B. Pakistan fails to provide adequate protections to juveniles In police custody Pakistan also fails to provide adequate protections to children in police custody. Article 37(a) of the CRC imposes an affirmative obligation on State Parties to ensure that “[n]o child shall be subjected to torture or other cruel, inhuman or degrading treatment or punishment.”235 Torture, already a violation of international law, is made even more egregious by its application to juveniles. Pakistan has a clear and non-derogable duty to ensure that juveniles are not exposed to torture. In the context of criminal justice, torture heightens the likelihood that juveniles will make false confessions during interrogation. Aftab Bahadur, for instance, was tortured into confessing murder at age 15. In Aftab's words, “It would perhaps have been better not to have to think of what the police did to try to get me to confess falsely to this crime.”236 These harmful practices are perpetuated by shortcomings at the appellate phase. International law mandates that such inquiries be available at all stages in the adjudicatory process. This obligation requires a review of any evidence made available that may verify a defendant's juvenile status. Yet Pakistani appellate courts rarely question the trial court's age determination (or lack thereof), a failure that has prevented hundreds of juveniles from obtaining relief or retrials in age-appropriate proceedings. That the Pakistani government reduced some death sentences on the basis of new evidence about the defendant's age—but not others—illustrates the extent to which the government arbitrarily and inconsistently applies its own domestic law. Muhammad Amin attempted to submit evidence of his juvenility during the appeal of his death sentence. However, the Supreme Court in his case rejected the introduction of those documents, declaring that “[t]he tendering of documents . . . at this stage should also be of no avail so belatedly.” Similarly, in 2004, Muhammad Azam and Moinuddin requested commutation of their death sentence under Article 45 of the Constitution and the JJSO. Their request was quickly denied. In dismissing their petition, the Anti-Terrorism Court judge wrote: [I]t is apparent that the accused never raised any defence regarding their minority during the course of trial or before any appellate court as such it does not lie in the mouth of the convicted prisoner to agitate that they are minor. . . . The accused have also not been proceeded under the provision of [the] Juvenile Justice Ordinance 2000 and their cases have been decided much prior to the promulgation of [the] Juvenile Justice Ordinance 2000. Even otherwise [the] Juvenile Justice Ordinance 2000 does not provide that after conclusion of the case the accused may be referred to medical board for ascertainment of their ages.237 A “MOST SERIOUS CRIME”: PAKISTAN'S UNLAWFUL USE OF THE DEATH PENALTY 29