international commitments. Furthermore, the Court highlighted that the provisions were in conflict with the teachings of the Quran and Sunnah.18 In its judgment, the Court called upon the President to take appropriate measures for the amendment of Section 10(2) and related provisions of the Pakistan Citizenship Act. It urged for swift action within a stipulated time frame of six months to rectify the discriminatory nature of the law. Specifically, the Court emphasized the necessity of providing a fair and equitable procedure for granting Pakistani nationality to foreign husbands of Pakistani women.19 A decade later in 2016, the Lahore High Court also addressed the issue of citizenship denial to a foreign national married to a Pakistani woman within the context of Article 25 of the Constitution. While the Court acknowledged that Article 25 permits classification of individuals, provided that those in similar circumstances are treated equally, it found that the denial of citizenship to a foreign national with a Pakistani wife lacked a rational basis and appeared arbitrary.20 The Court scrutinized the classification based on marital status and concluded that it did not serve any legitimate objective, nor did it align with the principles of equality enshrined in the Constitution. Accordingly, the Court directed to grant citizenship to the husband of the petitioner as per procedure and stated that denying this right under Section 10(2) of the Citizenship Act is declared as discriminatory and in violation of Article 25 of the Constitution of Islamic Republic of Pakistan, 1973. The judgment reiterates that the Constitution of Pakistan expressly prohibits gender discrimination, thereby nullifying any justification for differential treatment based on gender within the realm of citizenship laws.21 The Peshawar High Court, relying on earlier judgments against the discrimination of Section 10(2) of the Pakistan Citizenship Act, has directed for the issuance of Pakistan Origin Cards (POC) to foreign spouses (including Afghan refugees) of Pakistani women seeking 18 Suo Moto Case No. 1/K [2006] PLD 2008 FSC 1. Ibid. 20 Mrs Rukhsana Bibi v. Government of Pakistan [2016] PLD 857 (Lahore). 21 Ibid. 19 11

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