Not to take away from the fact that the articles is primarily about blasphemy laws, the key stepping-stone for Islamization and tightening of the blasphemy laws in Pakistan was provided by Bhutto-orchestrated constitutional amendment to declare Ahmadis non-Muslim. This singular event paved the way for what became of Pakistan. [Ahmadiyya Times Editor]
Source/Credit: View Point Online
By Anqa Dehlvi | February 21, 2013
Pakistan was one of the few Muslim countries to back the United Nations Development of Human Rights (UDHR) on the issue of Article 18, which was concerned with the freedom to change one’s religion. Headed by Sir Zafarullah Khan, Pakistan ardently supported the right to change one’s religion
In this essay, I shall try to analyze the reasons behind the continued relevance of Pakistan’s blasphemy laws, especially section 295-C, and the underlying reasons behind its ‘untouchability’.
As was exemplified by the killings of Governor Salman Taseer and Shahbaz Bhatti [1], blasphemy laws continue to be viewed as an extremely sensitive issue in Pakistani society. Blasphemy has been a contentious issue in many post-colonial states torn between what they perceive as their societal notions and values on one hand, and an obligation to uphold universal secular values such as free speech [2].
Just as the promulgation of blasphemy laws has affected the socio-political climate in Pakistan, the reverse has also taken place. The growth of highly vocal religious organizations and the corresponding societal pressure have greatly compromised the independence of judiciary as an institution. One finds many cases in which the judges have caved in to pressure from outside, and this has only increased the arbitrariness in legal judgments. Thus one finds a complex interplay between various factors at work here; legal, societal, international as well as state-controlled. The issue of blasphemy is not solely a legal question, but it has ramifications on society, politics and the state as well.
Hence, in this essay, my approach shall be to analyze the issue from various perspectives, and thus I shall try to discern the reasons behind their persistent relevance and the resulting ‘untouchability’.
The Raj years
During the colonial era, the Raj followed a policy of religious neutrality. The colonial government viewed religious conflict as a potentially destabilizing force, and hence it always treated communal passions with extreme caution. In the light of this, it instituted several laws which criminalized religious offence [3]. In keeping with the Raj’s policy of religious neutrality, these laws were not specific to a particular sect or community. For instance, if one takes a look at article 298 of Pakistan’s penal code:
‘Uttering words, etc., with deliberate intent to wound religious feelings: Whoever, with the deliberate intention of wounding the religious feelings of any person shall be punished with imprisonment of either description for a term which may extend to one year or with fine, or with both [4].
As one can observe, the laws lay great stress on proof of intention and ‘malice’. Not only was it necessary that the act of blasphemy was proved, it was also important that the ‘deliberate intent’ of the accused be established beyond reasonable doubt.
Another deterrent to potential misuse of blasphemy laws during this time was the requirement of compliance with the Section 196 of the Code of Criminal Procedure (CrPC). Under Section 196, a court could only take cognizance of an offence under section 295-A only ‘upon complaint made by order of, or under authority from the Central Government, or the Provincial Government concerned, or some officer empowered in this behalf by either of the two governments [5]. In other words, complaints against blasphemy couldn’t be filed by private individuals. This drastically refused the scope of misuse and abuse of blasphemy laws for personal vendetta, as it has been observed in some of the recent cases.
During the initial phase of Pakistan[s statehood, it continued to practice a policy of religious neutrality. Except for a token allegiance to Islam in it’s constitution as a way of appeasing the conservatives, the state was largely committed to non-interference in religious affairs. This was not least due to the ideological orientation of its state machinery, which was largely trained under the Raj, and thus was firmly grounded in the principles of neutrality.
A telling example of this attitude is the report of the Munir Commission (1954), which was instituted in the wake of Anti-Ahmadi protests in Pakistan. This report explicitly stated that it wasn’t the state’s business to declare a person Muslim or Non Muslim. Religion was thus considered a largely private affair, and subject to one’s personal faith and belief [6].
Pakistan was also quite pro-active on the issue of human rights internationally. It was one of the few Muslim countries to back the United Nations Development of Human Rights (UDHR) on the issue of Article 18, which was concerned with the freedom to change one’s religion [7]. Headed by Sir Zafarullah Khan, Pakistan ardently supported the right to change one’s religion. Moreover, Zafarullah Khan put forth the view that this position was completely in compliance with Islam [8]. In 1968, a renowned jurist S A Rehman observed that death penalty for apostasy was against the tenets of Islam [9].
