Above the Judge? The Unsettled Boundaries of Judicial Review over Pakistan’s Federal Ombudsman Institutions

Abstract

Pakistan’s federal ombudsmen operate under some of the most emphatic ouster clauses in the country’s administrative law. Section 18 of the Federal Ombudsmen Institutional Reforms Act 2013 bars any court from hearing a matter within an ombudsman’s jurisdiction, routing appeals to the President instead. A single, still-unresolved dispute shows how fragile that immunity actually is. In 2016, the Federal Ombudsperson for Protection Against Harassment, Yasmin Abbasi, issued an arrest warrant against a sitting Lahore High Court judge. The clash produced overlapping contempt proceedings, a misconduct reference to the Supreme Judicial Council, and a suo motu case that a six-judge Supreme Court bench was still hearing in November 2024.

This article uses that saga to trace the doctrine Pakistani courts built to survive ombudsman ouster clauses: immunity applies only “within the four corners” of an ombudsman’s jurisdiction, and disappears the moment an ombudsman acts beyond it. Following that doctrine from State Life Insurance Corporation v Wafaqi Mohtasib (2000) through Peshawar Electric Supply Co v Wafaqi Mohtasib (2016) to a February 2026 ruling of Pakistan’s new Federal Constitutional Court, the article argues that the Twenty-Seventh Amendment, which also transferred the Supreme Court’s suo motu power to the new Court, has added a genuine jurisdictional puzzle to an already unsettled question, one that legislative clarification, not further litigation, should resolve.

Keywords: Ombudsman; FOSPAH; judicial review; ouster clause; Federal Constitutional Court; Pakistan.

1. Introduction

On 5 May 2016, Yasmin Abbasi, then the Federal Ombudsperson for Protection Against Harassment of Women at the Workplace, issued a show-cause notice accusing a sitting Lahore High Court judge, Justice Syed Mansoor Ali Shah, of gross misconduct.¹ Four days later she appeared before that same judge in his chambers and tendered an unconditional apology for her own contempt of court. The reconciliation did not last. The very next day, acting on her own show-cause notice, she issued a bailable warrant for Justice Shah’s arrest, directing the Inspector General of Police, Punjab, to produce him before her office.² On 11 May 2016, Chief Justice of Pakistan Anwar Zaheer Jamali took suo motu notice under Article 184(3) of the Constitution and suspended the warrant.³ The Lahore High Court referred Abbasi to the Supreme Judicial Council for misconduct; she, in turn, told the Supreme Court it had no jurisdiction to review her decisions at all, relying on the sweeping bar written into the ombudsman statutes.⁴

Almost a decade later, that underlying question, whether a High Court can examine what a federal ombudsman does despite a statute that says it cannot, remains formally unresolved. A six-judge constitutional bench of the Supreme Court revisited the case in November 2024, still debating first principles.⁵ Since then, Pakistan’s judicial architecture has been rebuilt twice over: first by the Twenty-Sixth Amendment in 2024, then more radically by the Twenty-Seventh Amendment of November 2025, which created a new apex forum, the Federal Constitutional Court, and transferred to it the very suo motu power Chief Justice Jamali once used to intervene.⁶ It is no longer clear which court would resolve the 2016 dispute today.

This article argues that the FOSPAH episode is not a historical curiosity but a live illustration of an unresolved structural problem: the tension between ombudsman ouster clauses and the judiciary’s insistence that those clauses cannot immunise action taken outside an ombudsman’s jurisdiction. Part 2 sets out that statutory architecture. Part 3 traces the doctrine courts built to narrow it. Part 4 returns to the FOSPAH saga in full. Part 5 considers what the Federal Constitutional Court changes. Part 6 weighs the case for, and against, strict ombudsman independence. Part 7 concludes.

