Supreme Court of Pakistan
Muhammad Kamran v. The State and another
Published on this website
Criminal Review Petition No. 73 of 2025 in Criminal Appeal No. 91 of 2024
Citation: Approved for reporting; review citation not printed in supplied judgment
Background
Background
Supreme Court rejects Kamran’s death-sentence review: marriage refusal aggravates the motive, and fourteen years in custody does not justify the relief sought.
Kamran sought review of the appellate decision maintaining his death sentence for killing Mst. Memoona Shaheen after a rejected marriage proposal. Counsel argued prolonged death-row custody and an emotional motive; the Court rejected both grounds within review jurisdiction.
Legal questions
Legal questions
Did prolonged death-row custody and the rejected marriage proposal justify review and commutation under the life-expectancy principle?
Court holding
What the Court decided
A woman’s refusal to marry does not mitigate her murder; the established motive aggravates the offence. Under the life-expectancy approach applied, twenty-five years in custody, additional compelling mitigation and an offence not among the most aggravated are required. The Court found fourteen years in custody, no mitigation and no reviewable error.
Final outcome
Final outcome
Criminal review dismissed and leave refused. Earlier appellate decision maintaining the death sentence left undisturbed.
Practical effect
What the decision means in practice
Criminal review dismissed and leave refused. Earlier appellate decision maintaining the death sentence left undisturbed.
This summary states the immediate effect recorded in the decision. The original judgment and the facts of the particular case remain controlling.
Key legal principles
Key legal principles
- Article 188 review is not a second appeal; reargument alone does not identify a reviewable error.
- The life-expectancy approach discussed requires twenty-five years in custody, additional compelling mitigation and an offence not among the most aggravated.
- Fourteen or fifteen years of death-row custody does not automatically place the convict in the position of a prisoner sentenced to life imprisonment.
- The established rejected-marriage motive aggravated this murder rather than mitigating it.
- The twenty-five-year threshold concerns the particular life-expectancy ground discussed, not a universal ban on all other grounds for commutation.
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Original judgment and official source
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Later treatment
Later treatment
Approved for reporting. No review reporter citation or later judicial treatment verified. The announcement date was checked visually against the handwritten final-page endorsement.
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Related article
Related article
Supreme Court rejects Kamran’s death-sentence review: marriage refusal aggravates the motive, and fourteen years in custody does not justify the relief sought.
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