Civil Law · Legal issue collection
Limitation and Delay in Pakistan
Research filing deadlines, court holidays, delayed challenges and limitation after remand. The collection separates the facts and procedural routes of each case, with a link to the existing Limitation Act resource.
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Appeal Limitation During Court Holidays: Supreme Court Requires Filing on Reopening Day
Muhammad Akram and others / Nazir Hussain and others v. Mst. Nazeer Begum (deceased) through legal representatives and others · Civil Appeal Nos. 348 and 349 of 2018; CMA Nos. 797 and 798 of 2025 · Approved for reporting; reporter citation not printed
Supreme Court holds that section 4 protection requires filing on the first reopening day when limitation expires during court holidays.
Rejection of Plaint on Limitation: Supreme Court Requires Maintainability to Be Decided Before Amendment
Muhammad Islam Badshah and another v Abdul Wahab Shah and others · Civil Petition No. 675 of 2025 · Approved for reporting; reporter citation not stated in the supplied copy
The Supreme Court directed the trial court to decide limitation and maintainability independently of a pending plaint amendment, without finally deciding the time bar.
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More relevant judgments and articles
Buyer’s Missing Signature Alone Cannot Invalidate a Registered Sale Deed: Supreme Court
Shaman (deceased) through his L.Rs. and others v. Syed Kamran Haider Gillani and others; connected: Shaukat Mahmood and others v. the same respondents · Civil Appeals Nos. 231-L and 232-L of 2015 · Approved for reporting; no neutral or reporter citation stated in the supplied judgment
In Shaman, Pakistan’s Supreme Court ruled that missing buyers’ signatures alone do not invalidate a registered sale deed, and rejected a delayed fraud suit.
Sales Tax Limitation After Remand: Supreme Court Rejects Unlimited Re-Adjudication
Commissioner Inland Revenue, Legal Zone, Corporate Tax Office (CTO), Lahore v M/s Makerwal Collieries Limited · Civil Appeal No. 1693 of 2021 · Order dated 18 August 2026; approved for reporting; reporter citation not stated in supplied copy
The Supreme Court held that the statutory adjudication period runs afresh from remand, dismissing the tax Department’s appeal against an order made years too late.
Supreme Court: Land Rights Cannot Be Cancelled Without Hearing, and the State Gets No Special Limitation Relief
Province of Punjab, etc. v. Bashir; Province of Punjab through District Collector, Sargodha, etc. v. Rulya · Civil Appeal No. 187-L of 2009 and C.P.L.A. No. 769-L of 2016 · Approved for reporting; reported citation not stated in the supplied judgment
In Province of Punjab v. Bashir and a connected matter, the Supreme Court protected vested land rights from cancellation without notice and rejected a separate provincial petition filed 4,402 days late.
FCC: Article 199 Cannot Bypass Statutory Limitation
Muhammad Abdul Qadoos and connected petitioners v. Province of Punjab and others · F.C.P.L.A. No. 507 of 2025; C.P.L.A. Nos. 1461-L, 1464-L, 1474-L, 1523-L, 1555-L and 1586-L of 2024 · Approved for reporting; reported citation not stated in supplied copy
The Federal Constitutional Court held that a litigant cannot avoid a missed statutory remedy and its limitation period merely by recasting the dispute as an Article 199 fundamental-rights case.
OGDCL v. Dr. Capt. (R) Nusrat Hussain: Section 9A Benefits, Corporate Succession and Laches
Managing Director, Oil and Gas Development Company Limited, Islamabad, and others v. Dr. Capt. (R) Nusrat Hussain through legal representatives · C.P.L.A. No. 4245 of 2022 and C.M.A. No. 10808 of 2022 · Approved for reporting; reported citation not yet assigned
By a 2–1 majority, the Federal Constitutional Court set aside an order granting Section 9A benefits because the claim did not fit the statutory framework and had become stale in Article 199 jurisdiction.