ISLAMABAD: The Lahore High Court has held that public officers appearing before judicial or quasi-judicial forums are expected to maintain restraint and institutional propriety. In the same judgment, it ruled that mere criticism, disagreement or discourtesy does not by itself amount to “derogatory language” under the Lawyers Welfare and Protection Act, 2023.
In WP No. 2344/2026 (Fakhriya Anjum vs. Inspector General of Police, Punjab, and others), Justice Tariq Saleem Sheikh allowed the petition of an FBR Commissioner. He set aside the order of the Ex-officio Justice of Peace, Lahore, dated 03.01.2026, which had directed the SHO, Police Station Civil Lines, Lahore, to register an FIR against her. The application of the Advocate Supreme Court, under sections 22-A and 22-B Cr.P.C. stands dismissed.
The dispute arose from a complaint filed before the FTO through Advocate Supreme Court, over the adjustment of an income tax refund against a sales tax demand. The petitioner, then CIR Islamabad, filed departmental comments. The advocate objected to two passages warning of “severe consequences” and of “legal action against the lawyer which he seems to have forgotten”. He said they were an attempt to intimidate him and sought an FIR under the Lawyer Welfare Act of 2023 and the PECA.
Giving “derogatory language” its ordinary meaning, the court said language is derogatory where, in context, it disparages, demeans or belittles the person addressed. It held that “mere criticism, disagreement or discourtesy does not by itself answer that description.”
Reading the impugned passages in context, the court found that the first criticised the accusation and referred to possible legal consequences, rather than disparaging the Advocate. The second was “personal and pointed” and might be discourteous, but did not amount to derogatory language.
On PECA, the court held that investigation of such offences lies with the National Cyber Crime Investigation Agency under sections 29 and 30. A direction to an SHO to register an FIR for a PECA offence therefore could not lawfully be made. Reputational harm cannot substitute for those elements.
The court did not decide territorial jurisdiction, the protections under section 227(2) and section 197 Cr.P.C., or whether section 15 of the Act of 2023 overrides them.
Nothing in the judgment approves the tenor of the petitioner’s official response. “Public officers participating in proceedings before judicial or quasi-judicial forums are expected to maintain restraint and institutional propriety: LHC ordered.
Copyright Business Recorder, 2026
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