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ISLAMABAD: In a landmark judgment expected to guide the conduct of statutory institutions for years to come, the Federal Tax Ombudsman (FTO) has laid down an enduring principle of public law: no public institution, however well-intentioned, can exercise powers beyond those expressly conferred upon it by law.

Deciding three consolidated complaints filed as Public Interest Litigation (PIL), the FTO held that while the protection of public interest is of paramount importance, the jurisdiction to entertain Public Interest Litigation rests with the superior constitutional courts and not with the Federal Tax Ombudsman established under the Federal Tax Ombudsman Ordinance, 2000.

The judgment draws a clear distinction between individual taxpayer grievances involving maladministration, which fall squarely within the FTO’s statutory mandate, and Public Interest Litigation, which is governed by Pakistan’s constitutional framework.

READ ALSO: FTO fortifies taxpayers’ privacy protections

The order emphasizes that the rule of law demands every institution act strictly within the authority granted to it by Parliament.

Rejecting the complaints for want of jurisdiction, the FTO observed that tax disputes are essentially person-specific and cannot be equated with matters traditionally falling within the domain of Public Interest Litigation. The order further notes that where superior courts specifically refer cases of alleged maladministration to the FTO, the Office is fully empowered to investigate such matters under the law.

The Federal Tax Ombudsman reiterated that the Office remains steadfast in protecting taxpayers against maladministration, abuse of authority, delay, negligence and unfair treatment by tax officials. At the same time, the Office will continue to exercise its powers with complete fidelity to the law, neither declining responsibilities entrusted to it nor assuming jurisdiction that the legislature has not conferred.

Commenting on the significance of the judgment, the Federal Tax Ombudsman observed:

“The rule of law is strengthened not when institutions enlarge their powers, but when they faithfully observe the limits prescribed by law. Jurisdiction is the foundation of every judicial and quasi-judicial forum. Respecting those limits is itself an affirmation of constitutional governance.”

The judgment is expected to serve as an important precedent on the scope of the Federal Tax Ombudsman’s jurisdiction and the constitutional boundaries governing Public Interest Litigation, providing clear guidance for taxpayers, public authorities and future litigants alike.

Copyright Business Recorder, 2026

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