January 20, 2026
By Xari Jalil
LAHORE
In a stark and deeply critical observation, the Supreme Court of Pakistan upheld the conviction of a man for murdering his wife, while at the same time lamenting society’s persistent failure and indifference for protecting women subjected to abuse within their marriages. The court noted that women who suffer prolonged abuse at the hands of their husbands and in-laws are often pushed back into the very environments that endanger their lives.
The observations came as the apex court converted the death sentence of accused Ibrar into life imprisonment in a jail petition arising from the murder of his wife, Zeenat Bibi, following prolonged matrimonial discord. The court, however, maintained his conviction under Section 302(b) of the Pakistan Penal Code (PPC), along with compensation and other sentences awarded by the lower courts.
The six-page order authored by Justice Naeem Akhter Afghan, the court reiterated that women subjected to sustained maltreatment are undeniable victims of domestic violence who deserve protection, compassion and effective legal recourse. Instead, the court noted, entrenched social norms and family pressure often force women to return to abusive marriages — environments that amount to “nothing less than a living hell”.
The bench, which also comprised Justice Irfan Saadat Khan and Justice Malik Shahzad Ahmad Khan, was hearing a petition filed against a Lahore High Court judgment dated January 28, 2025, which had upheld both the conviction and death sentence awarded by a trial court in Gujranwala.
Case background
According to the prosecution, the petitioner and the deceased were married but embroiled in a serious matrimonial dispute. On January 17, 2020, the petitioner allegedly entered the house of his in-laws in Kot-Ishaq, Gujranwala, armed with a .30-bore pistol, after being aggrieved that his wife was not being allowed to return with him.
The petitioner opened fire, striking Zeenat Bibi in the head. When her father, Asghar Ali, attempted to intervene, the petitioner shot him as well, injuring his shoulder. The accused fled the scene, while the injured father and daughter were rushed to Lahore General Hospital. Zeenat Bibi succumbed to her injuries over a month later, on February 24, 2020.
Conviction of accused
An additional sessions’ judge convicted the petitioner in March 2021, sentencing him to death for murder, along with seven years’ rigorous imprisonment for attempting to murder the complainant. The Lahore High Court dismissed his appeal and confirmed the death sentence through a murder reference.
However, upon reappraisal of the evidence, the Supreme Court held that while the prosecution had conclusively established guilt through the testimony of injured witnesses and medical evidence, certain procedural lapses — including delayed dispatch of forensic evidence and lack of independent witnesses to weapon recovery — constituted mitigating circumstances.
Citing settled principles of law, the court ruled that even a single mitigating factor could justify awarding life imprisonment instead of death. Accordingly, it converted the death sentence into life imprisonment while maintaining all other convictions, compensation, and the benefit of Section 382-B of the Code of Criminal Procedure.
The court observed that despite repeated instances of abuse, families often compel their daughters to return to violent homes in the name of reconciliation — a practice that continues to place women at grave risk. The judgment underscores how domestic violence, when left unaddressed by families and society at large, can escalate into irreversible tragedy.
