IN THE SUPREME COURT OF PAKISTAN, ISLAMABAD

(Original jurisdiction)

Constitutional Petition No:______/2025

MUHAMMAD QAYUM KHAN-S/O Faraidun Khan Citizen of Pakistan from

Village: Gojalti, Tehsil: Yasin, Distt: Ghizer, GB, CNIC# 7150101245473
Cell No: 03188278872.

............PETITIONER
VERSUS

1. The Federation of Pakistan through Secretary Law and Justice,

Government of Pakistan, Islamabad.

2. The Speaker of the National Assembly: Through Principal Secretary

National Assembly of Pakistan. Islamabad.

3. The Chairman Senate: Through the Principal Secretary Senate of

Pakistan, Islamabad.

4. The President of Pakistan: Through the Principal Secretary to President

of Pakistan, Awan-e- Sadar, Islamabad.
................RESPONDEN
TS

CONSTITUTIONAL PETITION UNDERARTICLE-184(3),199 AND 19 OF

THE CONSTITUTIONOF PAKISTAN-1973WHICH GUARANTEES ALL
THE ENABLING RIGHTS TO ALL THE CITIZENS OF PAKISTAN.AS
ULTRA VIRES MAY KINDLY BE TREATED NULL AND VIOD.
BACKGROUND
As the State according to its written constitution guarantees through its State pillars’ violation of all these
guaranteed rights ultra-vires legislation repugnant to the freedom of expression and freedom speech
sabotaging the natural justice system through a so-called PECA Amendment Act as a non-issue of the time
and as a fake urgent need of the society passed illegally and forcefully by the high jacked mandated proxy
government on the behest of the power corridors in conflict of interest may kindly be treated null and void
and suspended immediately to ensure peace and stability may not be further effected and spoiled in the
country some of them given below:

1. That the above cited Constitutional Petition is made in person for reversal and suspension of
amendment as it is so urgent and an extra ordinary nature of paramount national interest in the
light of current national multiple crisis resolution needed to brought based on the approach of
“peace first and justice later.

2. The Petitioner in person humbly submits and intends to file this constitutional petition to fix
urgent hearing of petition as the case relates to fundamental rights of speech and speak of the
 huge public to be safeguarded by the judiciary in view of the current ongoing national multiple
terrible crises not to be enhanced but to be ended.

3. In order to protect the fundamental and human rights of the 90% public, worst affected for last
around 3 years in consequences of all kind of brutal despotism created devastating crises in
the country and uncertainties pushing the nation into the flames of depression and acute
stress worried for their survival and creating extreme desperation in the entire environment
generally and brutally victimizing the leaders and workers including mothers, sisters and
daughters of the nation of the federal party of the country (unprecedented) being targeted for
not being part and parcel of corrupt practices and corrupt mafias of the 10% elite class during
Khan government became united to fix the people loving party of 80% particularly abusing the
legal processes even of false and concocted cases, abductions and arbitrary arrest violating all
human rights of liberty –to speak- to associate- to assemble to peaceful protest and isolating
the federal party and crushing them through various brutally and rigorously investigating
manners adopting various tactics employed in personal revenges based on political vendetta to
victimize one party leader through their united agonies inflicted on the founder of the party,
consequently bringing the economy to the brink of constant default in the short period of
around years.

4. It is therefore imperative to awake the Honorable Supreme Court and 5 High Courts juries as
last resort of peace and hope and expected to bow honoring the huge social rejection of the
ousting the legitimate government, then rigging elections process to be conscious to ensure
peace in the country, to settle all unwanted self-created crises to extend further and any miss-
happening in the country in view of present hatreds about the institutional role and images
developed in the minds of the nation due to various cases of abductions and killings particular
party candidates and blatant uncertainties of state owned discriminations and despot acts
among the parties as abundantly witnessed during nomination and campaign process, high
jacking the mandate of the nation and now trying the constitution to be ruptured to suppress
the nation’s fundamental rights against the wish and will of the nation.

5. The highest Forum of judiciary the Supreme Court of Pakistan being the last hope of justice
system to ensure peacekeeping- justice and rule of law to protect and safeguard human rights
of citizens under our constitution to recover the certainty badly affected the whole society and it
is imperative for the judges of the Honorable Supreme Court and High Courts consisting 2
Senior judges from each High Courts must concentrate to take a Suo Moto action urgently to to
reverse this rupturing effort of all the current legislation in the conflict of interest of gang group
and urgently restore the PTI previous government or otherwise immediately announce the
results according to the 1st midnight, Forms-45 issued by the respective ROs even not within
the stipulated time given in the constitution and election rules otherwise the contempt of court
and violation of constitution must be exercised against the Chief Election Commissioner, his
staff and ROs for the current violation of the constitutional responsibilities and also to stop the
construed and highly perceived abortive effort expected by any constitutional institutions to do
unconstitutional act to be stopped for the peace in the country and to revive the image of all
state organs within the scope of the constitution bestowed on them, otherwise any civil strife
seeking justice on streets is not ("Kharijazimkaan".).or we have to wait and pray till the
“Divine curse and agony” is not imposed on the elite class who exploited and sieged the
entire system for last 76 years.