2. The Architecture of Ombudsman Immunity

2.1 Origins: the 1983 Presidential Order

Pakistan’s ombudsman system predates its current constitutional form. Article 276 of the 1972 Interim Constitution first contemplated federal and provincial ombudsmen; the 1973 Constitution preserved that provision, now Article 270-A.⁷ The Wafaqi Mohtasib, or Federal Ombudsman, was established a decade later under the Establishment of the Office of Wafaqi Mohtasib (Ombudsman) Order 1983, promulgated during the tenure of President Zia-ul-Haq.⁸

Article 9 of the Order gives the Mohtasib broad power to investigate maladministration by federal agencies, while excluding the Supreme Court, the Supreme Judicial Council, the Federal Shariat Court and the High Courts. Article 29 separately bars ordinary courts from questioning the Mohtasib’s findings, leaving only a representation to the President as recourse.⁹

2.2 The 2013 reforms and the bar of jurisdiction

The Federal Ombudsmen Institutional Reforms Act 2013 extended this model to every federal ombudsman institution, including FOSPAH. Section 18 states plainly that no court may entertain a matter within an ombudsman’s jurisdiction, nor assume jurisdiction over anything an ombudsman has already decided. Section 24 gives the Act overriding effect over conflicting law.¹⁰ A dissatisfied party’s only recourse is a representation to the President.¹¹ On its face, this is a near-complete privative scheme: judicial review is not discouraged, it is textually excluded.

2.3 FOSPAH’s parallel framework

FOSPAH, created under the Protection Against Harassment of Women at the Workplace Act 2010, inherited this same architecture when the 2013 reforms folded it into the wider ombudsman regime.¹² Unlike the Wafaqi Mohtasib’s enabling order, however, FOSPAH’s statute never expressly excludes the judiciary as an institution from its reach. That gap, as the 2016 episode shows, left genuine doubt about whether a sitting judge could be summoned before the ombudsperson at all.

3. The “Four Corners” Doctrine

Despite this apparent completeness, Pakistani courts have never treated ombudsman ouster clauses as absolute. The foundational statement came in State Life Insurance Corporation of Pakistan v Wafaqi Mohtasib, where the ouster was held to apply only where the ombudsman acted within the four corners of the statute; anything beyond that scope was never a valid exercise of jurisdiction, and so was never shielded from review at all.¹³

The Supreme Court gave the principle its most authoritative form in Peshawar Electric Supply Company Ltd v Wafaqi Mohtasib, holding that where the Mohtasib assumes jurisdiction the statute does not actually confer, a petition under Article 199 will lie despite the statutory bar. The Sindh High Court followed the same reasoning in Sui Northern Gas Pipelines Ltd v President of Pakistan.¹⁴ A related line of authority, beginning with Shafatullah Qureshi v Federation of Pakistan, holds that the Wafaqi Mohtasib is not a “court” but a quasi-judicial authority: a classification that matters because it forecloses any claim that ombudsman ouster clauses enjoy the same constitutional protection reserved for the judiciary’s own internal decisions.¹⁵

The doctrine has outlived the judiciary’s own recent restructuring. In February 2026, the Federal Constitutional Court, in Ghulam Abbas v Telephone Industries of Pakistan (Pvt) Ltd, reaffirmed that a constitutional court may intervene wherever a Wafaqi Mohtasib order suffers from a want or excess of jurisdiction, or is coram non judice, notwithstanding Article 29 of the 1983 Order, expressly relying on Peshawar Electric Supply Co as settled law. The Court added that the Mohtasib may act only to the extent Article 9 permits, and that even a respondent’s voluntary participation cannot cure proceedings that are coram non judice, since estoppel does not run against a statute.¹⁶

What emerges is a narrow but consistent exception: ouster clauses bar review of what an ombudsman validly decided, not whether the ombudsman had any business deciding it. That distinction requires interpreting the very statute the clause was meant to place beyond judicial reach. Nowhere is that difficulty starker than in the FOSPAH arrest-warrant saga.

4. Case Study: The Ombudsperson Who Arrested a Judge

4.1 An unlikely origin: a federalism dispute

On 14 September 2015, a complainant, Sumera Fazil Khan, filed a harassment complaint with FOSPAH against a senior Supreme Court advocate, his son, and others. The respondents challenged FOSPAH’s jurisdiction before the Lahore High Court, which, on 3 November 2015, stayed the ombudsperson’s proceedings, not on any question of judicial immunity, but on federalism grounds. Since the alleged conduct occurred at a workplace in Lahore, the High Court held, jurisdiction rested with the provincial ombudsperson under Punjab’s own 2012 harassment legislation, not with FOSPAH, following the devolution worked by the Eighteenth Amendment.¹⁷ It was, in other words, a four-corners dispute of an entirely different kind: not whether FOSPAH could reach a judge, but whether a federal ombudsman could hear the complaint at all.

