Sania Shabbir etc VS FOP etc.

JUDGMENT SHEET

IN THE ISLAMABAD HIGH COURT,

ISLAMABAD

WRIT PETITION NO. 3562 of 2025 Ms. Sania Shabbir and others Versus OGRA through its Chairman, etc.

PRESENT:

M/s Hafiz Arfat Ahmed Chaudhary, Qaiser Imam, Tariq Zaman, Kashif Ali Malik, Raja Saif ur Rehman, Raja Khalid Mehmood, Muhammad Umair Baloch, Ali Murad Baloch, Ch. Ali Abbas, Farooq Ahmed, Saifullah, Haris Rehman, Waleed Ahmed, Riyan Ahmed, Barrister Muhammad Usama Rauf, Shujjah Ullah Gondal, Auf-Abdur Rehman, Dina Zainab, Bilal Shahzad, Sohail Mahmood, Main Zahoor Ahmed, Syed Muhammad Bilal Ahmed, Shabbir Ahmed, Wasi-Ullah Khan Sorrani, Ghulam Qasim Bhatti, Raina Zubair, Faisal Nawaz, Malik Qatadah Jamal, Ali Shahryarm Nasir Ahmed, Shafqat Ghafar, Shahryar Nawaz Khan and Nasir Ahmed Abbasi, Advocates, for petitioners, in their respective petitions.

M/s Dr. Muhammad Zakryya Khan, Muhammad Ayaz Khan, Ali Zulqarnain, Shaukat, Muhammad Nasir, Kashif Sajid, Petitioners, in person in W.P. No. 3890/2025.

Mr. Usman Rasool Ghuman, AAG.

Mr. Shabbir Ahmed, AD Legal, DGSE.

Dr. Agha Ghulam Haider, Director Legal, M/O FE&PT. Mr. S.M. Rehan Naqvi, DD, FDE.

M/s Abu Bakar Khan, AD Legal and Asad Ullah Khan, representative of PIMS.

Mr. Shoaib Raza, SO, Establishment.

Mr. Moeen ud Din, Audit Officer, AGPR.

Mr. Muhammad Akmal, AO, Legal M/O Science and Technology. Mr. Muhammad Sohail, AD Litigation-IV, M/O National Health. Ms. Sehrish Fasih, AD, Bureau of Immigration.

Date of Hearing: 09.10.2026.

SHAHRUKH ARJUMAND, J. Through this judgment, this Court shall decide the above-mentioned writ petition along with Writ Petitions listed as Annexure-A as common questions of fact and law

are involved. Through the instant constitutional petition, the petitioners, serving as teaching staff/computer teachers in Federal Government Colleges situated within the Islamabad Capital Territory and functioning under the administrative control of the Federal Directorate of Education (“FDE”), have assailed the letter dated 20.08.2025 issued by the Federal Public Service Commission (“FPSC” or “the Commission”), together with the consequential Office Memorandum dated 22.08.2025 issued by the Establishment Division and the letter dated 04.09.2025 issued by the FDE. Through the impugned correspondence, information concerning employees regularized pursuant to decisions of the Cabinet Sub-Committee on Regularization was sought on a prescribed proforma for the purpose of conducting tests and interviews. The petitioners question the proposed scrutiny of their appointments after their regularization and subsequent continuation in service for more than a decade.

2.The relevant facts, as pleaded by the petitioners, are that they are serving as teaching staff/computer teachers in Federal Government Colleges situated within the Islamabad Capital Territory and functioning under the administrative control of the Federal Directorate of Education (“FDE”). Through the instant petition, they have assailed the letter dated 20.08.2025 issued by the Federal Public Service Commission (“FPSC” or “the Commission”), the consequential Office Memorandum dated 22.08.2025 issued by the Establishment Division, and the letter dated 04.09.2025 issued by the FDE, whereby information concerning employees regularized pursuant to decisions of the Cabinet Sub-Committee on Regularization was sought for the purpose of conducting tests and interviews. According to the petitioners, advertisements for the appointment of computer teachers were published in July 2004 and July 2005, pursuant to which they participated in a competitive selection process and were appointed on a contract basis in projects initiated by the FDE. Their contracts were renewed annually, and the projects were subsequently converted to the non-development phase

in 2009. While they were serving as contractual employees, certain other contract employees approached the Hon’ble Supreme Court of Pakistan through Civil Petition No.42 of 2007 and various Human Rights Cases which were ultimately disposed of through an order dated 19.01.2011. The Hon’ble Supreme Court appreciated the Government’s policy of considering the cases of employees who had served against their respective posts for several years instead of terminating their contracts and accordingly disposed of the listed cases concerning teachers working on a contractual or daily-wage basis in grades above or below Grade 16, except those ad hoc employees or teachers who fell within the definition of a civil servant but had failed to qualify the requisite test, to whom relief could not be granted. The petitioners maintain that their cases were nevertheless not processed for regularization by the concerned authorities following that order. They further refer to the Federal Cabinet’s decision dated 06.01.2010, whereby a Cabinet Sub-Committee on Regularization (“the Sub-Committee”) was constituted under the chairmanship of Syed Khursheed Ahmed Shah, the then Federal Minister. The Sub-Committee formulated criteria for regularization, which were circulated to the concerned Ministries, Divisions and organizations, together with a prescribed proforma, through a letter dated 28.01.2011 issued by the then Ministry of Labour and Manpower. In response, the FDE furnished information concerning the petitioners on the prescribed proforma on 02.03.2011. Subsequently, on 29.06.2011, the Establishment Division submitted a summary to the Prime Minister of Pakistan proposing the regularization, with effect from that date, of contract officers who had completed one year of contractual service or three spells of eighty- nine days by 30.04.2011 in the Ministry of Health, Special Education and Social Welfare/NCCWD/NTD under the CAD Division, and the Ministry of Women Development. The proposal contemplated regularization as a special case, pending approval of the Cabinet, in view of the devolution of those Ministries to the provinces, and