6. The Petitioner in person humbly submits and intends to file this constitutional petition to fix
urgent hearing of petition as the case relates to fundamental rights of the public and paramount
interest of the nation and extra-ordinary urgent nature in the light of current national multiple
terrible crises demanding immediate resolution reversing the rupturing amendments and the
evicted mandates to the national party given back as the best remedy by the judiciary.
A: QUESTION OF LAW AND CONSTITUTION:

1. Whether as a citizen of Pakistan who cherishes democratic principles, independence of

justice system rule of law equally to all and protection of human rights and human dignity,
beyond thepolitical interest, I firmly believed that a fairly mandated governments elected
through fair and transparent elections, and having a fair majority in the Assembly should not
be entitled to bring such Amendments Bills, Acts and Laws with appropriate deliberation and
debate in the fair National Assembly if it is treated a true issue of the society. The limits
established in the Constitution would be meaningless where it the fundamental and
paramount law of the nation and that is cannot be altered by an ordinary act of the legislature
so an act of the legislature repugnant to the constitution is void.

2. Whether the will of the people is respected and protected and the above referred rights of the
inhabitants of the country have not been guaranteed by the State and whether the
interventions by any State bringing a non-issue of the society to further enhancing the existing
interminable terrible crises should be allowed to do legislation in conflict of interest and the
Apex Court should not be alert to defend the violation of guaranteed rights through its
bestowed constitutional responsibility under Article 184(3) must not intervened through its
inherent right to do so through the Suo Motu action immediately to protect citizen rights?

3. Whether the pillars of the States should be allowed to bring ultra vires amendments repugnant
to constitutional rights sabotaged in this time through a forceful process of legislation by an
illegal and stolen election result based proxy government selected to protect their common
malicious intensions and interest in the conflict of interest may not be intervened actively by
the Apex Court through its inherent right under the Article 184(3) of the constitution and other
enabling Articles as fundamental and freedom of expression and speech as well?

4. Whether such unnecessary intervention and alterations in existing Acts, Laws and procedures
of constitutional operation should be allowed to do the amendments so swiftly urgently or to
achieve the pillars of the State individual malicious objectives or common objectives of such
State pillarsto target and suppress their common opponent party, its leaders and workers and
opinion makers in social media is not a gross human right violation under national laws and
international Covenants passed by the United Nation in its various Resolutions.

5. Whether the State Pillars bestowed authorities in the good faith of public service and in the
best national interest like powers to our establishment (national security) to defend the
country should be allowed to abuse their authority and power against the will, interest and the
welfare of its citizens to harass and to abuse that power to enjoy their free grazing
manipulating everything in their individual interest or in favor of the institutional kingdomto
hold on the absolute power constantly through their brutal despot actions against their
critiques makers?

6. Whether the paramount independence right of the judiciary as the Last Hope and the Last
Resort for the citizens of the country to get equal justice impartially, unbiased and timely
should be allowed to be sabotaged through such Amendments made to protect the interest of
one group and to victimize another should not be opposed by any citizen in the best interest
of the society at large and should not be brought to the notice of the Apex Court if itself is
compromised and restrained to do so on its own responsibility?

7. Whether a citizen has no human and fundamental rights to work for peace building and
stability of Pakistan in the long run objective of the sustainable development and in so doing
to defend a perceived malicious attempt made through this Act on the base of all previous
evidences and experience one after another compounded and persistently played in the
vindictive way to harass and tortures the public at large noticed through protests and all
actions by the constitutional institutions and allied forces becoming united in the rivalries and
agonies of the only national party founder and his leaders and workers for last near to 3 years
creating all kind of terrible crises and uncertainties in the country reaching interminable and
insurmountable day by day affecting the survival of lives of the majority of inhabitants at the
brink of starvation to the level of Great Depression 1930 in US is not enough in awakening
the attention of the Supreme Court to obstruct such despotism immediately at its own notice?
8. Whether it is imaginable and there is any kind of precedence like that more than 200 cases
have been registered against any affectionate national leader just to cripple and compel himto
surrender from his ideology and accept the fake reality of power politics of the united
gangsters and unfortunately the compromised, naïve, fragile, suppressed and biased judiciary
proceeded the cases of non-maintainable in any court of law and justice through speedy
called trial of PTI founding father, its leader and workers in similar indifferent locations to
exploit their energy?

9. Whether such compromised and puppet judges should be allowed to serve the nation and
entitle for the benefits and perks working for special groups should not to be taken to task and
also defense authorities should be allowed to abuse their authority of defending the country in
their individual interest against their code of conduct and the objective theme of the oath?

10. Whether there is not a big question for the supreme judiciary that such Law making
maliciously on fake acts and Laws coming forcefully through a proxy government Prime
Minister without a fair public mandate as not real issue of the society but to be allowed to be
passed by the legislature with a fake mandate, and the proposal coming from any interest
group of beneficiary to the Cabinet to be supported and passed in emergency through a back
door channel and whether a 2 Term President heading a national party 4 time in Central
Government and all time in provincial government of Sindh considering himself a champion of
democracy so swiftly accord sanction such malicious intended amendment act suppress their
opponents but in reality a hazardous law in the long run to every stakeholder and citizens who
loving democracy, freedom of expression/speak/speech in the environmental justice based
global village just a futile wish to make his son the Prime Minister and to make the
environment beneficial to him supporting this unconstitutional Act against the spirit of his own
party and the Misaq-e-Jamhuriat Agreement with currently fake ruling party making this
document a fake converting it into Mizaq-e-Jamhoriat in reality beside that the President is
also a fake President selected by the fake parliament imposed through the stolen and high
jacked election based results.

11. Whether our supreme judiciary as a safeguarding institutions and guarantor of the all the
gross human rights and the public should be allowed and bear the consequences of such
Laws and Acts like PECA and 26 th Amendment also to punish their opponents swiftly to
victimize them in fake conviction to the opinion makers of the truth?