Post-1971
After the loss of East Pakistan in 1971, the Pakistani nation underwent an ideological crisis. The loss put a huge question mark over the relevance of Islam as the great unifier. Interestingly enough, instead of reducing it’s relevance on Islam, the centrality of Islam to Pakistan’s political discourse increased during this period. This can be attributed to two reasons. First of all, with the creation of Bangladesh, religious minorities had been rendered numerically insignificant. Second of all, the fear of ethic separatism only increased the state’s reliance on Islam to keep dissenting voices in check [10]. Thus, in 1973 a new constitution was promulgated which declared that Pakistan was an ‘Islamic Republic’.
However, the real shift towards Islamisation took place under the Zia regime. Zia-ul Haq, a military dictator seized power from Zulfiqar Ali Bhutto.
Zia-ul Haq cleverly utilized Islamic rhetoric to legitimize his own rule, whilst at the same time bolstering his support amongst religious parties [11]. As was mentioned earlier, Islamisation also served as a tool to quell dissent. The most visible ramification of this policy was the blasphemy laws, which were implemented the early eighties.
These laws essentially criminalized any act of blasphemy against Islam. In form and content, they marked a significant departure from previous provisions against blasphemy. For instance, article 295-C states that
‘295-C.Use of derogatory remarks, etc., in respect of the Holy Prophet: Whoever by words, either spoken or written, or by visible representation or by any imputation, innuendo, or insinuation, directly or indirectly, defiles the sacred name of the Holy Prophet Muhammad (peace be upon him) shall be punished with death, or imprisonment for life, and shall also be liable to fine [12].
If one compares this section to previous legislations incorporated during colonial era, one finds that in the latter, a heavy burden of proof was placed on the accuser. However, in section 295-C one finds that there is no mention of ‘deliberate intention’; rather, even an ‘innuendo’ by the accused can make him/her liable for punishment. Furthermore, the severity of punishment has also increased substantially.
Also, one finds that besides affirming the paramountcy of Islam vis-à-vis other religions, these laws also de-legitimize any heterodox conception of Islam. For instance, Section 298-A (which criminalizes blasphemous remarks against the righteous caliphs) explicitly targets the Shias, a minority Muslim sect in Pakistan. Laws like these have a limiting influence on the concept of citizenship, and it effectively establishes the state as the arbiter of belief and faith [13]. Thus, not only do the blasphemy laws serve as a deterrent against non-Muslims, but also against those Muslim sects who are not willing to toe the government’s line on religious matters.
Socio-religious aspects of blasphemy law
Although the amendments during Zia’s regime were largely state driven and followed a rather ‘top-down’ approach, it had a considerable effect on the socio-political climate of Pakistan. However, the changes in legal system were symptomatic of the increasing politicization of Islam in Pakistan.
Under the Zia dictatorship, there was a spurt in the number of sectarian organizations and seminaries in Pakistan [14]. Although not all of these organizations were politically active; nevertheless, they exerted what is known as ‘street power’, which was a manifestation of their reactionary and vocal nature, and the ability to mobilize the masses on the basis of religious sentiments.
This increasing politicization of Islam had quite a significant impact on the perception of Islam in Pakistan. Traditionally, most Pakistanis have been followers of the Barelvi sect. This sect traditionally enjoyed mass acceptance due to their toleration of indigenous customs like shrine worship, intercession etc. In practice, this version of Islam was highly non- scriptural. However, with the rise of Zia’s Islamisation, this version of Islam began to give way to a highly textual and standardized version, as advocated by the Deobandis and Ahl-e-Hadith.
In these schools, much importance was given to proper ‘Islamic law’ and procedures, and local customs were often branded un-Islamic. Thus, Islam in Pakistan gradually acquired rigidity, especially in urban areas [15]. This also led to a rise of a political class of ulema, who were generally more vocal in their demands to align state polity with Islam. However, it would be incorrect to make watertight assumptions about Barelvis as moderates and Deobandis and Ahl-e Hadith as more ‘extreme’ in their outlook. After all, Salman Taseer’s assassin was a Barelvi. The sect’s reverence towards Prophet Mohammed can be traced back to its founder, Ahmad Riza.
