025 SCMR 367
(1) Cancellation of appointment without any notice is a violation of Article 4 & 10-A of the Constitution
(2) Public functionaries must carry out their powers with a judicious approach
(3) Errors in the recruitment process cause severe injustice and perpetuate exploitation
(4) Parameters of review jurisdiction.
C.P.L.A.187-Q/2024
The Govt of Balochistan, through Secretary Energy Deptt, Quetta and another v. Muhammad Yasir
2025 SCMR 298
(1) Section 22 of the Financial Institutions (Recovery of Finances) Ordinance, 2001
(2) Order XXI Rule 89 & 90 of the CPC r/w Section 19 (7) of the FIO (3) Under Article 166 of the Limitation Act, only 30 days’ time is available to apply for setting aside a sale in the ex*****on of a decree.
C.P.L.A.3811/2019
Chaudhry Ghulam Hussain & another v. M/s Saudi Pak Commercial Bank Ltd, Lahore & another
2025 SCMR 40
(1) Rule 5 & 7 of KPK E&D Rules, 2011
(2) Logical reasons for dispensing with the inquiry
(3) Due to departmental lapses (intentional or unintentional) the benefit often goes to the delinquents.
C.P.L.A.531-P/2024
Government of Khyber Pakhtunkhwa through Secretary Elementary & Secondary Education Department, Peshawar and others v. Aurangzeb (decd) through L.Rs
2025 SCMR 235
(1) Effect of non-service of show cause notice and dismissal order in jail
(2) Departmental appeal could be filed from jail if dismissal order is served
(3) When limitation is a mixed question of law & fact.
C.P.L.A.1181-L/2016
Tassaar Hussain v. The Regional Police Officer,etc
2025 SCMR 269
(1) S.O. 15 (4) of Standing Order Ordinance, 1968
(2) Section 25-A and Section 65-B of IRO 1969
(3) Time-barred grievance notice and time-barred grievance petition
(4) Distinction between the Federal and Provincial Industrial Relation Laws
(5) Labour cases must be decided quickly and without delay.
C.P.L.A.2305-L/2016
M.C.B. Ltd through its G.M., Circle Office Rahim Yar Khan now Bahawalpur, etc v. The Punjab Labour Appellate Tribunal, Lahore
2025 SCMR 303
(1) Section 2, clause (xvi) & (###ii), Sections 33, 54, 57 & 58 of IRA, 2012
(2) Regulation 43, 45 & 49 of the NIRC (Procedure and Functions) Regulations, 2016
(3) Article 143 of the Constitution
(4) Doctrine of “Coram non judice”
(5) IRA has an overriding effect on all provincial labour laws
(6) Effect of the amendment in procedural law.
C.P.L.A.1866-L/2023
Muslim Commercial Bank Ltd. v. Punjab Labour Appellate Tribunal through its Chairman, Lahore, etc
2025 SCMR 92
(1) Two show cause notices on similar allegations under the Punjab Police (Efficiency and Discipline) Rules, 1975
(2) Distinction between discreet inquiry, fact-finding, and regular enquiry
(3) The regular inquiry cannot be conducted beyond the allegations mentioned in the show cause notice.
Faisal Ali v. District Police Officer, Gujrat, etc
2025 SCMR 249
(1) Regulation 2(c) & 3 of the State Life Employees (Service) Regulations
(2) Juristic person & perpetual succession
(3) Dominus litis
(4) Misjoinder & non-joinder of a party
(5) Section 99 & Order 1, Rule 10 of C.P.C
(6) Change in the date of birth.
C.P.L.A.2367/2024
The Executive Director (P&GS) State Life, Principal Office Karachi and others v. Muhammad Nisar
2025 SCMR 249
(1) The Notifications of granting age relaxation of up to 15 years in the upper age limit is struck down
(2) Lack of transparency in the appointment process by SPSC is a brutal murder of merit
(3) S.26 of Sindh Civil Servants Act
(4) Rule 12(2) of APT Rules (5) S.13 of SPSC Act & Regulation 0358, 0359 & 0413 of SPSC Regulations, 2006.
C.P.L.A.231/2022
Ayaz and others v. Mustafa Saeed and others
