The fourth non-prosecution dismissal of the day completes the set. M/s Kurative Pharma International's income tax reference (3 of 2021) against the Commissioner Inland Revenue met the same fate as the LIOYD, Tarom, and Bestow Interior references: dormant for years, no effort by the applicant to prosecute, unrepresented at the hearing — dismissed for non-prosecution by the division bench of Justice Agha Faisal (author) and Justice Shah Nawaz Memon, following Commissioner Inland Revenue v. Rafeh Limited (PLD 2020 SC 518).
The legal point this case underlines is worth stating separately: a reference application's age does not save it. It does not matter whether the reference is from 2005 or 2021 — what matters is whether the applicant is prosecuting it. Abandonment kills the reference; the calendar does not rescue it.
For corporate litigants, this is a governance lesson as much as a legal one. Companies change tax consultants, in-house teams turn over, and old High Court files slip through the cracks. Kurative Pharma's case shows what the crack costs: the entire reference, gone, with the department's position left intact and the merits never examined.
The day's four dismissals together form a pattern practitioners should treat as a standing warning from this bench: prosecute your references or prepare to lose them. File the listing application, keep counsel instructed, appear on the date fixed. Qanoon unhi ka saath deta hai jo apna case khud larte hain — the court will not fight your reference for you.