further proposed withdrawal of the concerned Ministries’ and Divisions’ requisitions from the FPSC, if not already withdrawn. According to the petitioners, the relevant proposal was approved by the Prime Minister on 30.06.2011. Meanwhile, the Sub-Committee held successive meetings, and the Commission commenced a selection process pursuant to the Hon’ble Supreme Court’s order in Civil Petition No.42 of 2007. However, through a letter dated 06.08.2011, a senior official of the Capital Administration and Development Division (“CA&DD”) requested the Commission to discontinue that process, referring to the Sub-Committee’s meeting held on 02.08.2011 in which it had been decided that contractual and daily-wage employees of the concerned Ministries, Divisions, attached departments, autonomous bodies and organizations would be regularized in accordance with the policy and criteria prescribed by the Cabinet Committee. In response, the Commission issued a circular dated 08.08.2011 cancelling the interview scheduled at Islamabad from 09.08.2011 to 22.09.2011 for the regularization of daily-wage and contract lecturers in BS-17 and junior teachers in BS-16 serving in different colleges under the FDE. The Sub-Committee thereafter considered the petitioners’ cases in its meeting dated 13.09.2011, the minutes of which were issued on 04.10.2011. The petitioners maintain that their cases were examined and their regularization was recommended following detailed deliberations. Their services were regularized with immediate effect, whereafter the FDE, through a notification stated in the petition to be dated 20.12.2011, posted them to different institutions as regular employees. The petitioners next refer to the judgment dated 13.09.2024 rendered by the Hon’ble Supreme Court in Mohsin Raza Gondal v. Sardar Mehmood and others, reported as 2025 SCMR 104, whereby petitions for leave to appeal arising from the judgment dated 31.01.2023 passed by this Court in Intra-Court Appeal No.514 of 2015 were disposed of. They contend that the said judgment upheld the Division Bench’s decision in the particular controversy before it and did not direct the

Commission to conduct tests and interviews of all employees regularized by the Sub-Committee during 2012–2013; they accordingly characterize the judgment as operating in personam rather than in rem. Thereafter, the Establishment Division issued an Office Memorandum dated 19.03.2025, circulating the judgment to the concerned Ministries and Divisions and requiring further necessary action to ensure its compliance in letter and spirit. The petitioners allege that this communication misconstrued the scope of the judgment by treating it as generally applicable to employees regularized pursuant to the Sub-Committee’s decisions. Subsequently, through the impugned letter dated 20.08.2025 addressed to the Secretary, Establishment Division, the Commission recorded that only two organizations had furnished complete information, while the remaining organizations had either failed to provide the requisite particulars or submitted incomplete information, owing to which tests and interviews could not be conducted in compliance with the Hon’ble Supreme Court’s judgment. Pursuant thereto, the Establishment Division issued the Office Memorandum dated 22.08.2025, forwarding the Commission’s letter and proforma for immediate compliance, whereafter the FDE issued its letter dated 04.09.2025, directing all Area Education Officers to provide the requisite information by 08.09.2025 concerning teaching staff regularized by the Sub-Committee. The petitioners contend that their cases had already undergone scrutiny before the Sub-Committee and that their regularization, continued service for more than a decade, and subsequent judicial proceedings concerning their service benefits had generated a legitimate expectation of remaining in service until superannuation. They therefore question the proposed renewed scrutiny as being without lawful basis and violative of Articles 4, 9, 18 and 25 of the Constitution of the Islamic Republic of Pakistan, 1973, and, asserting the absence of any other efficacious remedy, have invoked the constitutional jurisdiction of this Court.

3.Learned counsel for the petitioners contended that the impugned letter dated 20.08.2025 issued by the Federal Public Service Commission, together with the consequential Office Memorandum dated 22.08.2025 issued by the Establishment Division and the letter dated 04.09.2025 issued by the Federal Directorate of Education, was without lawful authority and sought to reopen a regularization process that had been concluded approximately fourteen years earlier. He submitted that the petitioners had initially been appointed through an advertised, transparent and competitive selection process and that their cases were subsequently examined and approved for regularization by the Cabinet Sub-Committee pursuant to the policy of the Federal Government. According to learned counsel, the resulting regularization conferred upon the petitioners the status of regular employees and created vested and accrued rights which could not be unsettled through subsequent administrative correspondence or made conditional upon their participation in fresh tests and interviews. He maintained that their regularization constituted a past and closed transaction and that their continued service for more than a decade following regularization generated a legitimate expectation of remaining in employment until superannuation. He further submitted that, having accepted and utilized their services over the years, the respondents were estopped from treating them as fresh entrants and disregarding their existing service status.

4.Learned counsel principally questioned the respondents’ reliance upon the judgment of the Hon’ble Supreme Court in Mohsin Raza Gondal v. Sardar Mehmood and others (2025 SCMR 104), contending that the decision was confined to the facts and controversy arising in that case and could not be extended indiscriminately to all employees regularized by the Cabinet Sub-Committee. He submitted that the judgment operated in personam rather than in rem and contained no general direction requiring every such employee to undergo fresh tests and interviews. He argued that the Establishment Division had misconstrued its scope and, by directing a general

scrutiny of previously regularized employees, had assumed a jurisdiction not vested in it. Without prejudice to that submission, learned counsel stated that the judgment was under review before the Hon’ble Supreme Court and advanced the contention that earlier pronouncements of the Supreme Court concerning regularization had not been considered therein. On that basis, he sought to characterize the decision as having been rendered per incuriam. In support of his submissions, learned counsel relied upon Pir Imran Sajid v. Managing Director, Telephone Industries of Pakistan (2015 SCMR 1257), submitting that the Hon’ble Supreme Court had granted relief to employees initially appointed through a transparent process against advertised vacancies, whose contracts had repeatedly been renewed and whose services had been retained for more than twelve years. He referred to the observations reproduced in the petition concerning the permanent nature of the posts, the employer’s continuing need for the employees’ services, their satisfactory performance, and the fact that they had devoted the prime years of their lives to the organization and might have become overage for alternative employment. He maintained that the reasoning of that judgment applied to the petitioners, whose appointments had likewise followed a competitive process and whose regularization had been approved under the Federal Government’s policy. He further relied upon the approval attributed to the then Prime Minister on the summary submitted by the Establishment Division on 29.06.2011, arguing that the Commission could not retrospectively undo the executive approval granted in 2011 or unsettle rights which, according to him, had also received judicial recognition in subsequent service proceedings.

5.Learned counsel further contended that section 11-B, as invoked in the impugned correspondence, had been misapplied. He submitted that the provision concerned appointments made without observance of the prescribed procedure or without fulfilment of the applicable requirements relating to qualifications, experience and age, whereas the petitioners had been recruited transparently after

observance of the prescribed process. He additionally argued that the Commission’s jurisdiction under the provision depended upon a reference by the appointing authority and that, to the petitioners’ knowledge, no such reference concerning their appointments had been made. He therefore maintained that the Commission lacked the requisite jurisdiction to initiate the proposed exercise. According to learned counsel, the reference to section 11-B also indicated that successful candidates might be treated as fresh appointees, thereby prejudicing the petitioners’ previous service, seniority, pay protection and pensionary entitlements. He also submitted that the proposed exercise, in substance, called into question the petitioners’ subsisting regularization without first issuing any show-cause notice or affording them an opportunity of hearing. He characterized this course as contrary to the principles of natural justice and the constitutional guarantee of due process under Article 10-A, and further alleged infringement of the protections contained in Articles 4, 9 and 25 of the Constitution. Emphasizing the practical consequences, learned counsel argued that the petitioners and similarly placed employees had, in certain cases, served for more than twenty years and were approaching retirement; treating them as fresh inductees could jeopardize their pensionary rights and disregard the experience acquired during their service. He further maintained that requiring thousands of serving employees to undergo fresh examinations would disrupt the administrative structure and create uncertainty across the affected organizations. He accordingly prayed that the impugned letter and consequential communications be declared without lawful authority and of no legal effect, that the petitioners’ existing regularized status be protected against a fresh induction process, and that the respondents be restrained from disturbing their accrued service rights, seniority and pay protection.

