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10/08/2026

2023 PCrLJ 1071

Circumstantial evidence -- Last seen evidence Scope Accused was charged that he along with his co - accused committed murder of the cousin of complainant --- Last seen evidence was furnished by witness , who was named in the FIR -- Said witness was not related to the deceased or the accused --- Said witness was not a chance and he had no reason to falsely implicate the accused --- Evidence of said witness was straight forward and he was not dented during cross - examination --- Evidence of said witness was found to be trustworthy , reliable and confidence inspiring , hence believable and thus , relied upon --- Said witness stated that the accused was present in the Madrassa at the time of the incident , as corroborated by the CCTV evidence -- Accused , the deceased and other witnesses were present in the room / place of occurrence at about 11.00 p.m .-- When the witness of last seen evidence got up to go the wash room he had seen the accused sitting on the stairs looking puzzled at 12.30 a.m. ( night ) --- Said witness had seen the accused already on his bed when he returned to his bed which would be at around 1.00 a.m. ( night ) --- At about 2.30 a.m. said witness and some of the other student woke up when they heard a sound as if something had fallen and they found the deceased lying on the mattress with blood oozing from his head --- At about 2.30 a.m. when the witness and others woke up and found the body of the deceased , the accused was gone --- Cement block was found adjacent to the mattress of the deceased which had not been there before --- Significantly , the timings given by the witness tied in roughly with the timings mentioned by complainant in his evidence whilst watching the CCTV footage --- Thus , keeping in view the fact that it had already come in evidence that the beds of the accused and the deceased were next to each other in the same room -- Moreover , it would appear that the last seen evidence test had been met --- Namely , at about 1.00 a.m. , the accused was seen sleeping beside the deceased and within one and a half hours the accused was gone and the deceased was dead in the bed next to the accused where a cement block was found which the accused had already been found carrying in the CCTV / USB footage back towards his room where the deceased was sleeping next to him --- Circumstances established that the prosecution had proved its case against the accused beyond any reasonable shadow of doubt --- Motive was not proved , thus death penalty was reduced to imprisonment for life.

09/08/2026

2025 SCMR 776

It would be relevant to mention here that it is now well settled that the share of minor legal heirs in Diyat shall remain protected under all circumstances, regardless of whether a compromise has been reached by all legal heirs of the deceased.

So far as the issue of inability of convict to pay the amount of Diyat due to weak financial resources is concerned, in the case of Government of Punjab v. Abid Hussain (PLD 2007 SC 315) this Court issued directions to the Federal Government to frame rules on this matter. Consequently, the Rules i.e. Diyat, Arsh and Daman Fund Rules, 2007, were framed by the Federal Government under the mandate of section 338-G PPC.

These rules provide four types of remedies for convicts/inmates unable to pay the amounts of Diyat, Arsh or Daman subject to the terms and conditions specified therein, namely;

(i) provisions of Soft Loans,
(ii) grant out of the Fund,
(iii) release on Parole, and
(iv) facilitation for Jobs.

In such view of the mater, the petitioner is at liberty to approach the administrative committee constituted under the Rules for the management of the Fund. Similarly, the petitioner can also approach the Trial Court under section 331 PPC for payment of Diyat amount in installments.