12. Whether this fake PECA Act was the only burning and acute urgent issue more important to
national security and interest and in the public importance comparatively restore peace,
political, economy and social stability, justice access to all, rule of law and democracy in order
to achieve the real mission of the governance for sustainable development was not enough
to conceive firmly that the Amendment was brought to suppress the opponent opinion
makers, news channels, you tubers and social media workers being the resilient of real
independence?

13. Whether the Supreme Court of Pakistan and other fair justices in country High Courts as the
last hope and the last resort of human rights guardian and guarantor and as the healer to
tortured and aggrieved one and other constitutional institutional responsible officers should
not to concentrate on national long term interests of sovereignty and survival of the existing
system and the Supreme Court of Pakistan should not conscious to lead toward a “Grand
Judicial Reconciliation Review Bench” through a Suo Motu right in the constitution
establishing a Bench consisting all justice inclined to play their part for providing justice to the
nation recusing the biased justices who are responsible to bring injustice in their various
judgments to hurdle progress of the society to look into the crises for last around 3 years
compounding day by day as in best interest of the beneficiary group of crises and should not
be conscious to look into the inherent responsibility of judicial system in any nation to bring
peace the 1st of all requirements the nation rests to survive to be done through the Truth and
Reconciliation Commission by a fair mandated government in the coming period?

14. Whether It is not a surprising, astonishing, as sad and desperate opinion of fear manifested in
the society that the absolute power is not the nation who have been treated like animals to be
controlled by Generals’ stick, the constitutional institutions like the Judiciary and law enforcing
 agencies are following the power corridor will and orders like deaf and dump, to follow the
influenced order like a blind man and the corrupt politicians to seek their pleasure to abuse
the country scarce resources never tried to be enhanced and specially our divided sold
justices of the justice system obeying the corrupt gangsters influence instructions and carrying
the establishment luggage like Mules in majority in justice system making judiciary just a
stable of Mules instead of few horses who are suppressed so far and willingly not able to
provide the true and natural justice to justice seekers showing their naive and fragile position
of restraining justice and being very active to do injustice at the behest of the power holders
and the corrupt politicians who inducted them in the justice system as longtime investment
could not function independently like a fruit producing fruit do not know who planted it in the
soil initially?

15. Whether all these blatant brutalities of despotism to victimize purely on individual rivalry for
not granting any NRO to abuser of security powers at the cost of fake public and national
services by the responsible Officers in fake protocols based on fake national security risks
and announcing fake projects by fake PDM-3 government do not compelled the society to
become not a doubtful stage in the two nation theory based on our cultural and religious
ground at that time was a fake slogan when it proved in the 1 st incident of separation of East
Pakistan in 1971 and again our national security services would not be the responsible in
further separation of provinces from the federation even at the cost of huge expenses of
defense and justice system both looks on the same page commitment to benefit from
concocted crises become extremely fake to provide justice explicitly to victims, aggrieved and
deprived one equally to all justice seekers, along with all fake laws made by the fake
government and similarly the recent involvement of influences by ISI guys in land acquisitions
and the fake SCP justices and other subordinate Courts were expected to fair but found fake
to be the last hope and last resort to provide justice to the society during this current
despotism period around 3 years and national pride and trust on both the institutions shackled
and ruined and hope of the nation on the justice system and its integrity to provide justice
became fake due to clear division of judges dividing themselves in different interest group
mainly in three groups?

B: An alarming rationale of the Fake Objectives

behind the naïve narration of Fake News stoppage
picked out singly in the PECA as a Fake Act passed by
the Fake Assembly to achieve Fake Objectives among
other countless Fakes in our society unfortunately

i. As the purpose and the intension of this Amendment in Act is not that one as propagated;
it is actually target and harass PTI loving people particularly social media opinion makers
illusorily in reference of this Act; hence this Act itself is a Fake Act malicious too and
forcefully passed If fake news against the proxy government established on fake election
results high-jacked based is itself a fake government and the institutions doing everything
against their oath and constitutional responsibilities abusing the rights and powers
bestowed by the constitution brought forward even all fake crises and uncertainties basis
martial laws imposed in our history. The Fake purpose behind this act passed through all
fake process and the current fake statements of the constitutional institutions blatantly
against the true news to negate their affects through a monopolized manner in last around
3 years self-created fake crises created by themselves.

ii. In the last 3 years all brutal despotism acts including the 1 st fake “No Confidence Motion”
brought to the National Assembly as a fake “Regime Change Operation” initially through a
self-created and propagated Cipher but later on immediately proved and used against
Imran Khan to out his legitimate government and used the fake Secret Act of before
Pakistan time of British government to suppress Pak India citizens as a fake law while
registering all fake FIRs and Petitions against Khan, his leaders and workers to target and
filing above 200 fake cases, all prosecuted in the fake environment of fake judicial process
in Jail fake trials by the managed judges maliciously assigned task at the choice of power
corridors specially inducted in fake persecution by the Judges of trial, terrorist and
accountability courts through all fake process propagating a fake security risk intentionally
not to show Khan physically to its loving public as his basic human right and a victim right
 also and te later on forcefully imposing the military courts to persecute the fake and false
flag operation of the 9th May, 2023.

iii. All the fake victimizing Acts happened from assassination attempt at Wazirabad, a fake
mistaken operation in other country land to eliminate Arshad Sharif, the fake arrest of Khan
from the court’s premises of IHC in a fake Rangers’ operation which treated and endorsed
as legal action by the fake Justice, the Chief Justice of IHC which proved as fake
immediately reversed by the Honorable SCP was not a fake biased judgment of the Chief
Justice of IHC was not an act accountability of such Judges in the justice system.

