nationality for their husbands in multiple cases.22 However, reportedly, these directions for issuance of POC cards have not yet resulted in provision of citizenship to the foreign husbands. Most recently in 2024, the Sindh High Court adopted a new approach towards Section 10(2), in a case of five petitions filed by Pakistani women for citizenship of their foreign spouses. The Court reiterated that section 10 (2) of the Citizenship Act, 1951 was discriminatory towards women and therefore contrary to the Constitution of Pakistan. To avoid striking down the provision, the court relied on the doctrine of reading in to extend the scope of the Section 10(2) by adding the words “or man” and “or he” to be read wherever reference is made to “woman” and “she” in Section 10(2). The Court noted that “[t]his adjustment shall not have any effect on the operability of the statute. Indeed, had the legislators been cognizant of the requirements of Article 25 at the time, they would surely have made the adjustment themselves.” In this way, the Sindh High Court aimed to limit the discriminatory language in section 10(2) having a head-on conflict with a constitutional provision, bringing it in conformity with constitutional provisions and affirming that Pakistani women have equal rights as Pakistani men in transmitting nationality to their foreign spouse. Notwithstanding court decisions affirming women’s right to equality under citizenship laws in line with the Constitution of Pakistan, it is pertinent to note that in practice all concerned women in these cases have had to refer to the court to enforce their constitutional legal right, which is not effectively protected under the existing provision, processes and practices of the relevant departments. 22 https://www.dawn.com/news/1794394/issuance-of-pakistan-origin-cards-toafghan-spouses-of-pakistanis-ordered. See also Mst Amna and Another v. Federation of Pakistan etc. WP 1536-P/2023 (Peshawar). 12