6.Learned counsel for the respondents, while controverting the submissions advanced on behalf of the petitioners, raised a preliminary objection to the maintainability of the petition under

Article 199 of the Constitution. He submitted that the relief sought concerns the petitioners’ regularization, continuation in service, seniority, pay protection, pensionary benefits and alleged accrued service rights, all of which pertain to their terms and conditions of service and fall within the exclusive jurisdiction of the learned Federal Service Tribunal under Article 212 of the Constitution. Relying upon I.A. Sherwani v. Government of Pakistan (1991 SCMR 1041), he maintained that a service dispute could not be brought within the constitutional jurisdiction of this Court merely by alleging infringement of fundamental rights. He further submitted that the petitioners had themselves previously invoked the jurisdiction of the Tribunal to obtain recognition of their contractual service and consequential benefits and could not now bypass the statutory forum in respect of another controversy concerning their service status. Learned counsel additionally contended that the petition was premature, as the impugned communications merely required the collection and transmission of information for processing the cases of employees regularized through the Cabinet Sub-Committee. He emphasized that no order terminating the petitioners’ services, withdrawing or cancelling their regularization, or adversely affecting their seniority, pay protection, pensionary benefits or continuity of service had been passed. Their apprehensions concerning fresh induction, loss of previous service and deprivation of pension were, according to him, contingent upon future events and did not establish a present legal injury warranting constitutional intervention. He submitted that, should an adverse order ultimately be passed, the affected employee could pursue the remedies available under the governing service laws. He also maintained that the controversy involved disputed questions concerning the petitioners’ initial engagement, subsequent adjustment against regular posts, compliance with recruitment requirements and alleged consent to referral of their cases to the Commission, which required examination of the administrative and judicial record. On the merits, learned counsel

submitted that the Commission was established pursuant to Article 242 of the Constitution and entrusted with statutory functions relating to recruitment to the services of the Federation and civil posts in BS- 16 and above falling within its purview. Referring to section 7(1)(a) of the Federal Public Service Commission Ordinance, 1977, section 5 of the Civil Servants Act, 1973, and rule 10 of the Civil Servants (Appointment, Promotion and Transfer) Rules, 1973, he argued that appointment to such posts required observance of the prescribed process through the Commission. He further relied upon the statutory provision that an appointment would be regarded as having been made on a regular basis only if made in the prescribed manner. According to learned counsel, advertisement of contractual project positions and participation in a departmental selection process did not, by themselves, satisfy the distinct legal requirements for appointment to regular civil posts falling within the Commission’s jurisdiction. He maintained that conversion of a development project to the non- development side likewise did not dispense with those requirements. Learned counsel submitted that the petitioners had initially been engaged in project employment and were subsequently adjusted or regularized against posts of Senior Computer Teacher in BS-17 without undergoing the prescribed selection process through the Commission. The departmental respondents further alleged non- compliance with the applicable formalities concerning recruitment to regular posts, including the relevant advertisement requirements, medical fitness, quota allocation and scrutiny by the FPSC. He maintained that neither the availability of vacant posts nor the issuance of regularization notifications could substitute for compliance with the statutory mode of appointment. In that context, he referred to the departmental account that 1,111 contractual and daily-wage employees had been regularized through the defunct Capital Administration and Development Division on the Sub- Committee’s recommendations, comprising 570 employees in BS-16 and above and 541 employees in BS-1 to BS-15, and contended that

adjustment against available vacancies did not establish the legality of the process adopted.

7.Addressing the authority of the Cabinet Sub-Committee, learned counsel submitted that the Federal Government’s regularization policy issued on 29.08.2008 concerned eligible contractual employees in BS-1 to BS-15 and did not authorize the Sub-Committee to regularize appointments in BS-16 and above in derogation of the Commission’s statutory role. He contended that the Sub-Committee exceeded its mandate, departed from the approved policy and proceeded to recommend regularization beyond its lawful competence. Referring to Articles 240 and 242 of the Constitution and the Rules of Business, 1973, he argued that neither the Prime Minister nor the Federal Cabinet could exercise executive authority contrary to the Constitution, the governing statute or the rules framed thereunder. Consequently, the petitioners’ reliance upon executive approval and the Sub-Committee’s scrutiny could not answer the objection that the legally prescribed selection authority had been bypassed. Learned counsel principally relied upon the judgment dated 13.09.2024 in Mohsin Raza Gondal v. Sardar Mehmood and others (2025 SCMR 104), which, according to the respondents, upheld the judgment dated 31.01.2023 passed by this Court in Intra-Court Appeal No.514 of 2015. He submitted that the Hon’ble Supreme Court had expressly held that the Cabinet Sub-Committee lacked authority to recommend regularization of appointments in BS-16 and above and that recommendations made in excess of that authority were void ab initio. He further emphasized that the judgment rejected protection of such actions under the doctrine of past and closed transactions and upheld referral of the affected cases to the FPSC. According to learned counsel, the petitioners’ regularization rested upon the same mechanism examined in that judgment, and the legal principle declared therein therefore applied to their cases.