Hyphenation of blasphemy with apostasy
The change in the nature of ‘Islam’ in Pakistan is well reflected by societal attitudes towards contentious issues like apostasy. Since the advent of the British rule, several Muslims belonging to lower sections of society had converted to Christianity in order to gain social mobility [16]. Although traditional Islamic law considers apostasy to be a hudd crime, such events generally went unnoticed in the countryside. From the point of view of state policy, the judiciary adopted a tolerant attitude on the issue of apostasy, and this is exemplified by jurists like S.A. Rehman and Munir, who were of the view that death penalty for apostasy was not only incompatible with modern thought, they were also against the spirit of Islam. Interestingly, even Zia ul Haq did not include apostasy as a hudd crime in his infamous Hudood Ordinances.
Consequently, in the absence of laws prohibiting apostasy, the ulema started hyphenating the crime of blasphemy with apostasy. Although the Hanafi school makes a distinction between apostasy and blasphemy, the former being a hudd crime, and the latter a taazir offence, the differences were not always delineated. Certain ulema have argued that a Muslim blaspheming against his religion effectively abandons his faith, thus making him subject to hudd punishments. Furthermore, certain Islamic texts like the Hedaya clearly state that an apostate should be considered as an outlaw, and thus s/he is not liable to be protected by the state [17]. What this indirectly implies is that if a Muslim was to kill an apostate, he would not be liable to state punishment. Such line of thinking gave legitimacy to the concept of vigilante justice and the rise of non-state actors as arbitrators of justice.
Gradually, this attitude towards apostasy percolated downwards in the society. Pakistan has been a witness to several extra-judicial killings, against alleged blasphemers, as well as those who sought to defend those wrongly implicated for such crimes [18]. The case of Salamat Masih [19] deserves a special mention in this regard.
This case involves two Christian men, Rehmat Masih and Manzoor Masih, and an eleven-year-old Christian boy Salamat Masih. Following a small quarrel, some villagers accused these people of blasphemy. On the day of the hearing, a mob had gathered outside the courthouse demanding capital punishment for the accused. Realizing the pressure, the court transferred the case to Lahore, where the court was finally able to come to a settlement on the matter. However, tragically, while the accused were being escorted out of the courthouse, someone opened fire, killing Manzoor Masih [20].
The Salamat Masih case is a powerful reminder of the manner in which the issue of blasphemy has ceased to be merely a question of Islamic law. The issue has become so sensitive that any sort of debate or introspection seems out of question as David Forte points out in his paper titled, ‘The mechanism of suppression is self enforcing in the laws of apostasy or blasphemy’ [21]. Apart from the victims, even the people who support some reform in blasphemy laws have not been spared. The case of Asia Bibi is relevant on both counts. This case involves a poor Christian woman who was accused of blasphemy by her fellow villagers. The court of Nanakana Sahib awarded her a death penalty [22].
Following the court verdict, several civil rights groups and senior politicians denounced the decision. The Governor of Punjab, Salman Taseer, himself appealed to the President to grant pardon to Asia Bibi. Subsequently, Salman Taseer was strongly criticized by religiously conservative sections of Pakistani society. On the 5th of January, 2010 Salman Taseer was gunned down by his own bodyguard in Islamabad [23].
The murder of Governor Taseer sent shockwaves across the country. The political classes in Pakistan became wary of touching upon the issue of blasphemy.
Super ordinate nature of Sharia vis-à-vis state law
This trend of vigilante justice also reveals the inherent tension between (secular) state law and Sharia/Islamic Law in contemporary Muslim states. After the end of colonialism, many states had inherited legal systems of their erstwhile rulers. In the case of Pakistan, its legal system was largely based on Anglo-Indian law. The Anglo-Indian law was largely secular and religion was largely relegated to the private sphere in the guise of ‘Personal Laws’.
Even in the sphere of personal laws, the British had introduced several important changes. For instance, in traditional Islamic law, an apostate from Islam lost all his claims to inheritance. The British removed this clause from Muslim personal law [24].
However, despite this constitutional laxity, there is a perceived level of societal sanction for punishment against apostasy. This is indicative of the mentality that Sharia is somehow super ordinate to state law [25].
This super ordinate position of Sharia is often attributed to the popular belief of its divine origins. Sharia, as perceived by many sections, is not a methodology of Islamic jurisprudence but the word of god itself [26].
This notion of ‘god’s law’ was also voiced by several conservative thinkers in the wake of Governor Taseer’s murder. One such columnist Ansar Abbasi thus wrote in an editorial of the Urdu daily the Jang:
Certain Westernised sections of Pakistani society have used Salman Taseer’s assassination for their own personal agenda of abolition of laws regarding Blasphemy against the Holy Prophet. These ‘enlightened classes’ have tried to portray this law as ‘man made’. By doing so, they have tried to stifle the proper implementation of Islamic laws in this country [27].