iv. Similarly all the fake criminal cases and persecutions and fake convictions later on
reversed in Islamabad High Court after a fake assiduous and rigorouslitigation
unnecessarily adopted in the IHC just to delay the process and maliciously keep Khan in
confinement one after another cases. All these fake efforts to punish the implement a fake
arrestsof PTl leaders and workers in the 9 th May and to trial them in the fake victimizing
military courts through a fake persecution of law and justice in a fake blame of an attack on
security premises actually done by the arranged Gloo Butts and may or may not be the
security personnel to crash PTI and to convict them in the military courts beside the
presence of the judicial existing system in place. The propagation of the 9 th May to take the
opportunity by PDM 1-3 fake governments for last near to 3 years to victimize, isolate and
pressurize Imran Khan, his leaders and workers to suppress them through unwanted brutal
actions to penalize them for doing nothing wrong and bad for Pakistan separating and
propagating concocted fake news y the fake government about every incidents happened
hiding the truth starting from the Crackdown of the 25 May 2022 against the citizen loving
PTI idea genuinely tried to suppress through all gross human rights violation and human
dignities as well and creating new crises instead of resolution of them and compounding
the crises day by day as the beneficiary of the crises a a philosophy of no exit from crises
to extend their grip on the resources persistently which lastly reached to the tragic level of
brutal incident of the massacre n 26th November 2024 in the constitution avenue in front of
the fake National Assembly and highest forum of our justice system and the other so-
called legislatures in the Shuhuda Chowk (D-Chowk) to be renamed which still not
reported by the fake government propagating fake statement of no blot fired in the incident
of Massacre in the black out night on the peaceful political protesters trying to genocide the
pushtoon protestors announced by the fake minister of interior and information in fake
mandated government based on high-jacked and stolen fake election results and the
compromised judiciary being a spectacle(tamashai) on all crises but it will be right to say
being the part and parcel of the beneficiaries of high-jacked system.

v. It is astonishing to notice the deed silent attitude of our supreme judiciary as a

safeguarding State pillar to guarantee all human rights of public of its country should enjoy
their perks, benefits and protocols doing nothing for the improvement of justice system and
allowing and later on implementing actively to facilitate them to achieve the malicious
objectives behind such Laws and Acts made by the legislature and the executive of the
country against the generally accepted human rights may not be intervened under Article
184(3)in its own level through Suo Motu.

vi. As the President was expected to return this biased legislation brought just to crush PTI
and its worker will be returned genuinely but the President proved himself as fake
President sanctioning the discriminating Law routed by the fake Minister of Law and
Justice in the again fake good faith of the people and the situations witnessed revising and
revising the draft was fake proposal not genuinely processed by the Ministry of law and
justice without any appropriate and due debate and deliberation in the Assembly in
presence of Opposition as a serious issue of the time, but it was obvious to everybody
concerned to this Act are well aware the effective hands behind the Act to bring this Act
immediately implemented by our fake neutral establishment and the national security
intelligent agencies realistically working against the objective of establishing such an
institution in the best national interest commitment base but unfortunately these trustees
are doing the real politics in the country intend to strong their grip of besieged position on
the national resources in their control forever.
vii. The entire nation is in an astonishing, and surprising situation why this proxy government
has been awarded contract and by whom to do all during its government in 3 episodes
from PDM-1 to PDM-3 awarded the contact to do all evil intended amendments from NAB
Ordinance, Electronic Voting Machine, 2nd Election Amendments, the CEC authority, the
26th Amendments Bills to establish a Constitutional Bench of their choice in the SCP
resultantly manipulating the existing procedure of the SCP and the last but not least the
Fake PECA Act Amendments to do so y hook and by crook to enjoy their willy-nilly in
Pakistan as it was stated by the current COAS in his 1 st speech that Pakistan is neither old
Pakistan nor it is new Pakistan- It is our Pakistan- and at that time the nation was unable to
understand his activist statement which now it has been proved as what was his real
message to the nation at that time was a threat to the bloody civilians an arrogant
perception teach to them in their basic training in Military Training Academies.

viii. The fake groups of justice system in divided justices and lawyers one group deliberately
promoting injustice actively with the back support of corrupt gangs and the other which
wants to deliver true justice but compromised due to their own various reasons and
restraining to manifest their will bravely and there is hardly a small a small portion of
judges who could stand for the independence of the judiciary at their own and their family
member’s risk of life and harassment and other victimizing acts to suppress them

ix. The humiliation and the down fall of integrity of the divided judiciary is developed and the
characteristic attitude of activism and restraining is due to unfair induction of judges
without any competitive merits in the era Iftikhar Chaudhry as the most controversial Chief
Justice having entirely active biased and obliged implement to Sharif family missions
opening the window in the induction judges on political affiliation basis as biased and
partial judges providing opportunity to those corruptly cumulating the wealth mafia family
and investing enough bribery facilities increasing their perks, benefits and protocol on
judges in the judiciary without merit introduced a direct inductions from the lot of lawyers in
respective Courts from Civil judge level to the Supreme Court Justice planted in the
system to oblige them for long time in their service period and protecting the mafia’s
interest to enhance their properties national and internationally for the generation to come
and the Judges being their man always serving in the service of judiciary. to do corruption
as a legitimized activity for mafias and the judges to play their role providing fake justice to
victims and aggrieved people while facilitating and making even the injustices acceptable
to them and in favor of the planters.

C: FACTUAL OBJECTIVES TO FILE THIS CONSTITIONAL PETITION:

1. Inorder to bring this petition to the notice of the Honorable Supreme Court Pakistan is to
undo this fake oriented Amendment Act treating this unconstitutional Act repugnant to the
theme of our constitution which is the 7th Constitutional Petition to review and reverse and
suspend the Act passed not in good faith of the national interest.