8.In response to the contention that Mohsin Raza Gondal was confined to the parties before the Hon’ble Supreme Court, learned counsel submitted that its authoritative interpretation of the governing constitutional and statutory provisions constituted a declaration of law binding under Article 189 of the Constitution. He maintained that the application of that principle to similarly situated employees did not depend upon their having been parties to the earlier proceedings. He also referred to the opinion obtained by the Establishment Division from the Law and Justice Division under rule 14 of the Rules of Business, 1973, which treated the judgment as having general applicability beyond the individual litigants. He accordingly disputed the petitioners’ attempt to avoid its application by characterizing it as a judgment in personam or as having been rendered per incuriam. In further support, he relied upon Shahid Pervaiz v. Ejaz Ahmad and others (2017 SCMR 206), particularly the observations reproduced in the comments concerning the binding effect of the Supreme Court’s declarations of law and the absence of protection for benefits founded upon an unlawful exercise of authority. Learned counsel further contended that the earlier proceedings in Civil Petition No.42 of 2007 supported, rather than excluded, scrutiny by the Commission. According to the departmental respondents, the relevant proceedings contemplated referral to the FPSC of cases concerning contractual and daily-wage teachers in BS-16 and above who had completed more than three years of service, and cases were accordingly forwarded against 287 available posts, with the remaining cases to be referred upon availability of vacancies. He maintained that the relevant order had not been recalled and that the Sub-Committee subsequently intervened to procure withdrawal of cases already sent to the Commission and undertake regularization itself. He also relied upon the respondents’ assertion that the petitioners had consented to referral of their cases to the FPSC, while submitting that any dispute concerning the scope of that consent required examination of the underlying record. He further referred to the later proceedings arising

from Intra-Court Appeal No.325 of 2014, in which cases were considered by a committee headed by Mr. Haseeb Athar in the light of the 2008 policy, and maintained that those proceedings did not confer an unrestricted entitlement to regularization outside the applicable policy and statutory requirements.

9.With regard to the plea of vested rights, legitimate expectation and estoppel, learned counsel submitted that an appointment or regularization effected without lawful authority could not acquire validity merely through prolonged continuation. He argued that the passage of approximately fourteen years, the receipt of service benefits and the employer’s continued acceptance of work could not confer upon the Sub-Committee a jurisdiction which it did not possess when making its recommendations. He maintained that the doctrines invoked by the petitioners could not require the respondents to perpetuate a mode of appointment declared unlawful by the Hon’ble Supreme Court. According to him, the petitioners’ assertion of permanent status presupposed a legally valid regular appointment, whereas the very foundation of their regularization remained subject to the statutory requirements identified in Mohsin Raza Gondal. He further submitted that the recognition of particular service benefits in earlier proceedings did not justify obstructing the present process undertaken to examine conformity with the prescribed mode of appointment. Learned counsel submitted that section 11-B of the Civil Servants Act, 1973 expressly provided a mechanism for examining appointments made without observance of the prescribed procedure or fulfilment of the stipulated qualifications, experience and age requirements. Under that provision, the appointing authority could refer a case to the Commission for determination of the employee’s fitness to hold the existing post or another post compatible with his or her qualifications and experience. He also relied upon the FPSC (Functions) Rules governing the Commission’s examination of persons whose appointments had not complied with the prescribed requirements. According to learned counsel, the proposed scrutiny

was therefore founded upon an existing statutory mechanism and did not constitute an unauthorized assumption of power by the Commission. He maintained that seeking particulars from the concerned departments was a step towards processing the affected cases and could not itself be equated with an order withdrawing regularization or terminating employment.

10.Answering the objection concerning absence of a show-cause notice, learned counsel referred to the safeguard contained in section 11-B requiring a reasonable opportunity of showing cause where termination was proposed in the light of the Commission’s advice. He submitted that the petitioners were challenging preliminary information-gathering communications at a stage when no such termination order had been proposed or passed against them. Their allegation that the impugned correspondence had already nullified their regularization was therefore disputed by the respondents. He further maintained that the consequences of any appointment made on the Commission’s advice, including its treatment as a fresh appointment and determination of seniority, were matters governed by the statute and the applicable rules, and apprehension of those consequences could not furnish a basis for preventing the statutory process altogether.

11.Lastly, learned counsel submitted that the impugned correspondence formed part of a coordinated effort to implement the Hon’ble Supreme Court’s judgment. He explained that, after obtaining the Law and Justice Division’s opinion, the Establishment Division issued its Office Memorandum dated 19.03.2025 directing the concerned Ministries, Divisions and organizations to ensure compliance. The Commission’s letter dated 20.08.2025, the Establishment Division’s consequential communication dated 22.08.2025 and the FDE’s letter dated 04.09.2025 were issued in furtherance of that exercise. He maintained that the respondents were giving effect to the governing law and binding judicial

pronouncement, and that the petitioners had established neither a present adverse order nor a lawful entitlement to exemption from scrutiny. He accordingly prayed for dismissal of the petition on the grounds of non-maintainability, prematurity and absence of merit.

12.I have heard the arguments advanced by learned counsel for the parties and have examined the record placed before this Court, including the impugned communications and the comments filed by the respondents. The respective submissions have been considered in the light of the statutory provisions and judicial pronouncements relied upon by the parties. The controversy principally concerns the legality of subjecting the petitioners’ appointments to scrutiny by the Federal Public Service Commission notwithstanding their earlier regularization and prolonged continuation in service. The central issue around which this litigation revolves is whether such regularization constitutes a past and closed transaction immune from subsequent scrutiny, or whether an action lacking lawful authority at its inception remains open to examination despite the passage of time and the service benefits subsequently enjoyed under it.

13.The contention that the judgment in Mohsin Raza Gondal v. Sardar Mehmood and others (2025 SCMR 104) is confined to the persons who were parties to those proceedings requires examination of the nature of the controversy decided and the legal foundation of the decision. The reach of a judgment cannot be determined merely by identifying the litigants named in its title or by reading its concluding order in isolation. A distinction must be maintained between the adjudication of the particular parties’ claims and the declaration of law upon which that adjudication rests.

14.In the present context, the distinction between a judgment in rem and a judgment in personam must also be understood with precision. In its strict sense, a judgment in rem conclusively determines a status or legal condition against the world, whereas a judgment in personam determines rights and obligations between

particular parties. The binding force of precedent is a related but distinct concept. A decision need not constitute a judgment in rem in that strict sense before its ratio decidendi becomes applicable beyond the immediate litigants. Consequently, the petitioners’ contention cannot succeed merely by attaching the description “in personam” to the ultimate order in Mohsin Raza Gondal. The decisive inquiry is whether the Hon’ble Supreme Court confined its reasoning to an individual factual defect or declared a principle concerning the legal competence of the Cabinet Sub-Committee and the validity of the mode of regularization employed by it. A reading of paragraph 13 demonstrates that the Hon’ble Supreme Court addressed the latter question. Its conclusion was founded upon the constitutional and statutory limits of executive authority and the absence of lawful competence in the Cabinet Sub-Committee to recommend regularization of appointments in BS-16 and above. The Court did not merely determine that a particular employee lacked a qualification or that an isolated notification was defective. It examined the authority of the body through which regularization had been obtained and held that recommendations made by that body for appointments in the specified grades were void ab initio and without lawful authority. The reasoning thus concerns a common legal foundation capable of recurring across departments and organizations. Where another employee derives the claimed regular status from the same mechanism, in a post governed by the same statutory requirements, the question of competence does not acquire a different answer merely because that employee was not named in the earlier litigation. The declaration concerning the Sub-Committee’s lack of authority formed an essential part of the decision. It supplied the legal basis for rejecting the plea of a past and closed transaction and for sustaining referral of the affected cases to the Federal Public Service Commission. Paragraph 16 reinforces that connection by treating referral to the Commission for determination of fitness and eligibility under the law as the relief already extended to the employees

concerned. The conclusion in paragraph 17 must therefore be read together with that reasoning. The refusal of leave followed a reasoned examination of the governing law; it was not an unexplained disposal from which no legal principle could be identified. The principle relevant to the present controversy is accordingly ascertainable from the judgment itself.