4.2 From jurisdictional dispute to personal collision

Abbasi did not accept the stay. On 11 January 2016, the High Court, before Justice Mansoor Ali Shah, escalated the matter into criminal contempt, issuing bailable arrest warrants to compel her personal appearance. She appealed to the Supreme Court that February, arguing the High Court had no authority to subject her to coercive process over a matter within her exclusive jurisdiction: the ouster-clause argument in its purest form.¹⁸

The standoff turned personal that May. On 5 May 2016, Abbasi issued her own show-cause notice to Justice Shah, calling him a “contemnor,” accusing him of flouting his code of conduct, and alleging that a police team had entered her office “intrusively” while enforcing process against her; she demanded his appearance by 10 May.¹⁹ On 9 May she appeared before him in chambers, alongside the Attorney General of Pakistan and the Inspector General of Police, Islamabad, and tendered an unconditional apology. Justice Shah discharged the contempt proceedings against her, but his order was doctrinally precise: the contempt power vested in a federal ombudsman, he held, is a sub-constitutional power that cannot be turned against a constitutional court, since every sub-constitutional tribunal remains subordinate to it. That holding should have ended the matter. Instead, the very next day, Abbasi proceeded with her own notice against Justice Shah and, when he did not appear before her office, issued a bailable warrant for his arrest, directing the Inspector General of Police, Punjab, to produce him by 13 May.²⁰ On 11 May 2016, Chief Justice Anwar Zaheer Jamali took suo motu notice, suspended the warrant, and summoned both Abbasi and the Attorney General.²¹

The Lahore High Court then referred Abbasi to the Supreme Judicial Council for misconduct. Justice Shah’s detailed judgment did not mince words: her conduct, it found, was “insubordinate and recalcitrant,” and “unbecoming” in a way that “offends the honour and prestige of the constitutional court.” Abbasi, for her part, maintained before the Supreme Court that the High Court’s orders had been “illegal and void,” and insisted she had exhausted every option before invoking her own contempt power.²²

4.3 An unresolved return

What makes this case doctrinally significant, not merely dramatic, is that it tests the four-corners doctrine at its most extreme. Ordinary ombudsman disputes ask whether an everyday administrative grievance, such as a billing or service complaint, falls within a statutory definition. Here the question was starker: did FOSPAH’s mandate to investigate workplace harassment ever extend to compelling a sitting judge’s personal appearance, on pain of arrest? Neither the 2010 Act nor the 2013 reforms address that scenario. It is a genuine statutory silence that the four-corners doctrine was never built to fill.

That silence explains why the matter still has not been resolved. A six-judge constitutional bench of the Supreme Court, led by Justice Aminuddin Khan, revisited the suo motu case in November 2024; the judges disagreed even on whether an ombudsperson’s action could be challenged in a High Court at all. Justice Mohammad Ali Mazhar held that the case was not moot, since the warrant had been issued and Abbasi had pressed on with it even after the High Court’s injunction; Justice Jamal Khan Mandokhail noted, more prosaically, that she no longer held office at all. Abbasi did not appear. The bench adjourned, again, for a fuller response from her counsel. It is the same posture in which the case remains today.²³

5. A New Wrinkle: The Twenty-Seventh Amendment and the Federal Constitutional Court

Any resolution of the FOSPAH dispute must now contend with an institutional landscape that did not exist when the case began. The Twenty-Sixth Amendment, passed in October 2024, restructured the Judicial Commission of Pakistan and began constraining the Supreme Court’s suo motu powers, drawing sustained criticism over judicial independence.²⁴ The Twenty-Seventh Amendment, passed just over a year later on 13 November 2025, went considerably further. It created the Federal Constitutional Court and gave it, under the new Article 175E, exclusive jurisdiction over constitutional interpretation, federal-provincial disputes and the enforcement of fundamental rights. That is the same jurisdiction the Supreme Court once exercised through its suo motu power under Article 184(3), the very provision Chief Justice Jamali invoked in 2016; the Supreme Court’s original jurisdiction to enforce fundamental rights, and its appellate jurisdiction over substantial constitutional matters, now sit with the new Court alone.²⁵

The amendment provoked immediate resistance from within the judiciary. The day it was signed, two Supreme Court justices, Syed Mansoor Ali Shah (the same Justice Shah at the centre of the 2016 dispute) and Athar Minallah, resigned in protest; Justice Shah wrote that he could no longer even judicially examine the amendment that had “disfigured” the Constitution.²⁶ A Lahore High Court judge, Justice Shams Mehmood Mirza, resigned days later.²⁷ The International Commission of Jurists condemned the amendment as a “flagrant attack” on judicial independence and the rule of law.²⁸