Crl.M.A.714/2023
Tanvir Hussain v. The State

07/08/2026

Post Arrest Bail in Pakistan
Bail After Arrest
Defined: Bail means to release a person from the custody of police and delivered him into the hands of surety, who undertakes to produce him in the court whenever to require to do so.
(2007 YLR 1582)
Cases in favour of prosecution
No doubt offence under section 489-F P.P.C. does not fall within the prohibitory clause of section 497 Cr.P.C., but it is not a rule of universal application to grant bail in each and every case. Grant of bail is discretionary and the discretion out to be exercise judicially. Accused remained absconder for long six years have caused not only financial loss but mental and physical agony to the complainant and his family. Long abscondence of accused is disentitled him to the concession of bail.
(2010 P.Cr.L.J, 1099)
Grant of bail in cases not following within the domain of prohibitory clause or proviso to section 497 Cr.P.C., is not a role of universal application. Each case has to be seen through its own facts and circumstances grant of bail no doubt is a discretion to a court but its exercise cannot be arbitrary, fanciful or perverse.
(2009 SCMR 174)
For an offence punishable with death or transportation for life, an accused charged with the same is not to be released on bail if there are reasonable grounds for believing that he has committed such an offence. The onus is on the prosecution to disclose those reasonable grounds and the courts has to examine the data available in the case to find out whether such reasonable grounds exist, to connect the accused person with the crime alleged against him.
(PLD 1972 SC 81)
Fugitive from law and courts losses some of the normal rights granted by the procedural as also substantive law. Unexplained noticeable abscondence entitles an accused to the concession of bail.
(2008 YLR 2086)
Court may decline to admit an accused to bail if a recognized exceptional circumstance is available for such refusal.
(2005 YLR 1215, PLD 1997 SC 545 ref)
Principles laid down by Supreme Court in Bail after Arrest
The scope of bail u/s 497 Cr.P.C. has been thoroughly discussed by the Supreme Court of Pakistan in PLD 1995 S.C 34, following the principle as laid down by the apex court this section divides non-bailable offence into two categories, i.e:-
(i) Offence punishable with death, imprisonment for life or imprisonment for 10 years and
(ii) Offences punishable with imprisonment for less than 10 years.
Grant of bail in non-bailable offence following in second category punishable with imprisonment for less than 10 years is a rule and refusal and exception. Bail in cases falling in the second category will be declined only in extra ordinary and exception cases e.g:-
(i) Where there is likely hood of abscondence of accused
(ii) Where there is apprehension of accused tampering with the prosecution evidence.
(iii) Where there is danger of the offence being repeated if the accused is released on bail.
(iv) Where the accused is a previous convict.
(2008 YLR 2717)
Large quantity of charas i.e, 200 kg recovered from the Suzuki pickup which was in possession of the accused at the time of recovery. Witnesses sporting the version of prosecution punishment provided for the offence fell under the prohibitory clause of S.497 Cr.P.C., embargo contained in sub-section 1 of S.51 CNSA fully attracted, bail refused.
(2010 Pcr.L.J 272)
Conclusion
To conclude, bail of a person can be dismissed if there is no malafide / false implication by the complainant party. Furthermore, bail application can be dismissed in case of apprehension of abscondence, tempering with prosecution evidence, repetition and previously conviction.
It is not hard and fast rule that the case not fall in prohibitory clause. So bail can be dismissed in such like cases.
Each case has its own facts and circumstances and to be decided on its own merits.

30/07/2026

2026 SCMR 1215
Recovery of narcotic substance---
CCTV footage, non-providing of---Effect---Benefit of doubt---Chars weighing 12 kilograms in total was recovered from accused, alleged to be packed in ten packets each weighing 1200 grams---Trial Court convicted the accused and sentenced him to imprisonment for twelve years and six months but High Court reduced that sentence to five years six months which he had already undergone---Validity---Weight of each packet categorically belied the version of prosecution that each packet weighed 1200 grams, and had raised serious doubts in prosecution's case---Prosecution witness who was serving as Moharrir at Police Station, stated that Seizing Officer handed over ten sealed parcels of samples to him for safe custody and onward transmission to the chemical examiner and admitted that no entry was made in the Roznamcha regarding receipt of case property on the relevant day---Entry in Roznamcha did not mention any detail-of recovered Chars except the motorcycle---Seizing Officer failed to describe nature and appearance of recovered Chars in both the FIR and the recovery memo-Prosecution witness who witnessed recovery, stated that the colour of recovered substance was brown, however, at the time when parcel was de-sealed the same was found black---Accused had specifically applied for CCTV footage to substantiate his claim of false implication and to show that he was unlawfully detained and alleged recovery was planted against him-Seizing Officer also admitted during cross-examination that CCTV cameras were installed at the building of Police Station but the investigating officer failed to take CCTV footage into possession, nor was it produced before Trial Court---CCTV footage, if secured and produced, could have conclusively established either guilt or innocence of accused---Standard of proof required to bring home guilt of accused under Control of Narcotic Substances Act, 1997 must be of the highest degree, leaving no room for doubt or speculation---Both the Courts below failed to appreciate the evidence in its proper legal perspective and completely overlooked the material contradictions, discrepancies, and inconsistencies that had created serious doubts in prosecution's case---Findings recorded by the Courts below were not sustainable in the eyes of law---Supreme Court set aside conviction and sentence of accused and he was acquitted of the charge---