15.Article 189 of the Constitution supplies the domestic foundation for applying that principle. A decision of the Hon’ble Supreme Court, to the extent that it decides a question of law or is based upon or enunciates a principle of law, binds the other courts within the constitutional framework. That obligation is not conditioned upon identity of parties between the earlier and subsequent proceedings. If it were otherwise, the authoritative interpretation of a statutory requirement would cease to govern whenever a different employee or department appeared before the Court. The law governing the competence of a public body would then vary according to the identity of the beneficiary, although the source and limits of the body’s power remained unchanged. Such an approach would defeat the purpose of binding precedent and permit a statutory requirement to be applied selectively. The national jurisprudential foundation is also reflected in Farhat Azeem v. Waheed Rasool,,etc. (PLD 2000 SC 18) as under: -

“8. The rule of interpretation of the law laid down by the High Courts and the Supreme Court in criminal cases is that when two varying precedents are available on a particular point, the one most relevant and applicable to the facts and circumstances of the case and delivered by a larger Bench should be followed. In this context, we may advantageously refer to Sikandar A. Karim v. The State 1995 SCMR 387 wherein it was laid down that: "The decision of Supreme Court, in so far it decides a question of law or is based upon or enunciates a principle of law is binding on all Courts in Pakistan. The decisions on questions of laws or enunciation of principles of law are the generalization of such questions and principles. There can be no generalization of the facts and circumstances of any case. The facts and circumstances of each case are peculiar to that case and, therefore, provide no guidance in the other cases. On the other hand, the generalized principles of law or generalized

enunciation of principles of law govern all those which fall within such generalization."

We do not think that there is hardly a need for reiteration that the Supreme Court is the highest judicial forum in the country, it has to interpret the law while hearing appeals from the judgments of the High Court and the subordinate judiciary. Invariably such matters are considered by more than one Judges having long experience and thrash out the proposition brought before them in the light of the chain of judgments rendered on the controversy in issue and ensure that continuity of law is maintained as it is essential for good judicial administration. The subordinate judiciary should always give its utmost respect, regard and consideration to the judgments, decrees, directions and orders of the Supreme Court, for, it is necessary apart from the binding nature of the same for maintaining discipline in all ranks of the judiciary. When the Supreme Court itself gives due consideration to the earlier decisions rendered by it we wonder why the subordinate judiciary in Pakistan should turn a deaf ear to the judgments, awards, findings or observations of the Supreme Court. The Courts and authorities subordinate to the Supreme Court are under legal obligation to follow the law laid down by it, and if they consider that the case-law cited before them is not relevant or applicable to the facts and circumstances of the case they are dealing with, then they should distinguish it with reasons showing application of mind by them. This exercise would enable the party citing the case-law to understand as to why the precedents relied upon by it was not followed.”

16.The material reproduced in the respondents’ comments emphasizes that a deliberate pronouncement settling a question of law constitutes the law declared by the Hon’ble Supreme Court and cannot be reduced to a proposition applicable only between the named parties. In the present case, however, it is unnecessary to derive the governing principle solely from that earlier authority: Mohsin Raza Gondal itself expressly determines the competence of the Cabinet Sub-Committee and rejects the protection claimed for its unlawful exercise of authority. Those conclusions directly address the legal premise upon which the petitioners seek exemption from scrutiny.

17.The broader operation of that declaration is further apparent from the nature of the power under consideration. A Cabinet Sub- Committee’s competence originates in the governing constitutional, statutory and administrative framework; it does not originate in the length of service of the individual benefiting from its recommendation. If the Sub-Committee lacked the authority to bypass

the prescribed selection mechanism in one case, prolonged service cannot supply that authority in another materially identical case. The relevant comparison is therefore between the legal sources and procedures of the respective appointments, rather than between the names of the employees or the dates on which their petitions were instituted. Subject to verification that the posts and mode of regularization fall within the category addressed by the judgment, the declaration applies generally to the affected class. Comparative Indian jurisprudence assists in explaining this distinction. In State of Uttar Pradesh v. Arvind Kumar Srivastava ((2015) 1 SCC 347), the Supreme Court of India distinguished between relief confined to particular litigants and judgments intended to operate for similarly situated employees generally. Its discussion recognizes that decisions concerning a common policy or scheme may carry an application extending beyond those who approached the Court. The authority concerned must examine the judgment’s intended reach rather than assume that non-participation in the litigation necessarily excludes its application.

“22. The legal principles which emerge from the reading of the aforesaid judgments, cited both by the appellants as well as the respondents, can be summed up as under.

22.1 The normal rule is that when a particular set of employees is given relief by the court, all other identically situated persons need to be treated alike by extending that benefit. Not doing so would amount to discrimination and would be violative of Article 14 of the Constitution of India. This principle needs to be applied in service matters more emphatically as the service jurisprudence evolved by this Court from time to time postulates that all similarly situated persons should be treated similarly. Therefore, the normal rule would be that merely because other similarly situated persons did not approach the Court earlier, they are not to be treated differently.

22.3 However, this exception may not apply in those cases where the judgment pronounced by the court was judgment in rem with intention to give benefit to all similarly situated persons, whether they approached the court or not. With such a pronouncement the obligation is cast upon the authorities to itself extend the benefit thereof to all similarly situated persons. Such a situation can occur when the subject-matter of the decision touches upon the policy matters, like scheme of regularization and the like (see K.C Sharma v. Union of India (1997) 6 SCC 721). On the other hand, if the judgment of the court was in personam holding that

benefit of the said judgment shall accrue to the parties before the court and such an intention is stated expressly in the judgment or it can be impliedly found out from the tenor and language of the judgment, those who want to get the benefit of the said judgment extended to them shall have to satisfy that their petition does not suffer from either laches and delays or acquiescence.”

