contain fundamental rights that adopt the terminology of ‘person’ versus ‘citizen’ in the text itself. To provide a comparative example, Article 9 states, “No person shall be deprived of life or liberty save in accordance with law” ... while Article 15 on freedom of movement states, “every citizen shall have the right to remain in…enter and move freely throughout Pakistan and to reside and settle in any part thereof.” Article 9 applies to all persons, which includes foreigners (including refugees) in Pakistan, while Article 15 is a protected right of only a citizen of Pakistan. This differentiation has also been acknowledged by the higher courts of Pakistan in various judgments, which emphasize that certain rights delineated in the Constitution are exclusively reserved for citizens of Pakistan. For instance, rights such as freedom of movement (Art. 15), assembly (Art. 16), association (Art. 17), trade (Art. 18), and speech (Art. 19) are exclusively available to citizens. Conversely, certain fundamental rights, including the right to life (Art. 9), protection against unlawful detention (Art. 10), and the inviolability of human dignity (Art. 11), are afforded to all individuals within Pakistan's jurisdiction, irrespective of their nationality.2 It is therefore the State’s constitutional obligation to protect fundamental rights of refugees, as persons, guaranteed under the Constitution, even in the absence of any other law in place for protection of refugees, asylum seekers and related groups in the country. 2 Umar Ahmad Ghumman v. Government of Pakistan and Others [2002] PLD 521 (Lahore); Rahil Azizi v. Federation of Pakistan WP 1666 of 2023. 2