2. All the constitutional petitions made in different occasions to the Honorable Supreme Court
which are pending in the Apex Court at various stages have the prime objective ensure
peace, stability, justice equally to achieve the nation’s sustainable development goals in
good faith of national interest and public importance circulated by the United Nation in
2015.

3. As the divided and compromised justices in Supreme Court of Pakistan exclusively may
not be promising to review all the wrong and unconstitutional judgments not socially
acceptable since the 10th April 2022 protesting the a forceful activist approach of the Apex
Court with considering the actual issue behind the malicious intension of various gangs
united to oust the Khan Government as treated a judicial coup by various law experts’
studies.

4. As the piece meal efforts of litigation in various wrong judgments will not bring immediate
peace in the country which is the most important to all depending reasons to failed nation.
Hence I have prayed in all my constitutional petitions to the Apex Court to arrange a
“Grand Judicial Reconciliation Review Bench” consisting all the remaining Supreme
Court Justices to being the members of all Benches who promoted the injustice in their
various biased decisions against the PTI party partially and 2 Senior Justices behind the
Chief Justices of High Courts and would be ideally bean extraordinary step to request 2
 Justices from the International Court of Justice(ICJ) to review all the biased judgments in
the light of peace, justice, law and order restoration to achieve the nations’ Sustainable
Development Goals SDG-1 to SDG-17.

5. As the most important Review is 1st of all other politically victimizing actions to crush,
isolate, victimize and continuing other constitutional rupturing efforts made after that tragic
1st evil to be review, treated unlawful and unconstitutional to be reversed the PTI previous
legal government to be restored undoing the mother mistake done by SCP from 3 rd April,
2022 to the 9th April, 2022 as the major evil through a judicial coup removing the smoothly
running legitimate government by the united gangsters of national and international players
through a notorious cipher oriented in the rivalry and common interest of the nation
sabotaging the mandate of the nation to be reversed suspending all activities done after
removal of government of Ex-Prime Minister Imran Khan Niazi which may kindly be
restored in the position of the 3rd April 2022 before the illegitimate ousting took placed in
order to provide appropriate remedy to the aggrieved and victim party to complete their
high-jacked and evicted mandated period replacing newly elected constituencies who had
left the PTI membership. This restoration measures will also bring 1 st hand face saving
safe exit to other beneficiary stakeholders restore peace, stability to revive the democracy
in the country immediately as an amicable and reconciling solution to be accepted by all
stakeholders.

6. Can an independent and impartial judiciary under Fundamental Rights from Article 8-28
and the provision of Article 184(3), and Article 199 the inherent power of the Judiciary in
paramount interest of the country intervene to ensure peace, justice and equity is not the
responsibility to take Suo Moto action to stop the construed malicious attempt by any
Constitutional institution, political party and individual to file any petition.

7. The Civilian population as human being having fundamental rights to defend all perceived
malicious attempt in in the air in advance and on the base of all previously experience one
after another and persistently played in the vindictive way to harass and tortures the public
at large noticed through protests and all actions by the constitutional institutions and allied
forces becoming united in the rivalries and agonies of the only national party founder and
his leaders and workers for last around 3years creating all kind of terrible crises and
uncertainties in the country to reach insurmountable level affecting the survival of 90%
Pakistan inhabitants at the brink of starvation to the level of Great Depression 1930 in US
will not draw the attention of the Supreme Court to obstruct such despotism?

8. As it is the responsibility of the judiciary in general and the Honorable Supreme Court
particularly as the last hope of peace building and to obstruct the new influx of
uncertainties regenerated following a political vendetta as “interminable soap opera” which
will cause a new unfortunate political catastrophic attempt victimizing the PTI
commensurate actually to victimizing the whole nation and to avoid such situation the
Honorable Supreme Court with its subordinate judiciary may not concentrate to intervene
under inherent power of the Suo Moto vide article 184(3)protecting the fundamental rights
to play its role to heel the inuries of frustration of the public at large and build peace in the
country will be a promising action.

9. The Supreme Court must concentrate on its responsibility under Article 8-28Article 184-3
and 199 as a safeguarding institution of the fundamental rights of the public to grant a
status-quo to immediately stop vindictive attempts of the governments on its own action
like alteration of the election results announced after issuing Form-45 to the candidates
and their agents on the 1st night of the election day by ROs to avoid new brutal despot
action creating new confusion, chaos and impasse on the part of Chief Election
Commissioner on the behest of other interest group of real ruling elite class could be
review but unfortunately the restraining attitude on the part of the Honorable Supreme
Court would be unacceptable and unaffordable.

10. In view of the persistent, blatant and discriminative vindictive attitude of the Chief Election
Commissioner who deliberately violated and subjugated the constitution denying to hold
elections within stipulated time in April 2023, August 2023 till the intervention of the
Supreme Court failed to do his prime duty and becoming an opponent party to one political
party appealing in the higher court who had no right to appeal against the PHC judgment in
 SCP is not an ultra vires and unconstitutional steps taken by him did not demand the
Honorable judiciary of Pakistan to intervene through a Suo Moto action against the
Election Commissioner either under contempt power or Article-6 for such blatant violation
and persistent sabotaging and refusing the orders of the Supreme Court as well as the
President of Pakistan; it was a better opportunity once to stop playing with the constitution
by the constitutional incumbents themselves, to bring the nation out of these interminable
crises or otherwise to wait for any miss-happening of civil strife would not be promising at
all.