It is evident from the above extract that although the blasphemy laws were promulgated by Zia ul Haq, there is a wide acceptance of the belief that the laws are indeed derived from Islamic law, and hence are immune to any suggestion of repeal or abolition. As a result, even the suggestion of amendment to blasphemy laws has met with vehement opposition. This opposition of resistance to reform was quite evident in the ruckus surrounding the blasphemy law amendment bill introduced by Sherry Rehman, a senior politician and leader of the Pakistan People’s Party (PPP). Some of the key points of this bill were
5. In sections 295 C, 298A of the Pakistan Penal Code after the word, ‘Whoever’, the words ‘maliciously, deliberately and intentionally’ be added.
6. In section 298B of the Pakistan Penal Code after the word ‘or by visible representation’, the words, ‘maliciously, deliberately and intentionally’ be added.
7. A section 203 A be added to the Pakistan Penal Code to say, ‘Anyone making a false or frivolous accusation under any of the sections of 295A, 295B and 295C, of the Pakistan Penal Code shall be punished in accordance with similar punishmentsprescribed in the section under which the false or frivolous accusation was made [28].
As one can infer from its tone, the reforms suggested by Sherry Rehman were quite ‘mild’ and in no way suggested the abrogation of blasphemy laws. Rather, their main aim was to remove some of the design defects in the original text of the legislation. Point no.6 suggests the inclusion of ‘intent’ as a pre requisite to prove the crime of blasphemy. Similarly, point no.7 borrows heavily from the approach of Protection of Women Act, 2006. Hence, the main intent behind this bill was to remove the procedural inadequacies that existed in blasphemy laws which gave rise to their rampant abuse [29].
However, in spite of the careful drafting of the bill, it was widely denounced by politico-religious organizations like Tehreek-e-Namoos-e-Risalat (Movement for the Honour of Prophethood). An article published in the Urdu daily Nawa-i-Waqt, stated:
Tehreek-e-Namoos-e-Risalat today announced protests against the proposed amendments to Blasphemy laws regarding the Honour of the Holy Prophet. It was announced that thousands of people are ready to die for this cause. The honourable ulema said that we’ll lay down our lives, but we’ll not tolerate any insult to the prophet. The ulema also said that this issue is of foremost importance to the nation, this law has not been made by any dictator, it is the law of Islam [30].
If one carefully analyzes the above extract, it is seen that the defence against any proposed amendments to blasphemy laws took place on two levels. Initially, the emotional relevance of the issue is clearly articulated. Phrases like ‘We’ll not tolerate any insult’ and ‘thousands of people are ready to die for this cause’ are meant to sentimentalize the issue and thus make it immune to any logical or rational scrutiny.
Secondly, the ‘Islamic’ nature of the act is again emphasized, which is aimed at bolstering the ‘immutability’ of the said legislation. Hence, supporters of blasphemy laws carefully mix emotionalism along with appeals to uphold Islamic law in order to garner support amongst the masses, and simultaneously curb dissent or criticism.
Besides societal attitudes, the inclusion of article 2-A in the constitution, which made the Objectives Resolution a legally justiciable part of the constitution helped consolidate the position of Islam in Pakistan’s legal system. Jurists like Tanzil ur Rehman opined that article 2-A was the grundnorm of the constitution, and no laws could be made in violation of article 2-A [31]. In effect, the inclusion of Objectives Resolution gave a constitutional safeguard to the question of Islam vis-à-vis State Law.
The judicial response
In this section, I shall try to examine the attitude of judiciary towards the issue of blasphemy by examining the relevant case law. By doing so, I hope to shed some light on the actual implementation of these laws, and any discrepancies that may arise thereof.
Pre-Zia era:
As has been mentioned earlier, Pakistan inherited a lot of its judicial apparatus from the colonial state. Pakistani law is still heavily grounded in Anglo-Indian law. During the initial years of its statehood, Pakistani jurists had been trained under the colonial state, and most of them were firmly ensconced in the ‘modernist’ camp. The colonial state laid strong emphasis on neutrality in religious matters, both in principle and in practice. Also, the status of judiciary as an independent institution had not been as severely compromised as it did during the Zia era.