Criminal Petition No. 749-L of 2022
TARIQ SAJJAD KHAN versus The STATE

30/07/2026

S. 21.M---Anti-Terrorism Act--- Joint trials --- Scope --- While trying a scheduled offence, the Anti-Terrorism Court is empowered under Section 21M of the Anti-Terrorism Act, 1997 to also jointly try any other offence committed by the accused, provided it is connected with the offence triable under --- However, it is very crucial to note that merely by virtue of being tried in the Anti Terrorism Court, a scheduled or non-scheduled offence does not assume the character of a terrorism offence, and remains punishable under the ordinary criminal law.
Criminal Appeal No. 22-K/2022 in CrLP.L.A. No. 184-K/2020
Riaz Hussain versus The State
2026 SCMR 1236

29/07/2026

2025 PCrLJ 1354
The determination of consent in r**e cases is often complex and fact-specific. The burden of proving the absence of consent initially lies with the prosecution, which can be discharged by presenting credible evidence, typically including the victim’s testimony, medical examination reports, and forensic evidence. Since the offence of r**e generally occurs in private, finding independent witnesses is challenging. Consequently, the victim’s solitary statement can suffice to secure a conviction in a r**e case, provided that it is trustworthy, consistent, and reliable.

In cases where direct evidence is unavailable, circumstantial evidence plays a pivotal role in guiding judicial reasoning and determining the presence of consent. This includes factors such as the victim’s physical condition, injuries suggesting resistance, forensic findings like DNA evidence linking the accused to the crime, the timing and sequence of events, or communication records such as messages or calls between the parties. However, it is essential to emphasize that the absence of injuries on the victim’s body or signs of physical resistance does not automatically indicate consent. As discussed, Explanation 2 of section 375 PPC explicitly provides that physical resistance is not a prerequisite for establishing non-consensual in*******se.

The court’s role is critical in balancing these shifting burdens. It must rigorously scrutinize the prosecution’s evidence to ensure it meets the high threshold of proving the absence of consent beyond a reasonable doubt. At the same time, the court must evaluate the accused’s evidence or defence to assess its plausibility and credibility.

During the investigation, the police concluded that the case involved fornication rather than r**e. These findings are essentially based on CCTV footage, pictures, and WhatsApp messages exchanged between the parties. While this evidence suggests a close relationship, possibly closer than the Complainant acknowledges, it does not definitively establish whether the act was consensual. This critical determination requires thorough scrutiny of all the evidence during the trial.

As previously discussed, under section 375 PPC, threats, intimidation, or coercion invalidate consent. Therefore, if proven, the allegations of pointing a pistol and threatening to release objectionable content would render any apparent consent irrelevant. The trial court is the appropriate forum to evaluate the evidence, including the CCTV footage, WhatsApp messages, and other material, to determine the nature of the offence.

Pre-arrest bail is an extraordinary remedy reserved for cases where the accused can demonstrate that the FIR was lodged with mala fide intent, personal animosity, or the like. The Petitioner has failed to satisfy this requirement. Claims of inconsistencies in the prosecution’s evidence, such as discrepancies between the FIR and the Complainant’s statement under section 164 Cr.P.C., necessitate detailed scrutiny alongside other evidence. Such an evaluation is beyond the purview of a pre-arrest bail application.

Crl. Misc.56457/24
Zain Tariq Vs The State etc.

26/07/2026

P L D 2026 Lahore 493

Recording of evidence via video link---Scope---Application moved by petitioner (lady/complainant) for recording her evidence through video link was turned down by the Trial Court---Validity---Record revealed that husband of petitioner/complainant was living abroad for gain, who had come to Lahore/Pakistan to participate in the marriage ceremony of his nephew and was allegedly murdered due to some property dispute---Apprehension shown by /complainant was that her husband was murdered through hired shooters and thereafter she and her children were also subjected to threats of dire consequences , therefore, she was constrained to sell out other properties and left Lahore to save herself as well as her children---For the protection of witnesses and other persons connected with the investigation of criminal case, the Punjab Witnesses Protection Act, 2018 (‘the Act 2018’) was promulgated, which has established a framework for witness protection including measures like physical protection, video links and restricted court room entry and protection for witnesses from being cross examined by the accused directly, particularly for serious and sexual offences while Preamble of the said enactment (the Act 2018) includes/states “or any other serious offence”---Section 10 of the Act, 2018 empowers the court to examine a witness through video link at a location outside the court and if it is not possible to have a video link in the court room, the court may move to the place, where such facility is available---Moreover, Art.164 of Qanun-e-Shahadat, 1984 (‘the Order 1984’) gives authority to the Court to admit any evidence that may have become available, because of technological advancement; which provision can reasonably be invoked for recording the evidence through video link---Accumulative effect of said provisions of the Act, 2018 and the Order, 1984 was that by invoking both the said provisions, the Trial Court may record a witness through video link, if the circumstances of the case so required---Petitioner was complainant as well as essential witness of the case---Witnesses are most important component of a successful justice system---The prosecution of crimes and the investigation process are both dependent upon the assertions and authentication of witnesses, as such State has an obligation to protect the witnesses---Petitioner seemed to be under threat and it may be very risky for her to appear before the Trial Court for recording her evidence---High Court set-aside the impugned order and directed the Trial Court to record the evidence of petitioner/complainant through video link/video conferencing, etc. after observing relevant protocols---