The consequences for the ombudsman-review doctrine are still unfolding, and Pakistan already has one instructive parallel. In December 2025, the Federal Constitutional Court openly questioned whether it could even continue hearing the long-running suo motu case into journalist Arshad Sharif’s killing, since that case had been built on suo motu powers the Supreme Court no longer holds.²⁹ Within weeks, in Ghulam Abbas, the same Court applied the four-corners doctrine to a Wafaqi Mohtasib dispute, suggesting it has fully inherited the supervisory role Peshawar Electric Supply Co once assigned to the Supreme Court.³⁰ That same month it went further still, holding in a tax dispute that Article 175E(5) lets it hear “any case” raising a substantial constitutional question, even without express statutory jurisdiction.³¹

That leaves a pointed question for the FOSPAH case specifically. The 2016 suo motu action rested on the Supreme Court’s since-curtailed Article 184(3) jurisdiction, the same jurisdiction the Arshad Sharif episode shows is still being sorted out in practice. Nothing in the public record suggests the FOSPAH dispute has been resolved, or even formally addressed, since the Twenty-Seventh Amendment took effect. No published commentary located for this article yet addresses what has happened to Pakistan’s most storied ombudsman-versus-judge dispute amid a restructuring this dramatic.

6. The Case for the Ombudsman, and Why It Does Not Reach This Case

The case for the ombudsman’s side deserves to be stated fairly, not dismissed. Ouster clauses exist for a real reason: without them, well-resourced respondents could tie up every adverse finding in years of litigation, defeating the purpose of a fast, informal grievance mechanism. FOSPAH investigates workplace harassment, where complainants are often less powerful than the people they accuse; a harassment ombudsman second-guessed by every well-lawyered respondent risks becoming toothless exactly where it is needed most. Seen this way, Abbasi’s insistence on her office’s independence, even against a sitting judge, reflects a genuine institutional value, not simple overreach. An ombudsman too timid to confront powerful respondents would fail complainants just as surely as one with no limits at all.

The difficulty is that this justification does not reach the FOSPAH case. Ouster clauses protect an ombudsman’s substantive findings from relitigation; they do not authorise coercive criminal process against a judge exercising that judge’s separate contempt jurisdiction. Justice Shah’s own resolution was narrower, and more defensible, than a blanket immunity claim on either side: an ombudsman’s contempt power is real, but sub-constitutional, and cannot reach a constitutional court. That is not judicial self-protection dressed up as doctrine; it is a structural limit applying symmetrically to any sub-constitutional tribunal.

The broader uncertainty, though, is systemic, not confined to this one case. Pakistan operates at least nine federal and provincial ombudsman institutions, each carrying some version of the same ouster-and-representation model, and each therefore capable of generating its own version of this dispute.³² Comparative scholarship on ombudsman authority over serving judicial officers, in the Philippines, India’s Lokpal framework and elsewhere, consistently treats separation-of-powers concerns as the binding constraint on how far an ombudsman’s investigatory reach can extend into the judiciary.³³ What is unusual about Pakistan’s position is that the answer has been left to case-by-case judicial improvisation, through a doctrine built for ordinary administrative grievances and applied, almost by accident, to a scenario none of its founding cases involved.

A legislative fix would not require abandoning ouster clauses, which remain sound for the ordinary run of ombudsman complaints. What is missing is an express carve-out for the narrow scenario in which an ombudsman’s coercive powers are directed at a judicial officer acting judicially, together with a clear, post-Twenty-Seventh-Amendment allocation of which court, the Supreme Court or the Federal Constitutional Court, resolves such disputes going forward. Without that, Pakistan risks precisely what the FOSPAH case has already produced: a dispute that outlives every official involved, unresolved not for want of legal principle, but for want of a legislature willing to state that principle in the statute itself.

7. Conclusion

The image of a workplace-harassment ombudsperson issuing an arrest warrant for a sitting High Court judge, only for the underlying question to remain open a decade later before a court that did not exist when the dispute began, says something real about administrative accountability in Pakistan. The four-corners doctrine that Pakistani courts have built since State Life Insurance Corporation v Wafaqi Mohtasib is a sound response to sweeping ouster clauses, and its survival into Ghulam Abbas confirms that it outlasted the most significant judicial restructuring in the country’s recent history. But a doctrine built for ordinary administrative grievances was never designed to answer the harder question the FOSPAH case actually poses: what happens when the watchdog turns its coercive powers on the judiciary itself, and which court, today, even has the authority to decide. Until Parliament addresses both questions directly, the matter will remain exactly where it has sat since May 2016: open, contested, and unresolved.