18.An analogous distinction is evident in the United Kingdom Supreme Court’s decision in R (UNISON) v. Lord Chancellor [2017] UKSC 51. There, the Court examined the legality of an employment tribunal fees order and held that the order was unlawful from its inception and had to be quashed. The legal conclusion concerned the validity of the governing measure, rather than a personal exemption available only to the applicant that challenged it. The comparison illustrates that a public-law determination concerning the legality of a common measure may have consequences beyond the immediate litigants. It does not establish that every service judgment is technically a judgment in rem, but supports examining the subject of the declaration and the measure or mechanism whose legality has been determined.

19.In that sense, the declaration in Mohsin Raza Gondal operates generally upon the mode of regularization examined therein. Its application cannot reasonably be confined to selected beneficiaries while preserving the same legally defective mechanism for others governed by identical provisions. The petitioners’ construction would produce precisely that result: the Sub-Committee would lack authority in relation to the earlier litigants but be treated as possessing it in relation to employees whose cases had not yet reached the Court. Neither the legal source of the Sub-Committee’s power nor the statutory role of the Commission supports such a distinction. The judgment therefore has an operation in rem in the broader public-law sense concerning the invalidity of the common mechanism, while its ratio binds as a declaration of law under Article 189. That general application must nevertheless be distinguished from an automatic cancellation of every individual appointment. Applying the declared

law requires identification of the employee’s post, the applicable recruitment provisions, the source of the regularization and any legally material distinction. Likewise, an individual order concerning appointment, termination, seniority or other service consequences must be made by the competent authority through the procedure prescribed by law. The judgment removes the asserted legal immunity of the Sub-Committee’s mechanism; it does not dispense with the statutory safeguards governing the subsequent treatment of individual employees. The respondents’ collection of information and proposed processing of cases must be understood within that distinction. The earlier adjudications concerning the petitioners’ pay protection, pensionary benefits and recognition of contractual service also require examination according to the issues actually decided. Finality attaches to an adjudication within its proper scope; it cannot be assumed that a decision granting specified service benefits necessarily determined the Sub-Committee’s competence or conferred an exemption from the Commission’s statutory scrutiny. Equally, a subsisting judicial order cannot simply be disregarded by an administrative authority. The relevant orders must therefore be respected and their scope examined when individual consequences are considered. Their existence does not, without an adjudication of the present question, establish that the petitioners’ mode of regularization stands outside the declaration in Mohsin Raza Gondal.

20.The principle may be illustrated by a simple example. Suppose the governing law entrusts selection for a particular category of public posts to a statutory commission, but an executive committee, possessing no authority to substitute itself for that commission, recommends the appointment of several persons to those posts. Upon a challenge concerning one such appointment, the Court determines that the committee lacked the requisite legal authority. Although the individual order before the Court concerns a particular appointee, the declaration concerning the committee’s competence necessarily governs other appointments made through the same mechanism under

identical statutory provisions. Another beneficiary cannot avoid the application of that principle merely by asserting that he was not a party to the earlier proceedings, that his appointment was notified separately, or that he has continued in service for many years. Those circumstances do not alter the legal limits of the committee’s power. To accept such a distinction would mean that the same committee possessed and lacked the same authority under the same law, depending solely upon the identity of the beneficiary—a conclusion incompatible with consistent application of the law. Nevertheless, the general declaration does not dispense with examination of each employee’s record or the procedure prescribed for any consequential order. An employee may establish that his appointment was made through the competent commission, rested upon a separate lawful source, or is otherwise materially distinguishable. The declaration governs the common question of authority; the individual record determines whether a particular appointment falls within it. Likewise, prolonged service may require consideration when determining the consequences permitted by law, but the passage of time cannot itself confer upon the committee an authority which it never possessed.

21.Accordingly, the plea that Mohsin Raza Gondal has no application because the present petitioners were not parties to it is untenable. The Hon’ble Supreme Court determined a question concerning the competence of the Cabinet Sub-Committee and the legality of regularization in BS-16 and above through its recommendations. That declaration governs materially similar cases and cannot be confined by reference to the individual identities of the earlier litigants. The respondents are therefore entitled to examine whether the petitioners’ appointments fall within the category addressed by the judgment and to proceed under the applicable statutory framework. The claim of a past and closed transaction cannot furnish a threshold exemption from that examination when the very source of the claimed regularization is the mechanism declared to be without lawful authority.

22.The next question is whether regularization founded upon recommendations declared by the Hon’ble Supreme Court to be void ab initio can nevertheless acquire protection as a “past and closed transaction.” The answer requires a distinction between the completion of an administrative process and the legal finality claimed for its outcome. An administrative process may have concluded: recommendations may have been accepted, notifications issued, employees posted and benefits extended. Those circumstances establish that the decision was implemented. They do not, without more, establish that the authority initiating the process possessed the power which the law required it to exercise. Completion concerns what occurred; legality concerns whether it could lawfully occur. The former cannot, by itself, supply the latter. The doctrine of past and closed transactions serves the important purpose of securing stability in legal relations. The law recognizes that settled affairs cannot remain indefinitely exposed to disturbance and that persons may arrange their lives in reliance upon decisions which have attained legally recognized finality. However, the protection claimed must be examined within the governing statutory framework and the binding law applicable to the transaction. The expression “past and closed” is not a formula by which every implemented administrative decision becomes immune from examination. In particular, where the precise legal foundation of a transaction has been declared to be without lawful authority, the mere fact that its implementation occurred in the past cannot establish the immunity asserted for it.

23.The essential difficulty in the petitioners’ argument is that it treats the consequence of the Sub-Committee’s recommendation as capable of validating the recommendation itself. Regularization is said to be protected because a notification was issued; the notification is said to have created vested rights because regularization was granted; and those rights are then invoked to prevent examination of the authority under which regularization occurred. This reasoning assumes the very proposition which requires determination. Before

the resulting status can be relied upon as an answer to scrutiny, the lawful source of that status must be identified. A benefit cannot establish its own legal foundation merely because it has been enjoyed. Where a recommendation is only advisory and the final decision rests upon an independent statutory power, the legality of the final decision must be examined by reference to that power and the conditions governing its exercise. It would therefore be inaccurate to hold that every administrative act following an invalid recommendation necessarily fails, irrespective of its independent legal basis. The position is different, however, where the recommendation supplies the very mechanism through which a mandatory statutory process is displaced. In such a case, the subsequent notification does not, merely by its issuance, sever the connection with the original defect. The relevant inquiry remains whether the competent authority exercised a legally available power in the prescribed manner, or merely implemented a recommendation which could not lawfully authorize the departure concerned.