Recording of evidence---“Presence” of person adducing evidence---Video link, option of---Scope---Application moved by petitioner (lady/complainant) for recording her evidence through video link was turned down by the Trial Court---Objection raised by the respondents/accused was that under S.353, Cr.P.C. all the evidence must be taken in the presence of accused (or when his personal attendance is dispensed with in the presence of his pleader), therefore, recording the evidence through video link shall be in flagrant violation of the said provision of law---Validity---The term "presence" used in S.353, Cr.P.C. should be interpreted to include constructive presence to allow the recording of evidence through video conference; meaning thereby that virtual attendance via video conferencing can be considered a substitute for physical presence---Notably, "virtual attendance" of a witness in the court through the medium of video conferencing enables the judge and other persons present in the court to see the witness and hear what he says and vice versa---Thus, such attendance is, in effect, in open court, and his evidence is also recorded under the personal superintendence of the judge---The judge under whose superintendence the evidence through conferencing is recorded can satisfy himself about the free will of the witness present on screen as he does about the witness present physically in court by questioning him in said regard and ensuring that he is not under the immediate influence of any other person---Petitioner was complainant as well as essential witness of the case---Witnesses are most important component of a successful justice system---The prosecution of crimes and the investigation process are both dependent upon the assertions and authentication of witnesses, as such State has an obligation to protect the witnesses---Petitioner seemed to be under threat and it may be very risky for her to appear before the Trial Court for recording her evidence---High Court set-aside the impugned order and directed the Trial Court to record the evidence of petitioner/complainant through video link/video conferencing, etc. after observing relevant protocols---Revision petition , filed by the complainant , was allowed accordingly.


Recording of statement of witness through video link---Reliability, ensuring of---Protocols stated.

ORDER---Through this criminal revision petition validity of an order dated 16.07.2025, passed by learned Additional Sessions Judge, Lahore, has been assailed, whereby an application moved by petitioner Mst. Zubaida Khanum (complainant of the case) for recording her evidence through video link was turned down.

2. According to the brief facts a criminal case FIR No. 2487 of 2023, dated 21.05.2023 stood registered with Police Station Harbanspura, Lahore, for offences under Sections 302, 34, 109 and 114 of P.P.C., under the authorship of petitioner (Zubaida Khanum) with the averments that two unknown persons came on Motorcycle on 21.01.2023 at about 05:40 p.m. and made straight fire shots upon her husband (Muhammad Ashfaq), who had arrived from Kuwait to participate in the marriage ceremony of his nephew. Motive behind the occurrence stated to be was that there was a house of her father-in-law, which was purchased fraudulently by one Usman Rasheed son of Abdul Rasheed and her husband (deceased) had made a claim regarding the house. The house was later on grabbed by said persons. One Iqbal alias Bhola harbored the said grudge in his mind and he used to issue threats towards complainant’s family, as such said Iqbal alias Bhola and his sons namely Ahmad, Fahad and nephew Farhan alias Fani Kuwetia and Usman Rasheed committed the murder of husband of the petitioner in consultation with each other.

3. The learned counsel for the petitioner mainly focused on the point that husband of petitioner was murdered; thereafter she was issued threats from the accused party, due to which she migrated to Karachi. Petitioner/ complainant was under threat from the accused party (respondents Nos. 3 to 6); and in case petitioner came to Court premises to appear before the learned trial court at Lahore, she is likely to be killed, therefore, her evidence be recorded through video link for the safety of her life.