Footnote(S):

¹ ‘Ombudsperson issues notice to judge in response to arrest warrants’ Dawn (Lahore, 6 May 2016).

² ‘Ombudsperson issues warrant for judge a day after apology’ Dawn (Lahore, 11 May 2016).

³ ‘Constitutional bench takes up matter of arrest warrants against fellow Mansoor Ali Shah’ Dawn (Islamabad, 16 November 2024).

⁴ ‘Jurisdictions overstepped: Row between courts, ombudsperson deepens’ Express Tribune (17 May 2016).

⁵ Dawn (16 Nov 2024) (n 3).

⁶ ‘Pakistan dispatch: two Supreme Court justices resign in protest of 27th Constitutional Amendment’ JURIST (4 December 2025).

⁷ ‘A Legal Research Guide to Pakistan’ (GlobaLex, NYU School of Law).

⁸ Pakistan Law and Justice Commission, ‘Enhancing the Powers of Wafaqi Mohtasib’ (Report No 15).

⁹ Ghulam Abbas v Telephone Industries of Pakistan (Pvt) Ltd CPLA No 464 of 2025 (Federal Constitutional Court of Pakistan, February 2026), discussing Establishment of the Office of Wafaqi Mohtasib (Ombudsman) Order 1983, arts 9(1)–(2) and 29.

¹⁰ Federal Ombudsmen Institutional Reforms Act 2013 (Act No XIV of 2013), ss 18, 24.

¹¹ ‘Federal Ombudsmen Institutional Reforms Act, 2013: For speedy relief’ Business Recorder (3 May 2013). The Act does not fix a uniform representation period across every Ombudsman; readers should consult the specific enabling statute of the Ombudsman concerned.

¹² Protection Against Harassment of Women at the Workplace Act 2010; Federal Ombudsmen Institutional Reforms Act 2013.

¹³ State Life Insurance Corporation of Pakistan v Wafaqi Mohtasib 2000 CLC 1593 (Sindh HC), as discussed in Constitutional Petition No D-4076 of 2016 (Sindh HC).

¹⁴ Peshawar Electric Supply Company Ltd v Wafaqi Mohtasib (Ombudsman) Islamabad PLD 2016 SC 940, as discussed in Constitutional Petition No D-4076 of 2016 (n 13); followed in Sui Northern Gas Pipelines Ltd v President of Pakistan, Constitutional Petition No D-4190 of 2016 (Sindh HC).

¹⁵ Shafatullah Qureshi v Federation of Pakistan PLD 2001 SC 142, as discussed in Constitutional Petition No D4076 of 2016 (n 13).

¹⁶ Ghulam Abbas v Telephone Industries of Pakistan (Pvt) Ltd (n 9).

¹⁷ ‘Ombudsperson moves Supreme Court against LHC verdict’ Dawn (Islamabad, 19 February 2016).

¹⁸ ibid.

¹⁹ Dawn (6 May 2016) (n 1).

²⁰ Dawn (11 May 2016) (n 2).

²¹ Dawn (16 Nov 2024) (n 3).

²² Express Tribune (17 May 2016) (n 4).

²³ Dawn (16 Nov 2024) (n 3).

²⁴ International Commission of Jurists, ‘Pakistan: 26th Constitutional Amendment is a Blow to the Independence of the Judiciary’ (ICJ, 13 November 2024).

²⁵ ‘Pakistan dispatch: two Supreme Court justices resign in protest of 27th Constitutional Amendment’ JURIST (4 December 2025).

²⁶ ‘Why two judges of Pakistan’s Supreme Court have resigned in protest’ Bar and Bench (14 November 2025).

²⁷ ‘Lahore High Court judge resigns protesting constitutional amendment in Pakistan’ Deccan Herald (15 November 2025).

²⁸ International Commission of Jurists, ‘Pakistan: Dismantling Justice – A Full-Frontal Assault on the Rule of Law’ (ICJ, 13 November 2025).

²⁹ ‘Arshad Sharif murder: Federal Constitutional Court wonders whether it can proceed with suo motu case’ Dawn (Islamabad, 3 December 2025).

