issue despite the recognition of such a duty under Pakistani law. As a 2004 Supreme Court opinion noted: Irrespective of the fact, whether the issue of the age of an accused person is or is not raised before the Court, it is the obligation of the Court to suspend all further proceedings in a trial and hold an inquiry to determine the age of the accused, if and whenever, it appears to be necessary… It would be horrendous to visualize a “CHILD” or a “MINOR” being hanged to death only because the question of his minority had not been raised before the relevant Court. It is the function of the Court to ensure that no illegality is permitted to occur and no injustice is allowed to creep into its decisions.227 Worse still, the appellate process provides little relief in cases where defendants do successfully broach the issue. Datasets of juvenile cases suggest that many defendants' attempts to use documentary evidence, including that issued by government authorities, to support their claims of juvenility fail, both at the trial and appellate levels.228 Pakistani courts remain divided on the evidentiary value of conflicting records,229 and empirical data indicates that there is no apparent consistency of age-determination procedure adopted by the courts; in practice, they are free to choose any evidence that favors the verdict of their choice. Birth certificates are often rejected outright as forgeries, despite the fact that they are government-issued documents. Similarly, medical board reports and school-leaving certificates are often deemed to be inaccurate or fabricated. As a result, juvenile defendants are left with no options to rebut the presumption of adulthood made by the arresting police.230 The age-determination inquiry for Shafqat Hussain231 epitomizes the egregious but all-too-common failure of judicial safeguards for juveniles, particularly within the ATA. As one report notes, “Section 32 of the Anti-Terrorism Act gives the Act overriding effect over all other laws, ruling out a trial for the juvenile accused under the JJSO. In more than one instance, high courts in Pakistan have insisted that juveniles charged under the ATA cannot have a separate trial [and that] a court under the ATA has complete jurisdiction to try any offence irrespective of whether the offender is a minor or not.”232 Pakistan's Federal Investigation Agency relied on five trial court documents suggesting that Shafqat was 23 at the time of the offense. However, all five derived from the original flawed arrest certificate, which simply recorded the police's incorrect overestimation of Shafqat's age. This mistake condemned him to adult proceedings and, in turn, a death sentence. Another juvenile offender, Ansar Iqbal, was 14 years old when he was arrested in 1994 for the murder of a neighbor. The victim's family claimed that Ansar killed the neighbor over an argument at a cricket match, but Ansar said police framed him after planting two guns at his house.233 At trial, defendant's counsel raised the issue of juvenility and offered both a school record and a government-issued Form-B National Registration Document as evidence in support of that claim. The trial court dismissed both the school record (on the ground that it was inadmissible because the record keeper had not testified) and the Pakistani Form-B (on the ground that it was a “duplicate document” and bore “discrepancies”).234 Instead, the trial court relied upon the police's assessment that Ansar was 22 or 23 years old. By trying Ansar as an adult, the court subsequently permitted him to be sentenced to death. A “MOST SERIOUS CRIME”: PAKISTAN'S UNLAWFUL USE OF THE DEATH PENALTY 28