4. Conversely, the learned Deputy District Public Prosecutors assisted by learned counsel for respondents opposed present petition vehemently and rigorously on variety of the grounds. They added that apprehension expressed by petitioner is ill-founded and without any base. She may be provided security by the learned trial court for appearance in the court; petitioner has made an attempt to cause inordinate delay in the conclusion of trial, as such the impugned order passed by learned trial court was just and proper in circumstances.

5. Arguments heard. File perused.

6. Perusal of the record speaks that husband of petitioner/complainant was living abroad at Kuwait for gain, who had come Pakistan to participate in the marriage ceremony of his nephew and was allegedly murdered due to some property dispute. Apprehension shown by petitioner/complainant was that her husband was got murdered through hired shooters and thereafter she and her children were also subjected to threats of dire consequences, therefore, she was constrained to sell out other properties and left the Lahore to save herself as well as her children.

7. For the protection of witnesses and other persons connected with the investigation of criminal case, “The Punjab Witnesses Protection Act, 2018” (Act, 2018) was promulgated, which has established a frame work for witness protection including measures like physical protection, video links and restricted court room entry and protection for witnesses from being cross examined by the accused directly, particularly for serious and sexual offences. Preamble of the said enactment stating its purpose, aims and justification, is being produced below for the facility of reference.

“It is necessary to provide for measures to protect witnesses or other persons connected with the investigation, prosecution and trial of certain criminal proceedings relating the offence of terrorism, sexual offence or any other serious offence; and, to provide for ancillary matters.” (emphasis supplied)

Under Section 10 of Act, 2018 empowers the court to examine a witness through video link at a location outside the court and if it is not possible to have a video link in the court room, the court may move to the place, where such facility is available. I think it appropriate to have a look of said provision of law, which reads as under:-

“Sec. 10. Video link.- (1) When so directed by the court, the Unit shall take special measures so that the court may examine a witness through video link at a location outside the court.

(2) Where it is not possible to have a video link in the court room, the court may move to the place, as determined by the Government in consultation with the High Court, where such facility is available.”

Moreover, Article 164 of Qanun-e-Shahadat Order, 1984 gives authority to the court to admit any evidence that may have become available, because of technological advancement. This provision can reasonably be invoked for recording the evidence through video link. It reads as under:-

“Art. 164. Production of evidence that has become available because of modern devices or information system, etc.—Depending on the nature of case and circumstances, the Court may, if deem appropriate, allow to be produced any evidence or witnesses recorded by the Court through the modern devices or techniques including video calls, viber, skype, imo, whatsapp, facebook, messenger, line caller and video conference, etc.”

8. Accumulative effect of said provisions was that by invoking both the said provisions, the learned trial court may record a witness through video link, if the circumstances of the case so required.

9. The learned law officers as well as learned counsel for respondents/accused raised the objection that under Section 353 of Cr.P.C. all the evidence must be taken in the presence of accused (or when his personal attendance is dispensed with in the presence of his pleader), therefore, recording the evidence through video link shall be in flagrant violation of the said provision of law.

10. Said proposition was answered in affirmative in detail by apex court in a judgment dated 02.09.2022, passed in Civil Petition No.1795/2022 in case titled “Mesha Shafi v. Ali Zafar”, wherein it was held that the term “presence” used in the said provision should be interpreted to include constructive presence to allow the recording of evidence through video conference. Meaning thereby that virtual attendance via video conferencing can be considered a substitute for physical presence. The above judgment further noted that “virtual attendance” of a witness in the court through the medium of video conferencing enables the judge and other persons present in the court to see the witness and hear what he says and vice versa. Such attendance is thus, in effect, in open court, and his evidence is also recorded under the personal superintendence of the judge. The judge under whose superintendence the evidence through video conferencing recorded can satisfy himself about the free will of the witness present on screen as he does about the witness present physically in court by questioning him in this regard and ensuring that he is not under the immediate influence of any other person.

11. Reference in this regard may also be had from a Divisional Bench case of this Court titled ‘Munawar Hussain and another v. The State’ (2020 PCr.LJ 1184), wherein Divisional Bench allowed the recording of statement of witness through video link further holding that whenever in the course of an inquiry, a trial or other proceedings a witness is required to be examined through video link, the certain protocols should be observed to ensure its reliability. Relevant portion of the judgment highlighting the said protocols reads as under:-

“(i) The video conferencing should be held at the place approved by the Court.

