215 CRC, art. 40(2)(b)(iii). 216 RODLEY & POLLARD, supra note . 217 Comm. on the Rights of the Child, General Comment No. 10, ¶ 39, U.N. Doc. CRC/C/GC/10 (2007). 218 U.N. Office of the High Commissioner for Human Rights, UN experts urge Pakistan not to execute juveniles (Mar. 20, 2015), http://www.ohchr.org/EN/NewsEvents/Pages/DisplayNews.aspx?NewsID=15729&LangID=E. The expert panel included Christof Heyns (the UN Special Rapporteur on extrajudicial, summary or arbitrary executions), Juan E. Méndez, (the UN Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment), and Kirsten Sandberg (the Chairperson of the UN Committee on the Rights of the Child). 219 Id. 220 Juvenile Justice System Ordinance of 2000 (XXII of 2000) [hereinafter JJSO]. 221 Zafar v State, 2001 PCrLJ 1939; see also Khurshid Iqbal, Judging Juvenility: Determination of Age of Juvenile Offenders Under Pakistan's Juvenile Justice System, 1 PAKISTAN J. CRIMINOLOGY 105, 109 (2009), http://www.pakistansocietyofcriminology.com/publications/Vol1No3Oct009.pdf. 222 JJSO, § 55. 223 Id. Concluding Observations of the Comm. on the Rights of the Child: Pakistan, ¶ 41, U.N. Doc. CRC/C/PAK/CO/3-4 (2009). 224 225 U.N. Office of the High Commissioner for Human Rights, Death Penalty: Pakistan Continues To Execute Child Offenders in Spite of UN Experts' Appeals, (Oct. 2, 2015), http://www.ohchr.org/en/NewsEvents/Pages/DisplayNews.aspx?NewsID=16560&LangID=E#sthash.71HcxlfK.dpuf. 226 Shafqat's Lawyers Concerned About Premature Conclusion to FIA Inquiry, DAWN (Apr. 2, 2015), http://www.dawn.com/news/1173471; see also FIDH, Slow March, supra note , at 38. 227 Sultan Ahmed v. Additional Sessions Judge, PLD 2004 SC 758. 228 See JPP Empirical Data Set (on file with authors). 229 Khurshid Iqbal, Judging Juvenility: Determination of Age of Juvenile Offenders Under Pakistan's Juvenile Justice System, 1 PAKISTAN J. CRIMINOLOGY 105, 108-112 (2009), http://www.pakistansocietyofcriminology.com/publications/Vol1No3Oct009.pdf. 230 The FIDH notes other cases of Pakistani juveniles being subjected to the death penalty, including Mutaber Khan. Khan claimed to have been 16 at the time of commission of his crime, and attempted to prove it with a school certificate and evidence that he had been kept two years in the child section of the Central Prison. However, his appeal was rejected on the grounds that the order to commute death penalty into life for all juveniles should not affect him, since his age had not been recorded at trial. See FIDH, Slow March, supra note , at 38. 231 For details on Shafqat Hussain's case, please see page 21. 232 Fahmina Naz, Pakistan: Out of the Frying Pan, Into the Fire, Child Rights International Network, (Sep. 28, 2007), https://www.crin.org/en/library/publications/pakistan-out-frying-pan-fire-juvenile-justice-pakistan. 233 Reuters, Pakistan Hangs Man Who Said He Was 15 When Arrested, GUARDIAN (Sep. 29, 2015), https://www.theguardian.com/world/2015/sep/29/pakistani-man-ansar-iqbal-hanged-murder. 234 Justice Project Pakistan & Reprieve, Comments on Pakistan's Replies to the List of Issues in Relation to Its Fifth Periodic Report to the Committee on the Rights of the Child, at 2 (June 7, 2016), http://tbinternet.ohchr.org/Treaties/CRC/Shared%20Documents/PAK/INT_CRC_NGO_PAK_23777_E.pdf (submitted to the Committee on the Rights of the Child in anticipation of its review of Pakistan's state report). 235 CRC, art. 37(a). 236 Aftab Bahadur, My 22 Years on Pakistan's Death Row Could End This Week. What Purpose Will My Execution Serve?, GUARDIAN (June 9, 2015), https://www.theguardian.com/commentisfree/2015/jun/09/22-years-pakistan-death-row-whatpurpose-execution. A “MOST SERIOUS CRIME”: PAKISTAN'S UNLAWFUL USE OF THE DEATH PENALTY 54