If one examines Pakistani case law during this time period, one finds strong evidence of this attitude amongst Pakistani jurists. The case of Punjab Religious Book Society vs. State, 1960 is especially relevant in this context [32]. This case involves the publication of a book Mizan ul Haq, which compared Islam and Christianity. The Home Department declared that the book ‘outraged the religious feelings of Muslims’. The observations of the court regarding the case are as follows:
As was but to be expected the object of the author, who was a Christian was to show that Christianity was a true religion and Islam was not. The author did not deny that his object was to show the superiority of Christianity over Islam, but he has said at more places than one that he had no intention of injuring the feelings of Muslims whom at places he had called his brethren [33].
Evidently, the courts took an extremely balanced and objective view of the whole matter. The last sentence indicates that since the accused had no visible ‘intention’ of outraging Muslim sentiments, he could be presumed innocent. Also, if one looks at the first part of the extract, one can indirectly infer that the judge has indirectly laid great stress on freedom of speech, and freedom to profess and propagate one’s religion. The court has stated it in a very unequivocal manner that each adherent believes his faith to be superior. However, his belief in superiority of his religion is not to be interpreted as denigration of the other.
Post-Zia Era:
However, this relative consistency and liberalism during the early years was not to continue after the Zia regime. These changes happened on two levels.
Constitutionally, the blasphemy laws were amended to remove the emphasis on intent. In doing so, the burden of proof was transferred from the prosecution back to the defendant. Moreover, the influence of politically active religious organizations deterred courts from taking a stand which might have been perceived as ‘un-Islamic’. Also, if one looks at various cases regarding religious offences, one finds a lack of uniformity in approach.
Firstly, it has been observed in many cases that the convictions pronounced by lower courts are generally not upheld by higher courts. For instance, in the case of Younas Sheikh, 2001, the session’s court upheld charges of blasphemy and sentenced him to death. However, this decision was later overturned in 2003 [34]. Similarly, in Pir Zahoor Ahmed vs. State, the Lahore High Court overturned the conviction awarded to the accused by the lower court [35]. The court cited lack of evidence as the main motivation behind the verdict. Similarly, in Qari Mohammed Younus vs State [36] the court overturned an earlier decision of life imprisonment citing that the case had not been lodged in accordance with CrPC 196 [37]. Curiously, this particular section of Criminal Procedures only applies to section 295-A, and not 295-C.
However, the court has also upheld several convictions relating to blasphemy crimes. The case of Haji Bashir Ahmed vs. State [38] is especially relevant. The lower court had given the death sentence to the accused. When the matter was taken to the Lahore High Court, the defence argued that some of the witnesses were members of Tehreek- e-Khatm-e-Naboowat, a radical group which actively champions blasphemy laws in Pakistan. However, the court held that their testimonies were true, and that the evidence regarding the crime was satisfactory to uphold the conviction.
Blasphemy laws vs. fundamental rights
Another landmark case, but this time under section 298-C, also throws some light on the inconsistency displayed by the Pakistani judicial system. Known widely as the Zaheeruddin case [39], the case concerns the rights of the Ahmadiyya community to profess and practice their faith. It reveals the underlying tensions between blasphemy laws and freedom of religion in Pakistan. In a landmark judgment, the court over-ruled the claims by Ahmadiyya community in which they challenged section 298-C on grounds of article 20, which guarantees freedom of religion to all Pakistanis. Elaborating on the matter, the court noted that the use of Islamic symbols by Ahmadis could offend Muslims. To this end, one of the judges from the majority bench noted that:
Anti Islamic Activities of the Quadiani Group, Lahori Group and Ahmadis (Prohibition and Punishment) Ordinance, 1984 gives the actual epithets, the descriptions and also titles and other requirements sought to be protected or imposed. It is also stated that they cannot be used for entities or situations other than those for whom they have been prescribed...The legislation was, therefore, necessary which in any way does not interfere with the religious freedom of the Ahmadis; for it only prohibits them from using those epithets etc., on which they have no claim of any nature. It does not prohibit them from coining their own.
As one can see, the language employed by the judges was rather biased and intemperate. Also, interestingly, in spite of the direct relevance of Article 19 (which promises freedom of speech and expression) with the case, the majority bench clearly avoided discussion on the issue. One finds only a passing mention of freedom of speech in the minority judgment:
Article 19, Constitution of Pakistan (1973) which guarantees freedom of speech, expression and press makes it subject to reasonable restrictions imposed by law in the interest of glory of Islam etc., and decency or morality. The restrictions given therein cannot, be imported into any other fundamental rights.