(ii) If the witness is in Pakistan, a commission should be issued to the Magistrate of the first class under section 503 or 506 of the Code to facilitate and supervise the process as hereinafter mentioned.

(iii) If the witness resides in any country with which Pakistan has reciprocal arrangements, a commission as aforesaid should be issued to such Court or Judge having authority in this behalf as may have been specified in terms of subsection (2-B) of section 503 Cr.P.C. However, where no such arrangements exist, the statement of the witness must be recorded in Pakistan Embassy/High Commission or Consulate or, if the Court permits, in a Notary's office in the presence of an officer of that Embassy/High Commission or Consulate or the Notary, as the case may be.

(iv) The judge, magistrate, officer of the Pakistan Embassy/High Commission, Consulate or Notary, as the case may be, must ensure that the witness is alone at the time of video conference and is not coached, tutored or prompted and he must submit his certificate to this effect to the Court.

(v) Before examination of the witness under audio-video link starts he must submit to the judge, magistrate, officer of the Pakistan Embassy/High Commission, Consulate or Notary, as the case may be, his original identity card, passport, driving licence or other document to prove his identity along with an affidavit (signed and thumb marked) duly verified before a Judge, or a Magistrate or a Notary that the person who is shown as the witness is the same person who is going to depose on the screen. The said identification document and affidavit must be shown on the screen to the other side and the officer concerned must forward a copy of these papers duly attested by him in a sealed cover to the Court (for which expenses must be paid to him in advance) which must make it part of the record.

(vi) As soon as the identification part is complete, oath should be administered to the witness (if required by law) through the media according to the Oaths Act, 1873, or any other law for the time being in force.

(vii) The witness should, as far as possible, be examined during the working hours of the Courts in Pakistan.

(viii) The proceedings must be conducted, as far as practicable, without any interruption and no adjournment should be granted unless the Court thinks that it is extremely necessary to meet the ends of justice.

(ix) The Court must provide to the witness copies of any documents that he may be entitled to demand under any law for the time being in force.

(x) The Court must record any remark as is material regarding demeanour of the witness while on the screen and should note the objections raised during the proceedings either manually or mechanically.

(xi) Deposition of the witness either in the question-answer form or in the narrative form must be reduced to writing by the Court and must be read over to the witness and if possible his digital signature must be obtained as a proof of its correctness. After that the Presiding Officer must also sign it and make the same part of record.

(xii) The visual must be recorded at the Court's end, secured with the seal of the Court and made part of the record.

(xiii) If a video link fails during the proceedings, the Court may adjourn the proceedings or make such other order as it may deem appropriate.

(xiv) In case of perjury the Court would be competent to proceed not only against the witness who gave false evidence but against the person who abetted it.

(xv) Unless the Court directs otherwise, the expenses for the arrangements should be borne by the applicant who wants this facility. The same should be deposited with the Court in advance.

(xvi) The Court may put such other conditions and issue directions as may be required in the circumstances of a case to meet the ends of justice and attain the object.

(xvii) Depositions of the magistrates in terms of Letter No. 2045/MIT/HC/2017 dated 27.1.2017, supra, and other official witnesses should be recorded in accordance with the instructions issued by this Court from time to time.

(xviii) The Court may at any time vary or revoke a direction/ permission for examination of a witness on video link.

(xix) The Court must not make a direction for examining a witness on video link if:

(a) the necessary facilities are not available or cannot reasonably be made available, or

(b) the Court is satisfied that the evidence can more conveniently be given or made in the courtroom, or

(c) the Court is satisfied that the direction would be unfair to any party to the proceedings, or

(d) the Court is satisfied that the person in respect of whom the direction is sought would not give evidence or make the submission.”

12. Petitioner is complainant as well as essential witness of the case. Witnesses are most important component of a successful justice system. The prosecution of crimes and the investigation process are both dependent upon the assertions and authentication of witnesses, as such State has an obligation to protect the witnesses. Petitioner seems to be under threat. It may be very risky for her to appear before the learned trial court for recording her evidence. I, therefore, set aside the impugned order dated 16.07.2025 and allow present petition.

13. Learned trial court is directed to record the evidence of petitioner/complainant through video link/video conferencing, etc. observing above protocol.
Criminal Revision No. 66407 of 2025
ZUBAIDA KHANAM Versus The STATE

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