24.This distinction is particularly significant in public employment. A regularization notification records an administrative decision; it does not constitute an independent source of recruitment power. Where the law prescribes selection through a statutory Commission, compliance must be established or a legally applicable exception identified. The use of the word “regularized” cannot itself establish that the prescribed requirements have been satisfied. Otherwise, the mandatory recruitment framework could be displaced through the simple expedient of issuing a notification describing an appointment as regular. The statutory safeguard would then depend upon the terminology chosen by the very authority whose compliance with it was in question. Nor does the passage of time resolve that difficulty. If an authority lacked the power to substitute its recommendation for the prescribed selection process when the recommendation was made, the expiry of ten or fourteen years cannot confer that power retrospectively. Time may alter the circumstances

of an employee, deepen reliance upon continued employment and make the consequences of corrective action more serious. It cannot alter the statutory distribution of authority under which the original decision was taken. A legally effective validation, where available, must proceed from a competent source and comply with the law. Administrative silence, repeated recognition and continued payment of benefits do not, by themselves, constitute such validation.

25.The contrary approach would produce an untenable consequence. An unauthorized regularization examined promptly would remain subject to the law, while an identical regularization left unexamined for a sufficient period would become immune from the same law. The difference would arise neither from a lawful exercise of power nor from a valid curative measure, but from the duration of administrative inaction. Such a proposition would allow the persistence of a departure from the prescribed process to become the justification for preserving it. In public employment, it would also place those who obtained entry through an unauthorized mechanism beyond scrutiny while requiring other citizens to satisfy the statutory conditions for appointment. The doctrine cannot be applied in a manner which converts delay into a substitute for the authority and procedure prescribed by law.

26.The present controversy is, moreover, governed by a direct pronouncement of the Hon’ble Supreme Court. In Mohsin Raza Gondal v. Sardar Mehmood and others (2025 SCMR 104), the Court examined the competence of the Cabinet Sub-Committee in relation to regularization in BS-16 and above. Paragraph 13 declares that the Sub-Committee lacked the requisite authority and that its recommendations for such regularization were void ab initio and without lawful authority. The Court then expressly addressed the claimed protection of a past and closed transaction and rejected its availability for an action possessing that legal character. The connection between the two conclusions is decisive: the plea of

closure could not preserve the arrangement because the authority necessary to sustain its legal foundation was absent. Consequently, the present plea cannot be examined as though the Hon’ble Supreme Court had determined the Sub-Committee’s competence while leaving the effect of the past-and-closed-transaction argument unresolved. The judgment addresses both questions. Its reasoning does not merely permit scrutiny despite the age of the transaction; it explains why elapsed time cannot provide the asserted protection where the transaction rests upon an exercise of authority declared to be unlawful. For materially similar cases, that declaration is binding under Article 189 of the Constitution. This Court cannot recognize the same mechanism as immune from examination on the ground which the Hon’ble Supreme Court expressly rejected. The petitioners’ reliance upon the conclusion of the regularization process approximately fourteen years earlier does not answer that declaration. Their case, as presented, places the Sub-Committee’s consideration and recommendation at the centre of the regularization subsequently notified in their favour. Accordingly, the relevant question is whether their regularization rests upon that mechanism under the recruitment provisions addressed in Mohsin Raza Gondal, or upon some independent and legally sufficient source of authority. If it rests upon the former, the date of the notification and the duration of subsequent service do not constitute a material distinction concerning the Sub- Committee’s competence. A recommendation does not acquire a different legal character merely because its implementation occurred earlier or because its beneficiary served for a longer period.

27.Likewise, the asserted transparency of the petitioners’ original contractual recruitment requires examination in relation to the appointment now claimed. An advertised and competitive process for contractual engagement may be relevant to their initial recruitment, qualifications and experience. It does not necessarily establish compliance with the procedure prescribed for appointment to a regular civil post within the Commission’s purview. The two processes

cannot be treated as interchangeable without reference to the applicable law. The question is whether the initial selection lawfully satisfied the requirements for the subsequent regular appointment, or whether regularization displaced a further statutory requirement which remained applicable. The plea of a past and closed transaction cannot prevent that question from being examined. The executive approvals relied upon must be considered on the same basis. The constitutional position of the approving authority does not dispense with identification of the legal power exercised or observance of its limits. Indeed, the reasoning reproduced from Mohsin Raza Gondal expressly emphasizes that the Prime Minister and the Federal Cabinet must act within the Constitution, statutory law and rules. An approval may therefore be relevant to the administrative history, but its existence alone cannot establish that a mandatory recruitment requirement was lawfully displaced. Any contention that a particular approval supplied an independent lawful basis must be tested against the relevant provisions; it cannot be accepted solely because the resulting arrangement remained operative for many years.

28.The petitioners’ lengthy service and the consequences they apprehend deserve careful consideration at the appropriate stage. Employees who have served for many years may face substantial hardship if their service position is altered near retirement. Those circumstances are relevant to the exercise of any discretion available under the law and to the observance of procedural safeguards. They cannot, however, establish the Sub-Committee’s competence or create a right to prevent examination altogether. The distinction is between protection against an unlawful consequential order and immunity from a lawful inquiry. The former must be secured through the applicable statutory process; the latter does not follow merely from prolonged service under the challenged mechanism.

29.In this regard, section 11-B of the Civil Servants Act, 1973, is significant because it provides a statutory framework for examining

appointments made without observance of the prescribed procedure or requirements. Its operation must conform to its terms, including the requirement of a reference by the appointing authority and the safeguards applicable to a proposed termination. Whether those requirements have been met in an individual case remains open to examination. Their existence nevertheless demonstrates why rejection of the past-and-closed-transaction plea does not amount to dispensing with lawful procedure. The employee’s individual position must be considered through the statutory framework; the finality of the Sub- Committee’s recommendation cannot itself displace that framework.

30.The impugned collection of information and proposed processing of cases must therefore be assessed according to their actual legal effect. On the respondents’ stated position that no order cancelling regularization, terminating service or withdrawing service benefits has yet been passed, the petitioners seek to prevent examination before any individual consequence has been determined. Their plea would thus operate as a threshold exemption from scrutiny. That exemption cannot be founded upon the age of a regularization whose asserted source is the mechanism declared by the Hon’ble Supreme Court to be without lawful authority. Any material distinction, independent lawful basis or protection arising from a subsisting judicial order must be considered when the relevant case is examined.

31.Accordingly, the fact that the Sub-Committee’s recommendations were implemented and remained operative does not establish that the resulting regularization became a past and closed transaction protected against the examination contemplated by law. Where the recommendations constitute its operative legal foundation, the declaration in Mohsin Raza Gondal answers the claimed immunity. The petitioners may invoke the statutory safeguards governing their individual cases and demonstrate any legally material distinction. They cannot establish an exemption from scrutiny merely

by relying upon the continued enjoyment of a status derived from the very mechanism whose authority the Hon’ble Supreme Court has rejected. The passage of time may bear upon the consequences permitted by law; it cannot furnish the missing authority upon which the claimed regularization depends.

