On 18.08.2003, the Government of Punjab issued a letter194 to the registrar of the Lahore High Court stating that the benefit of the President's Notification should apply automatically to all death row defendants who were juveniles at the time of commission of a ta'zir195 offense without the need for submission of a mercy petition. However, the President has not granted a single pardon—either for juveniles or adults—since the lifting of the moratorium in 2014. Additionally, rulings by the Federal Shari'at Court (FSC) and the Supreme Court have further undermined the ability of death row prisoners to seek pardon and commutation by the President. In a 1992 judgment, the Supreme Court held that the President had no power to commute death sentences resulting from hudud or qisas offenses, although the President retains the power to commute death sentences given as ta'zir punishments.196 In 1996, the full bench of the Supreme Court held that “[u]nder article 45 of the Constitution, the President enjoys unfettered powers to grant remissions in respect of offences . . . apart from specific cases where relief is by way of grace alone.”197 The FSC, which was created to evaluate the conformity of Pakistani laws with shari'a, ruled that the legal heirs of a murder victim are the sole persons entitled to grant mercy to the culprit.198 A Punjab Home Department official stated in 2006, “[a]ccording to the law, a death penalty can only be pardoned by relatives of victims.” 199 The Anti-Terrorism Act expressly forbids commutations or pardons: “[N]o remission in any sentence shall be allowed to a person who is convicted and sentenced for any offence [under the Act].”200 Consequently, death row prisoners have been denied the post-conviction rights to which they are entitled under international law. For example, Muhammad Amin was a minor when he was arrested in 1998 for allegedly killing a man during a burglary gone wrong. In fact, Muhammad had accompanied a classmate to the house of the classmate's stepmother and was waiting outside when he heard shots. The classmate came running from the house and fled, leaving Muhammad to be apprehended and severely beaten by police. Upon the conclusion of his trial, Muhammad received two death sentences: one for murder under the Pakistani Penal Code, and another for murder under the Anti-Terrorism Act, since the offense caused “terror, sense of fear and insecurity in the people of [the] locality.”201 Though the victim's family has pardoned Muhammad for the murder conviction, he is unable to seek a pardon and remains under threat of execution.202 The death penalty is the ultimate and irreversible punishment. Given the many procedural failings in Pakistan's criminal justice system, it is imperative that these individuals be provided with a fair opportunity to seek pardon or commutation, and to introduce new and potentially exculpatory evidence. A “MOST SERIOUS CRIME”: PAKISTAN'S UNLAWFUL USE OF THE DEATH PENALTY 24