Many Pakistani prisoners with diagnosed mental illnesses are on death row, with consequences both for their safety and for the deterioration of their mental health. The case files illustrated the violence death row confinement imparts on mentally ill prisoners. Khizar Hayat, who has been on death row since his conviction for allegedly murdering a fellow policeman in 2003, suffers from severe schizophrenia, for which he received an official diagnosis. His illness is a source of conflict with other prisoners who have beaten and harassed him. In 2010, a medical officer recommended that Hayat be transferred to a mental hospital after he showed signs of injuries, and after a fellow prisoner reported that Hayat was being beaten by other prisoners as a result of his mental illness. When his lawyers expressed concerns about a “deep wound” inflicted on Hayat by another inmate, a prison official responded that “such incidents are very normal in the prisons that houses 4,000 prisoners.” C. The way Pakistan notifies prisoners and their families of execution dates and stays is arbitrary and inflicts further psychological damage on prisoners. Because of the gravity around receiving notice of one's imminent execution, the way in which a state issues execution dates and stays may rise to cruel, inhuman, or degrading treatment in violation of international law. The Human Rights Committee has found gratuitous cruelty in a State's delay in giving a prisoner notice of his execution.274 It has also held that a delay in the notice of a stay amounted to cruel and inhuman treatment.275 The Committee has also found a violation of Article 7 where death row inmates were held in “death cells” for over two weeks after being issued a warrant for execution.276 Furthermore, under international law, the families of death row prisoners must be informed about a capital defendant's detention and execution.277 For example, the Human Rights Committee has foundthat a violation of Article 7 where “[c]omplete secrecy surround[s] the date of execution . . . [because it] ha[s] the effect of intimidating or punishing families by intentionally leaving them in a state of uncertainty and mental distress.”278 The Special Rapporteur on extrajudicial, summary or arbitrary executions has likewise concluded that such practices were inhuman and degrading, stating that “[r]efusing to provide convicted persons and family members with advance notice of the date and time of execution is a clear human rights violation.”279 In Pakistan, despite revised guidelines for the issuance of black warrants in 2014,280 notification to prisoners of their imminent execution remains arbitrary and at odds with international law. Mohammad Sarfraz's case illustrates how an arbitrary notification system can further infringe on a prisoner's fundamental rights. On March 16, 2016, a black warrant was issued for Mohammad by the Rawalpindi District and Sessions Court. However, the very next day, his counsel was unable to obtain a copy of the warrant, and subsequently was informed that none had been issued. Such misrepresentation hindered Mohammad's ability to avail himself of the legal and judicial remedies to which he has a right. Ultimately counsel was able to obtain a stay of execution from the Supreme Court, but the violations persisted. A “MOST SERIOUS CRIME”: PAKISTAN'S UNLAWFUL USE OF THE DEATH PENALTY 38