E. REFERENCE OF LANDMARKED JUDGMENTS REMARKS AND THE SCOPE OF A GRAND

JUDICIAL RECONCILIATION REVIEWS:

Two landmark decisions remarks by the US Supreme Court served to confirm the inferred
constitutional authority for judicial review in the United States and India brief details as follow:

1. In 1803, Marbury v Madison was the first Supreme Court case where the Court
asserted its authority to strike down a law as unconstitutional. At the end of his
opinion in this decision; the Chief Justice John Marshall maintained that the
Supreme Court’s responsibility to overturn unconstitutional legislation was a
necessary consequence of their sworn oath of office to uphold the Constitution as
instructed in Article Six of the Constitution of USA.

2. As of 2014 the United States Supreme Court has held 176 Acts of the US Congress
unconstitutional and in the period 1960-2019; the Supreme Court has held 483 laws
unconstitutional in whole or in part. Hence the powers of legislation are defined and
limited and the limits may not be mistaken or forgotten whether the constitution is
written or not. Similarly in their comments relating to judicial review, the framers
indicated that the power of judges to declare laws un-constitutional was part of the
system of separation of powers have following common features:

3. The framers stated that the courts’ power to declare laws unconstitutional would
provide a check on the legislature, protecting against excessive exercise of
legislative power. Any law contrary to the constitution is void.

4. The Supreme or the federal Court has the duty to interpret and apply the
constitution and to decide whether a federal or state statue conflicts with the
constitution. All the judges are bound to follow the constitution otherwise to be
accountable.

5. The Federal or Supreme Courts have a duty to follow the constitution and treat the
conflicting statues as un-enforceable.

6. The Federal or Supreme Court has the ultimate authority to decide whether statues
are consistent with the constitution.

7. A law violating a constitution established by the people themselves would be

considered by the Judges as “null and void”.

8. There is no record of any delegate to a state ratifying convention who indicated that
the federal courts would not have the power of judicial review.

9. If a law should be made inconsistent with those powers vested by the instrument in
Congress; the Judges as a consequence of their independence, the particular
powers of government being defined, will declare such law to be null and void.
10. For the power of the constitution predominates, anything therefore, that shall;be
enacted by the Congress contrary thereto will not have the force of law.

11. Publications by over a dozen authors in at least twelve of the thirteen states
asserted that under the constitution, the federal courts would have the power of
judicial review and there is no record of any opponent to the constitution who
claimed that the constitution did not involve a power of judicial review.

12. After reviewing the statements made by the founders, one scholar concluded: “The
evidence from the Constitutional Convention and from the state ratification
conventions is overwhelming that the original public meaning of the term “judicial
power” in Article III included the power to nullify unconstitutional laws.

13. Alexander Hamilton sated in the Federalist Paper that under the Constitution, the
federal judiciary would have the power to declare laws unconstitutional and he
asserted that this was appropriate because it would protect the people against
abuse power by Congress/legislatures.

14. A superiority of the judicial to the legislative power supposes that the power of the
people is superior to both legislative and the people and the judges ought to be
governed by the later than the former and they ought to regulate their decisions by
the fundamental laws, rather than by those which are not fundamental.

15. The Anti-Review Comments: The arguments, against ratification by the Anti-
Federalists agreed that the federal courts would have the power of judicial review,
though the Anti-Federalists viewed this negatively stated as “The judges under this
constitution will control the legislature, for the supreme court full bench is authorized
in the last resort, to determine what is the extent of the powers of the legislature.
They are to give the constitution an explanation, and there is no power above them
to set aside their judgment. -- The Supreme Court then have a right, independent of
the legislature, to give a construction to the constitution and every part of it, and
there is not proper and peculiar province of the courts is the interpretation of the
laws.

16. US Judiciary Act of 1789 establish jurisdiction to Supreme Court to hear appeals of
State Courts and the power to review state courts decision involving the
constitutionality of both federal statutes and state statutes the Act hereby
incorporated the concept of judicial review.

17. US Court decisions from 1788 to 1803: the judicial review was employed in both the
federal and state courts and in 31 states the statutes were struck down as
unconstitutional reflects widespread acceptance and application of the doctrine.

18. In Hayburn’s Case 408(1792) federal circuit courts held an act of Congress
unconstitutional for the first time where it found that Congress had violated the
Constitution by passing an act requiring circuit court judges to decide pension
applications subject to the review of the Secretary of War. These circuit courts
found that this was not a proper judicial function under Article –III. These three
decisions were appealed to the Supreme Court, but the appeals became moor
when Congress repealed the statute while the appeals were pending. In an
unreported Supreme Court decision in 1794, the Supreme Court reversed a
pension that was awarded under the same pension act that had been at issue in
Hayburn’s Case. The Court apparently decided that the act designating judges to
decide pension was not constitutional because this was not a proper judicial
 function. The apparently was the first Supreme Court case to find an act of
Congress unconstitutional. However, there was not an official report of the case and
it was never used as a precedent.

19. Kentucky and Virginia Resolutions pass by legislatures asserting that the state have
the power to determine whether acts of Congress are constitutional and in response
ten states passed their own resolution disapproving both the resolutions where
Vernmont’s resolution stated it belongs not to state legislatures to decide on the
constitutionality of laws made by the general government, and this power being
exclusively vested in the judiciary courts of the Union.

20. John Marshall’s opinion stated that in the Constitution, the people established a
government of limited powers as defined those limits may not be mistaken or
forgotten. The limits established in the Constitution would be meaningless where it
the fundamental and paramount law of the nation and that is cannot be altered by
an ordinary act of the legislature so an act of the legislature repugnant to the
constitution is void.

