LAHORE: The Lahore High Court (LHC) has granted post-arrest bail to a man implicated in a murder case through a supplementary statement recorded nearly nine months after the registration of the first information report (FIR), directing the Punjab police to strictly scrutinise such statements before making arrests.
Justice Muhammad Tariq Nadeem allowed the bail petition of Umer Farooq in a murder case registered at Civil Lines police station, Mandi Bahauddin, observing that implicating a suspect through a belated supplementary statement without disclosing any plausible source of information carried no evidentiary value and could not, by itself, justify an arrest.
According to the prosecution, unidentified assailants shot dead Muhammad Faisal Shahzad in November 2024. The FIR was lodged against four unknown suspects and neither the complainant nor the eyewitnesses nominated the petitioner in the initial report or their statements recorded under Section 161 of the Criminal Procedure Code (CrPC).
The judge noted that the petitioner, who had married the ex-wife of the deceased, was implicated only through a supplementary statement recorded about nine months later.
Grants bail to man implicated in murder case
During the hearing, Punjab Additional Inspector General of Police (Investigation) Shahzada Sultan conceded before the court that there was no statutory provision governing supplementary statements and acknowledged that such statements, without disclosing the source of information, were insufficient to justify an arrest.
He said the investigating officers tend to record supplementary statements just to fulfill their own ulterior and sinister motives. He assured the court that directions would be issued to investigating officers to refrain from making arrests solely on that basis.
Justice Nadeem relied on a set of Supreme Court judgments holding that the nomination of a suspect through an unexplained, belated supplementary statement renders the prosecution case doubtful and brings the matter within the ambit of further inquiry under Section 497(2), CrPC.
He further observed that an alleged confession made before the police was inadmissible under Articles 38 and 39 of the Qanun-i-Shahadat Order, 1984, and that the recovery of a pistol, without independent evidence connecting the petitioner to the offence, was insufficient to deny bail.
Rejecting the prosecution’s argument that the petitioner was involved in other criminal cases, the judge held that mere registration of multiple FIRs, in the absence of any previous conviction, could not be a ground to refuse bail.
Justice Nadeem also observed that the seriousness of an allegation alone was not sufficient to deprive a suspect of the concession of bail where the evidence warranted further inquiry.
Allowing the petition, the judge granted the petitioner post-arrest bail against surety bonds of Rs1 million.
The judge also directed the registrar office to circulate the judgment to the inspector general of police for onward dissemination among all regional, city and district police officers as well as heads of investigation across the province, requiring strict scrutiny of cases in which suspects are implicated through supplementary statements.
The IGP was further directed to submit a compliance report to the court within two weeks.
Published in Dawn, July 23rd, 2026