32.In view of the foregoing discussion, the petitioners have failed to establish any lawful basis for exemption from the scrutiny contemplated by the applicable statutory framework and the law declared by the Hon’ble Supreme Court in Mohsin Raza Gondal v. Sardar Mehmood and others (2025 SCMR 104). The instant petition as well as writ petitions listed in Annexure-A are, accordingly, DISMISSED. Nevertheless, this Court is mindful that the petitioners have devoted many years; in several instances extending over two decades, to public service, and that some are approaching superannuation. The competent authorities shall, therefore, examine their individual cases with due care and sensitivity, observe all statutory safeguards, respect subsisting judicial orders, and give due consideration, to the extent permissible under the law, to their length of service and the implications for their retirement benefits. These observations do not confer exemption from lawful scrutiny, but require that any consequential decision be taken fairly, through the prescribed procedure and with proper regard to the circumstances of each employee. No order as to costs.

33.Notwithstanding the dismissal of these petitions, in Writ Petition No.1145 of 2026 & 1371 of 2026, titled Shakeel Arshad v. Federation of Pakistan, the respondents shall ensure payment of any outstanding salary to the petitioner for the period during which he actually performed his duties pursuant to the restraining orders passed by this Court. Such payment shall be confined to the services actually rendered during the subsistence of those orders and shall not, by itself, confer any right to regularization or continued employment. Criminal Original No. 218/2026 is disposed of accordingly.

34.The office is directed to place a true copy of this judgment in all the cases, except W.P. No. 3562/2025, mentioned in Annexure-A.

(SHAHRUKH ARJUMAND)

JUDGE

Approved For Reporting.

JUDGE

Tanveer Ahmed/*

Annexure-A

S.# Case No. Title Club Status 1 W.P. 1561/2018 Service Qua Mehboob Hussain- VS -FOP Connected Warranto (SB) & others 2 W.P. 3493/2025 Service Samina Yasmeen etc- VS - Connected Regularization (SB) FOP etc.

3 W.P. 3562/2025 Service Sania Shabbir etc- VS -FOP Main Regularization (SB) etc.

4 W.P. 3631/2025 Service Azad Ali Korai etc. - VS - Connected Regularization (SB) FOP etc.

5 W.P. 3676/2025 Service Gulnaz Azim Bhatti etc- VS - Connected Regularization (SB) FOP etc.

6 W.P. 3652/2025 Service Dr. Sharjeel Zaheer etc- VS Connected Regularization (SB) -FOP etc.

7 W.P. 3758/2025 Service Dr. Iram Naveed etc. - VS - Connected Regularization (SB) FOP etc.

8 W.P. 4052/2025 Service Jangrez Khan- VS -FOP etc. Connected Regularization (SB) 9 W.P. 3701/2025 Service Syed Arbah Shah etc- VS - Connected Regularization (SB) FOP etc.

10 W.P. 3820/2025 Service Muhammad Waqar ur Connected Regularization (SB) Rehman etc. - VS -FOP etc.

11 W.P. 3765/2025 Service Muhammad Imran- VS -FOP Connected Regularization (SB) etc.

12 W.P. 3808/2025 Service Shabab Aliya Kazmi- VS - Connected Regularization (SB) FOP etc.

13 W.P. 3825/2025 Misc. Other M/s Lubna Shakir etc- VS - Connected (SB) FDE etc 14 W.P. 3834/2025 Service Mst Munazza Mastoor etc- Connected Regularization (SB) VS -FDE etc 15 W.P. 3890/2025 Service Dr. Muhammad Zakriya Connected Regularization (SB) Khan etc- VS -FOP etc.

16 W.P. 4059/2025 Service Dr. Allah Baksh Awan etc- Connected Regularization (SB) VS -FOP etc.

17 W.P. 3913/2025 Misc. Other Dr Robina Soomro etc- VS - Connected (SB) FOP etc.

18 W.P. 3912/2025 Service Dr. Noor Zaman etc- VS - Connected Regularization (SB) Fop etc 19 W.P. 3911/2025 Service Dr Rehana Noor etc- VS - Connected Regularization (SB) Fop etc 20 W.P. 3914/2025 Service Dr. Yousaf Ali etc- VS -FOP Connected Regularization (SB) etc.

21 W.P. 3903/2025 Service Shahzadi Begum etc. - VS - Connected Regularization (SB) FOP etc.

22 W.P. 3941/2025 Misc. Other Imtiaz Ahmed- VS -FOP etc. Connected

(SB)

23 W.P. 3940/2025 Service Fazal Muhammad - VS - Connected Regularization (SB) FOP etc.

24 W.P. 3977/2025 Service Khizar Hayat etc- VS -FOP Connected Regularization (SB) etc.

25 W.P. 4046/2025 Service Mst. Saba Ahmed etc- VS - Connected Regularization (SB) FOP etc.

26 W.P. 4160/2025 Service Ashfaque Hussain Chandio Connected Other (SB) etc. - VS -FOP etc.

27 W.P. 4234/2025 Service M/s Sumbla Hussain- VS - Connected Regularization (SB) FDE through its DG etc. 28 W.P. 4317/2025 Service Dr. Shazia Asghar - VS - Connected Regularization (SB) FOP etc.

29 W.P. 4294/2025 Service Muhammad Arshad - VS - Connected Regularization (SB) FDE etc.

30 W.P. 4608/2025 Service Dr Niaz Muhammad etc- VS Connected Regularization (SB) -FOP etc.

31 W.P. 5027/2025 Service Dr. Riffat Ramzan - VS -FOP Connected Regularization (SB) etc.

32 W.P. 731/2026 Service Dr. Mati ur Rehman etc. - Connected Regularization (SB) VS -FOP etc.

33 W.P. 814/2026 Service Muhammad Waseem etc- Connected Regularization (SB) VS -FOP etc.

34 W.P. 1145/2026 Service Shakeel Arshad- VS -FOP Connected Regularization (SB) etc.

35 W.P. 1371/2026 Service Shakil Arshad- VS -FOP etc. Connected Salary (SB) 36 W.P. 2330/2026 Service Abid Ali- VS -FOP etc. Connected Regularization (SB) 37 W.P. No. 5244/2026 Mst. Saima Pazir etc.- VS- Connected. FOP, etc.

38 Crl. Org. 218/2026 Writ (SB) Shakil Arshad- VS -Shahid Connected Iqbal Baloch etc