³⁰ Ghulam Abbas v Telephone Industries of Pakistan (Pvt) Ltd (n 9).

³¹ ‘Empowered to hear any case involving constitutional jurisdiction, says FCC’ The Nation (21 February 2026); Constitution of the Islamic Republic of Pakistan 1973, art 175E(5) (as inserted by the Constitution (TwentySeventh Amendment) Act 2025).

³² These include the Wafaqi Mohtasib, FOSPAH, the Federal Tax Ombudsman, the Banking Mohtasib, the Federal Insurance Ombudsman, and the provincial ombudsmen of Punjab, Sindh, Khyber Pakhtunkhwa and Balochistan.

³³ ‘Assessing the Legal Authority of the Ombudsman over Serving Judicial Officers: A Jurisprudential Analysis’ (2025) Journal of Marketing & Social Research.

Bibliography

Table of Cases

• Ghulam Abbas v Telephone Industries of Pakistan (Pvt) Ltd CPLA No 464 of 2025 (Federal Constitutional Court of Pakistan, February 2026)
• Peshawar Electric Supply Company Ltd v Wafaqi Mohtasib (Ombudsman) Islamabad PLD 2016 SC 940
• Shafatullah Qureshi v Federation of Pakistan PLD 2001 SC 142
• State Life Insurance Corporation of Pakistan v Wafaqi Mohtasib 2000 CLC 1593 (Sindh HC)
• Sui Northern Gas Pipelines Ltd v President of Pakistan, Constitutional Petition No D-4190 of 2016 (Sindh HC)
• Suo Motu Case regarding arrest warrant issued against Justice Syed Mansoor Ali Shah (Supreme Court of Pakistan, 2016–ongoing)

Table of Legislation

• Constitution of the Islamic Republic of Pakistan 1973
• Constitution (Twenty-Sixth Amendment) Act 2024
• Constitution (Twenty-Seventh Amendment) Act 2025
• Establishment of the Office of Wafaqi Mohtasib (Ombudsman) Order 1983 (President’s Order No 1 of 1983)
• Federal Ombudsmen Institutional Reforms Act 2013 (Act No XIV of 2013)
• Protection Against Harassment of Women at the Workplace Act 2010
• Punjab Protection Against Harassment of Women at the Workplace (Amendment) Act 2012

Secondary Sources

• ‘A Legal Research Guide to Pakistan’ (GlobaLex, NYU School of Law)
• ‘Arshad Sharif murder: Federal Constitutional Court wonders whether it can proceed with suo motu case’ Dawn (Islamabad, 3 December 2025)
• ‘Assessing the Legal Authority of the Ombudsman over Serving Judicial Officers: A Jurisprudential Analysis’ (2025) Journal of Marketing & Social Research
• ‘Constitutional bench takes up matter of arrest warrants against fellow Mansoor Ali Shah’ Dawn (Islamabad, 16 November 2024)
• ‘Empowered to hear any case involving constitutional jurisdiction, says FCC’ The Nation (21 February 2026)
• ‘Federal Ombudsmen Institutional Reforms Act, 2013: For speedy relief’ Business Recorder (3 May 2013)
• International Commission of Jurists, ‘Pakistan: 26th Constitutional Amendment is a Blow to the Independence of the Judiciary’ (ICJ, 13 November 2024)
• International Commission of Jurists, ‘Pakistan: Dismantling Justice – A Full-Frontal Assault on the Rule of Law’ (ICJ, 13 November 2025)
• ‘Jurisdictions overstepped: Row between courts, ombudsperson deepens’ Express Tribune (17 May 2016)
• ‘Lahore High Court judge resigns protesting constitutional amendment in Pakistan’ Deccan Herald (15 November 2025)
• ‘Ombudsperson issues notice to judge in response to arrest warrants’ Dawn (Lahore, 6 May 2016)
• ‘Ombudsperson issues warrant for judge a day after apology’ Dawn (Lahore, 11 May 2016)
• ‘Ombudsperson moves Supreme Court against LHC verdict’ Dawn (Islamabad, 19 February 2016)
• ‘Pakistan dispatch: two Supreme Court justices resign in protest of 27th Constitutional Amendment’ JURIST (4 December 2025)
• Pakistan Law and Justice Commission, ‘Enhancing the Powers of Wafaqi Mohtasib’ (Report No 15)
• ‘Why two judges of Pakistan’s Supreme Court have resigned in protest’ Bar and Bench (14 November 2025)