Qalandar Bux was no ordinary convict — he was the Deputy Superintendent of Central Prison-I, Sukkur. He was convicted under Section 221 PPC read with the Prevention of Corruption Act for facilitating the unlawful release of three under-trial prisoners on forged release orders. His defence was that he had acted in good faith, or under a mistake of fact, invoking the protections of Sections 76 and 79 PPC.
On 17.09.2026, the Supreme Court — Mr. Justice Ishtiaq Ibrahim authoring, with Mr. Justice Naeem Akhter Afghan — dismissed the Jail Petition (against the Sindh High Court's Circuit Court Larkana judgment of 17.03.2023). The conviction and sentences recorded by the Trial Court and affirmed by the High Court were maintained; the good-faith/mistake-of-fact plea was rejected. However, since the petitioner had already served more than five years — completing the sentence — he was ordered released forthwith.
The rejection of the Sections 76/79 plea is the doctrinal core. Those provisions protect acts done in genuine good faith or under a genuine mistake of fact; they do not cover a prison officer who releases under-trial prisoners on orders a deputy superintendent should have verified as forged. Custodial office carries custodial responsibility — the higher the post, the thinner the excuse.
The case is a warning to the prison administration: forged release orders are not paperwork errors, they are corruption, and the courts will not dress them up as mistakes. Qanoon ki hifazat karne wala jab khud qanoon tore, to adalat narmi nahi dikhati — the conviction stands, even if the cell door has already opened.