IV. INEFFECTIVE LEGAL REPRESENTATION Pakistan does not provide indigent capital defendants with effective legal assistance. All defendants are entitled to effective legal counsel under international law.130 In death penalty cases, according to the Human Rights Committee, it is “axiomatic that the accused must be effectively assisted by a lawyer at all stages of the proceedings.”131 “[B]latant misbehavior or incompetence”132 violate this standard. Where it is “manifest to the judge that the lawyer's behaviour was incompatible with the interests of justice,”133 the state violates the Article 14 right to fair trial.134 Though Pakistan provides indigent capital defendants with counsel at state expense,135 the quality of representation is poor. The International Federation for Human Rights notes that, for the most part, state-appointed counsel are “young and inexperienced lawyers, or briefless ones.”136 Furthermore, Pakistan does not provide for recourse to justice due to incompetent or ineffective counsel.137 More than half of the defendants in the cases reviewed suffered from inadequate representation by state-appointed lawyers in the early stages of their cases. In some, egregious errors by these lawyers directly resulted in convictions based on false testimony and in the execution of juveniles and members of other vulnerable groups that are owed special protection under international law. For instance, Zulfiqar Ali Khan138 spent sixteen years on death row prior to his execution on May 6, 2015, by firing squad. When the prosecution presented falsified witness statements during his trial, Zulfiqar's stateappointed lawyer failed even to challenge this testimony, causing irreparable damage to his case. Aftab Bahadur also was provided with a state-appointed lawyer at trial. This lawyer like wise failed to produce any evidence or witnesses in defense of Aftab. A “MOST SERIOUS CRIME”: PAKISTAN'S UNLAWFUL USE OF THE DEATH PENALTY 16