21. Marbury v. Madison was the first Supreme Court decision to strike down an act of
Congress as unconstitutional. Chief Justice John Marshall wrote the opinion for a
unanimous court. The case arose when William Marbury filed a lawsuit seeking an
order (a Writ Mandamus’) requiring the secretary of State, James Madison, to
deliver to Marbury a commission appointing him as a justice of the peace; Marbury
filed his case directly in the Supreme Court, invoking the Court’s “original
jurisdiction”, rather than filing in a lower court.

22. Marshall then discussed the role of the courts, which is at the heart of the doctrine
of judicial review,. It would be an ‘absurdity”, said Marshall, to require the courts to
apply a law that is void. Rather, it is the inherent duty of the courts to interpret and
apply the Constitution, and to determine whether there is a conflict between a
statute and the Constitution.

23. It is emphatically the province and duty of the judicial department to say what is the
law is. Those who apply the rule to particular cases must, of necessity, expound
and interpret that rule. If two laws conflict with each other, the courts must decide
on the operation of each. So, if a law be in opposition to the Constitution, if both the
law and the Constitution apply to a particular case, so that the Court must either
decide that case conformably to the law, disregarding the Constitution, or
conformably to the Constitution, disregarding the law, the Court must determine
which of these conflicting rules governs the case which is of the very essence of
judicial duty.

24. If, then, the Courts are to regard the Constitution, and the Constitution is superior to
any ordinary act of the Legislature, the Constitution, and not such ordinary act, must
govern the case to which they both apply. Marshall stated that the courts are
authorized by the provisions of the Constitution itself to “look into” the Constitution,
that is, to interpret and apply it, and that they have the duty to refuse to enforce any
laws that are contrary to the Constitution. Specifically, Article III provides that the
federal judicial power “is extended to all cases arising under the Constitution.”
Articles VI requires judges to take an oath” to support the Constitution.” Article VI
also states that only laws “made in pursuance of the Constitution” are the law of the
land. Marshall concluded. “Thus, the particular phraseology of the Constitution of
the country confirms and strengthens the principle, supposed to be essential to all
written Constitutions that a law repugnant to the Constitution is void, and those
courts, as well as other departments, are bound by that instrument.
 25. Marbury long has been regarded as the seminal case with respect to the doctrine of
judicial review. Some scholars have suggested that Marshall’s opinion is Marbury
essentially created judicial review.

26. In his book The Least Dangerous Branch, Professor Alexander Bickel wrote: “The
institution of the judiciary needed to be summoned up out of the constitutional
vapors, shaped, and maintained. And the Great Chief Justice John Marshall – not a
singlehanded, but first and foremost- was there to do it and did. If any social
process can be said to have been done at a given time, and by a given act, it is
Marshall’s achievement. The time was 1803; the act was the decision in the case of
Marbury v Madison.

27. Marbury was the point at which the Supreme Court adopted a monitoring role over
government actions. After the Court exercised its power of judicial review in
Marbury, it avoided striking down a federal statute during the next fifty years.
However, the Supreme Court did exercise judicial review in other contexts. In
particulars, the Court struck down a number of state statutes that were contrary to
the Constitution Thefirst case in which the Supreme Court struck down a state
statute as unconstitutional was “Fletcher v. Peck 10 US(1801).

28. In a few cases, state courts took the position that their judgments were final and
were not subject to review by the Supreme Court. They argued that the Constitution
did not give the Supreme Court the authority to review state courts decisions as
they asserted that the judiciary Act 1789, which provided that the SC could hear
certain appeals from state courts, was unconstitutional. In effect, these state courts
were asserting that the principle of judicial review did not extend to allow federal
review of state court decisions. This would have left the states free to adopt their
own interpretations of the Constitution.

29. The Supreme Court also has reviewed actions of the federal executive branch to
determine whether those actions were authorized by acts of Congress or were
beyond the authority granted by Congress. Judicial review is now well established
as a cornerstone of constitutional law. As pf September 2017, the United States
Supreme Court had held unconstitutional portions or the entirety of some 182 Acts
of the US Congress, the most recently in the Supreme Court’s June 2017 Matal v
Tom and 2019 Lancu v.Brunetti decision striking down a portion of July, 1946’s
Lanham Act as they infringe on freedom of speech.

PRAYE RS:
1. It is, therefore, most respectfully prayed the Amendment in PECA Act ultra vires to
constitutions power of the legislature and extremely repugnant against the human
rights, fundamental rights and rights of freedom of expression, speech and speaking
under the above referred Articles may kindly be reviewed in a full Court Bench of the
Apex Court to strike down the Act immediately to stop new legal crises could not be
afforded further and the existing PECA Act approved by Ex-Governments may kindly
be revisited in the light of our constitution and if found repugnant to the gross human
rights or in conflict of interest based may also be suspended.

2. It is also humbly requested in the national interest of peace, and stability both the
Amendment and Existing Law may kindly be reviewed in the Full Court Bench in the
 light of the freedom of expression of our opinion and view to disseminate to our society
and also in view of hurting opinion to other communities as recent judgment of the
American Court may be prohibited as we live in the Global Village where all human
beings have equal human rights and such hurting and targeting the opponents could
not be sustained and must be restricted along with the current PECA Act passed by
fake Assembly and sanction thereof wrongly accorded by the fake Assemblies
selected President may kindly suspended and such unnecessary Rules making and
making Amendments may kindly be prohibited unless not demanded by the society at
large.

