July 19, 2025
Staff Report
LAHORE
In a written order, the Islamabad High Court (IHC) has outlined 20 compelling reasons for establishing a commission to investigate the allegations of entrapment in blasphemy cases.
On July 15, the Islamabad High Court (IHC) directed the federal government to constitute a Commission of Inquiry within 30 days to investigate claims that dozens of individuals were entrapped into committing alleged acts of blasphemy through orchestrated schemes involving fake online identities.
Justice Sardar Ejaz Ishaq Khan, who authored the 10-page ruling released on the court’s website on July 18, made the direction under Article 199 of the Constitution, citing a “failure to act in accordance with law” by the federal government despite repeated calls for action.
“This Court had to see whether there existed sufficient circumstances that ought to alert the Government to the need for the constitution of a Commission for a deeper probe,” wrote Justice Khan. “It did not have to determine with finality whether the blasphemy gang existed the way it was alleged… or whether the accused in the blasphemy FIRs were not guilty.”
Background of the case
The judgment stems from a petition moved by more than 100 families whose relatives have been accused in blasphemy-related cases. Petitioners claimed that their family members had been entrapped into sharing or creating allegedly blasphemous content through deceitful interactions—often involving individuals using female online aliases to gain their trust.
The petitioners’ case relied heavily on two key documents: a January 2024 intelligence report from the Punjab Police Special Branch and an October 2024 investigative report by the National Commission for Human Rights (NCHR). Both raised alarm over the possible existence of an organized group collaborating with officials from the Federal Investigation Agency (FIA) to falsely implicate young men in blasphemy cases, allegedly for financial gain.
The Special Branch report suggested the need to expose “the dubious tactics of this gang,” while the NCHR’s findings alleged the use of women operating under multiple identities to lure men into sharing content deemed blasphemous.
Key findings and justifications
Justice Khan laid out 20 detailed reasons for his order
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“About 400 FIRs and about 700 accused in online blasphemy cases, with a fair number of the accused claiming entrapment that was never investigated.”
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“No investigation ever being conducted to identify and interrogate the mysterious girl ‘Imaan’,” despite consistent claims from unrelated accused across regions that she entrapped them.
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The alleged use of the same Facebook IDs and passwords in multiple FIRs after they had already been surrendered in earlier cases.
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“Four accused of blasphemy dying in prison, without judicial or administrative inquiry… with one video played before the Court showing visible bruises and signs of torture allegedly leading to his death.”
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FIA officials’ admission that “in many instances, they did not carry out the detailed forensic examination of the complainant’s devices,” despite defense claims of digital entrapment.
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A video showing a private citizen allegedly arresting a suspect outside Layyah University using a car registered to a lawyer accused of leading the entrapment gang.
The Court was particularly critical of what it called a “so-called ‘Legal Commission on Blasphemy’” allegedly headed by Rao Abdul Rahim, which it said is “neither registered under any applicable law nor listed in any official database,” thereby raising questions about its legitimacy and operations. It further noted that the same individual’s clerk “posed as a woman in WhatsApp groups,” resulting in criminal complaints.
Composition and terms of the commission
The court reiterated the structure proposed in its earlier January 31, 2025 order:
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A serving or retired Chief Justice from a constitutional court as the head;
- A retired FIA officer experienced in cybercrime;
- A liberal public figure with a history of working in public interest; and
- An expert in information technology.
The commission, the order states, must determine “whether the blasphemy law is being misused,” and examine “the process through which such FIRs are being registered” as well as “the framework for collection, preservation, and presentation of digital evidence.”
It added that the proceedings should be livestreamed where appropriate, unlike in a Joint Investigation Team (JIT) which lacks transparency. “A JIT could not offer public scrutiny, and its members could be under internal pressure,” the court noted.
Respondents’ objections and court’s rebuttal
Counsel representing the respondents, which include federal agencies and telecom companies, objected that only the accused—not their families—could seek judicial review. The court rejected this contention. “The test of being ‘aggrieved’ for purposes of Article 199… is not a direct and personal interest as suggested… An accused’s father or relative is an ‘aggrieved’ person if the Federal Government drags its feet in constituting the Commission despite there being sufficient circumstances.”
Implementation and next steps
The federal government has been ordered to:
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Constitute the Commission within 30 days with the TORs outlined.
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Ensure the Commission concludes its work within four months.
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Place the official notification on record with the court, which will exercise “continuous mandamus” (sustained compliance) to oversee implementation.
The matter has been relisted for further hearing on December 15, 2025.