Pakistan does not have any independent state-sponsored mechanism for investigating or documenting allegations of torture. As a consequence, torture117 is rarely investigated and seldom punished.118 The lack of safeguards at the arrest stage fosters a permissive environment for widespread custodial cruelty. While the Pakistani Constitution provides that “[e]very person who is arrested and detained in custody shall be produced before a magistrate within a period of twenty-four hours of such arrest,”119 police routinely detain individuals for days without entering them into the system.120 As a result of this practice, police have the ability to abuse prisoners before bringing them before a magistrate and, because “lawyers in Pakistan seldom visit people in police custody,”121 extrajudicial and coerced confessions are common. Once a defendant has confessed under torture, few procedural protections exist. Under Pakistani law, interrogations are supposed to be excluded on a showing of torture, but in practice, coercive interrogations are admitted regularly at trial. Often, such “confessions” are the only evidence prosecutors have against defendants, as it was for Shafqat Hussain, whose case is reviewed below. In practice, the “[l]ack of use of sophisticated methods of investigation . . . leaves the investigation team with only one method to solve a crime i.e. confession.”122 Too often, this leads the police to use torture to force confessions in order to proceed with a case. The admission of such testimonies is made easier by the low-quality representation of defendants who fail to challenge it. The Anti-Terrorism Act of 1997 (ATA) vitiates even the formal procedural safeguards afforded in regular criminal trials, notably the exclusion of confessions obtained in police custody.123 Section 21(H) of the ATA specifically permits extra-judicial confessions—such as confessions written up by the police—to be used in trials in ATC courts.124 Failure to exclude such confessions has the effect of tacitly condoning the use of coercion and torture by police to extract inculpatory testimony from detainees. Further, the Act explicitly immunizes officials from accountability for abuse: “No suit, prosecution or other legal proceedings shall lie against any person in respect of anything which is in good faith done or intended to be done under this Act.”125 Under the ATA, as detailed in the following case study, Shafqat Hussain's126 torture-procured admission of guilt became the basis for his conviction. In the majority of the 12 cases reviewed for this report, there was evidence that police tortured the defendant and that the resulting confession was critical to the conviction. The father of Kanizan Bibi,127 a woman sentenced to death and whose story is detailed later on, appealed to the Pakistani government for mercy. His letter to the government recounted the torture his daughter had suffered at the hands of the police: A “MOST SERIOUS CRIME”: PAKISTAN'S UNLAWFUL USE OF THE DEATH PENALTY 12