3. As I have already filed many constitutional petitions in person as a the best solution of
all self-created terrible crises may also be heard simultaneously to bring urgent peace
and stability in the country among them the restoration of PTI previous Government is
to immediately bring peace and stability and an opportunity of face saving safe exit to
all stakeholders and perpetrators through Grand Judicial Reconciliation Review will be
a doable immediate resolution of all crises will be ensured stopping just now basis
without any advent of further crises.

4. Any other relief which this Honorable Court deems fit, just and appropriate may also be
awarded in the national interest peace and stability 1stto satisfy the nation and
petitioner who has filed this constitutional petition in the large interest of public singly
out of 250 million population to be honored fixing urgent date of hearing to my petitions
simultaneously and the 1st thing 1st basis restoring the PTI existing as 1st step toward
national reconciliation.

Petitioner-in-Person

Muhammad Qayum Khan-

A citizen of Pakistan from Village Gojalti,
Tehsil, Yasin, District: Ghizer, G.B.
CNIC 71501-0124547-3
Cell # 03188278872

CERTIFICATE
 Certified under instructions that the petitioner is filling first
instant petition under Article 184(3) of the Constitution of
Pakistan, 1973 and prior to this no other petition on the
above subject was filed by the petitioner before this Hon'ble
Court and any High Court.
Petitioner-in-Person
Dated:-04-02-2025
 IN THE SUPREME COURT OF PAKISTAN
(Appellate Jurisdiction)

Constitution Petition No.__________/2025

Muhammad Qayum Khan

.............Petitioner
Versus

Federation Of Pakistan And Others

.............Respondents

CONSTITUTION PETITION UNDER ARTICLE 184(3) OF

THE CONSTITUTION OF THE ISLAMIC REPUBLIC OF
PAKISTAN, 1973

AFFIDAVIT OF MUHAMMAD QAYUM KHAN SON OF FRAIDUN

KHAN HAVING ADDRESS OF VILLAGE GOJALTI, TEHSIL
YASIN, DISTRICT:GHIZER OF GILGIT BALTISTAN-PAKISTAN.

I the above named deponent do hereby solemnly affirm and

declare as under:-

1. That I am the petitioner I may state here that the facts as

contained in the accompanying C.P. are true and correct
to the best of my knowledge and information received
from the Petitioners and that nothing material has been
kept concealed.

SWORN at Islamabad on this 04th day of February, 2025

VERIFICATION
Verified on oath on this 04th day of February, 2025, that the
contents of above mentioned Affidavit are true and correct
to the best of my knowledge and information and nothing
material has been kept concealed.

DEPONENT
 IN THE SUPREME COURT OF PAKISTAN
(Appellate Jurisdiction)

Constitution Petition No.__________/2025

Muhammad Qayum Khan

.............Petitioner
Versus

Federation Of Pakistan And Others

.............Respondents

AFFIDAVIT OF SERVICE
Muhammad Qayum Khan
Petitioner in Person

I the above named deponent do hereby solemnly affirm and

declare as under:-

1. That I did serve the respondents of my having filed the

above mentioned Constitution Petition, Petitioner-in-

Person, in the Supreme Court of Pakistan at Islamabad.

SWORN at Islamabad on the 04th day of February, 2025

DEPONENT
 IN THE SUPREME COURT OF PAKISTAN
(Appellate Jurisdiction)

Constitution Petition No.__________/2025

Muhammad Qayum Khan
.............Petitioner
Versus

Federation Of Pakistan And Others

.............Respondents
NOTICE
To,

1 The Federation of Pakistan through Secretary Law and Justice,

Government of Pakistan, Islamabad.

2 The Speaker of the National Assembly: Through Principal Secretary

National Assembly of Pakistan. Islamabad.

3 The Chairman Senate: Through the Principal Secretary Senate of

Pakistan, Islamabad.

4 The President of Pakistan: Through the Principal Secretary to President of

Pakistan, Awan-e- Sadar, Islamabad.

Please take notice that I have today filed the above mentioned
Constitution Petition Under Article 184(3) of the Constitution of Pakistan,
1973 regarding Amendment in PECA Act ultra vires to constitutions power of
the legislature and extremely repugnant against the human rights,
fundamental rights and rights of freedom of expression, speech and
speaking under the above referred Articles may kindly be reviewed in a full
Court Bench of the Apex Court to strike down the Act immediately to stop
new legal crises could not be afforded further and the existing PECA Act
approved by Ex-Governments may kindly be revisited in the light of our
constitution and if found repugnant to the gross human rights or in conflict
of interest based may also be suspended, Petitioner-in-Person, in the
Supreme Court of Pakistan at Islamabad.

Petitioner-in-Person

Muhammad Qayum Khan-

A citizen of Pakistan from Village Gojalti,
Tehsil, Yasin, District: Ghizer, G.B.
CNIC 71501-0124547-3
Cell # 03188278872
Dated:-04-02-2025
 IN THE SUPREME COURT OF PAKISTAN
(Appellate Jurisdiction)

Constitution Petition No.__________/2025

Muhammad Qayum Khan
.............Petitioner
Versus

Federation Of Pakistan And Others

.............Respondents

Counsel for the Petitioner:- Petitioner in Person

Muhammad Qayum Khan

Counsel for the Respondents:-

INDEX
Sr. Document Date Page
No. No.
1. Constitution Petition 04-02-2025 1-14
2. Affidavit of Facts 04-02-2025 15
3. Affidavit of Service 04-02-2025 16
Certified that the paper book as bound is complete and correct.

Petitioner-in-Person

Muhammad Qayum Khan-

A citizen of Pakistan from Village Gojalti,
Tehsil, Yasin, District: Ghizer, G.B.
CNIC 71501-0124547-3
Cell # 03188278872
Dated:-04-02-2025