Even when individuals sentenced to death succeed in initiating the appeals process, higher courts often refuse to consider arguments and factual determinations that are often dubious and worthy of scrutiny. In the case of Kanizan Bibi,175 who was tortured into falsely confessing to a murder, defense lawyers challenged the confession evidence on the basis that it was involuntary. However, the Supreme Court summarily affirmed the judgments of the lower courts on the grounds that “conviction on the basis of retracted judicial confession alone is sustainable provided the confession has been recorded in accordance with law.”176 The Court declined to even acknowledge Kanizan Bibi's claim that the confession was rendered invalid by torture.177 Despite provisions in Pakistani law that supposedly allow for the introduction of new and important evidence, such requests are denied routinely. Pakistan's Supreme Court has the authority to review convictions for any reason.178 Under the Constitution, the “Supreme Court shall have power to issue such directions, orders or decrees as may be necessary for doing complete justice in any case or matter pending before it.”179 Pakistan has claimed in a report to the Office of the United Nations High Commissioner for Human Rights that this Article, as well as Article 199 and the courts inherent power to recall an order passed allows for post-conviction reviews.180 However, in practice, attempts to introduce potentially exculpatory evidence almost never succeed. Out of the 12 cases analysed in this report, requests for post-conviction review were denied in at least 4 cases. The case of Aftab Bahadur illustrates the insufficiency of post-conviction review processes. Originally convicted for murder in 1992, Bahadur claimed that police had tortured him, eliciting both a false confession as well as fabricated fingerprints to link him to the crime.181 Even so, Bahadur's trial attorney failed to question the magistrates who had overseen his confession or the fingerprint bureau officers. Despite the effort of new and competent legal representation on appeal, the judge refused to consider new evidence of the false confession or the fingerprints. The state executed Bahadur in 2015. Finally, Pakistan violates international law by failing to ensure individuals' right to appeal without undue delay. To cite just a few examples, the trial court decided Muneer Hussein's case182 in 2001, and it took six years for the High Court to hear his appeal in 2007.Ubeid Pershaad has been on death row for 13 years pending appeal. Asia Bibi was finally granted an appeals hearing in July 2015, six years after being sentenced to death on blasphemy charges. As these cases illustrate, a nominal right to appeal is meaningless unless it is effective in practice. A “MOST SERIOUS CRIME”: PAKISTAN'S UNLAWFUL USE OF THE DEATH PENALTY 21