The Zaheeruddin case thus clearly established the supremacy of ‘Islamic principles’ over fundamental rights otherwise granted by the constitution. This case is a clear example of the glass ceiling on these fundamental freedoms in Pakistani society.
Conclusions
The issue of blasphemy laws in Pakistan is not only of legality, it is also heavily influenced by external factors. The complex interactions between state, society and politics have made the issue a bit of a legal quagmire, with no foreseeable solution in sight. These laws were introduced in a top down fashion by the state in order to control dissent and quell the conservatives. Ironically however, their rampant politicization on the societal level has now made the state a minor stakeholder on the blasphemy issue.
This controversy has only reconfirmed the fact that ‘Islam’ has acquired a central role in Pakistan’s political discourse. All discussions on blasphemy law, whether made by liberals or conservatives, are strictly made within an Islamic framework. The mere hint of a ‘secular argument’ is now considered dangerous and provokes a hysterical reaction from the more vocal elements of Pakistani politics. The noise surrounding the issue has insured that the persistent ‘untouchability’ of these laws.
Due to the sensitive nature of the laws and their potential socio-political fallouts, an effective approach should not be solely constitutional; a comprehensive overhaul of public discourse in Pakistan is also necessary. Merely concentrating on legal reforms will only serve a cosmetic purpose; the malaise runs much deeper. Looking at the current situation, one is perhaps reminded of the Punjabi poet Bulleh Shah, who once remarked
Bulleya aashiq hoyo rabb da,
hoi malaamat lakh,
Tainu kaafir kaafir kainday,
tu aaho aaho aakh
[Bulla, the lover of God!
a thousand accusations on you.
They call you infidel, infidel!
You say so it is, so it is]
References:
1 Dawn, Shahbaz Bhatti Profile, http://www.dawn.com/2011/03/02/profile-shahbaz-bhatti.html
2 Talal, Asad, Free Speech, Blasphemy, and Secular Criticism, http://escholarship.org/uc/item, p.1
3 Ahmad, A., Spectres of Macaulay in Censorship in South Asia, Mazzarella and Kaur, Bloomington, Indiana University Press, p.180
4 Constitution Of Pakistan, http://www.pakistani.org/pakistan/legislation/1860/actXLVof1860.html
5 Lau, Martin, Offences Against Religion in Pakistan. A Review in: Dewa, Swati (ed.), Law and (In) Equalities, Delhi: Eastern Book Company, 2010, chapter 7, p.177
6 Munir Commission Report, http://www.thepersecution.org/dl/report_1953.pdf, p.241
7 Khan, Amjad Mahmood, Persecution of the Ahmadiyya Community in Pakistan: An Analysis under International Law and International Relations, in: Harvard Human Rights Journal, 16, 2003, p.221
8 Ibid, p.222
9 Forte, David, Apostasy and Blasphemy in Pakistan, in: Connecticut Journal of International Law, 10:27, 1994-1995, p.50
10 Nasr, S. , Leviathan, p.138
11 Ibid, p.138
12 Constitution, http://www.pakistani.org/pakistan/legislation/1860/actXLVof1860.html
13 Yasmeen, S., "Islamisation and democratisation in Pakistan: Implications for women and religious minorities." South Asia-Journal of South Asian Studies, p.188
14 Nasr, S., "International politics, domestic imperatives, and identity mobilization - Sectarianism in Pakistan, 1979-1998." Comparative Politics 32(2), p.174
15 Zaman, M., "Sectarianism in Pakistan: The Radicalization of Shi'i and Sunni Identities." Modern Asian Studies 32(3), p.690
16 Forte, Apostasy, p.50
17 Ibid, p.47
18 Ibid, p.54
19 Salamat Masih vs State, (1995) 28 P.Cr.L.J. 811(Lahore)
20 Forte,Apostasy, p.64
21 Ibid, p.53
22 Dawn, Christian Woman Sentenced to Death, http://www.dawn.com/2010/11/12/christian- woman-sentenced-to-death-in-blasphemy-case-2.html
23 Dawn, Blasphemy Law claims another life, http://www.dawn.com/2011/01/05/blasphemy-law- claims-another-life.html
24 Forte, Apostasy, p.49
25 Ibid, p.52
26 Mahmud, Tayyab, Freedom of Religion and Religious Minorities in Pakistan: A Study of Judicial Practice, in: Fordham International Law Journal, 19:40, 1995, p.83
27 Jang,
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