Shafique Chaudhry
DESPITE a landmark Supreme Court judgment in 2014 mandating concrete protections for religious minorities, Pakistan continues to struggle with implementation, remaining caught between progressive legislation and prolonged inaction. More than a decade has passed since the Supreme Court of Pakistan delivered its historic verdict on June 19, 2014, in suo motu Case No. 1 of 2014. Authored by the then Chief Justice, Tassaduq Hussain Jillani, the judgment emerged in the aftermath of the devastating suicide bombing at Peshawar’s All Saints Church in 2013, which claimed 81 lives and left many injured. The apex court consolidated nine petitions highlighting systemic grievances of religious minorities and issued eight comprehensive directives aimed at safeguarding their constitutional rights.
These directives include formation of a task force to promote religious tolerance, revision of school curricula to foster harmony, strict action against hate speech—particularly online—with punitive measures, establishment of an independent minority protection body titled the National Council for Minorities’ Rights, deployment of dedicated police units for the security of places of worship, enforcement of a five percent employment quota for minorities, swift law enforcement responses to violations and continuous monitoring of progress through a dedicated judicial file. Rooted in Article 20, guaranteeing freedom of religion and Article 25, ensuring equality of citizens, the verdict sought to translate constitutional ideals into enforce-able protections for Christians, Hindus, Sikhs, Ahmadis and other minority communities.
However, Pakistan’s estimated 9.5 million religious minorities—constituting approximately 4pc of the country’s 241 million population according to the 2023 census—continue to face persistent vulnerabilities. As of mid-2025, compliance with the judgment stands at roughly 25 percent. At this pace, full implementation could take decades, leaving minority communities exposed to discrimination, violence and marginalization. This also undermines national integration, fostering divisions that fuel extremism, erode institutional trust and weaken overall social cohesion. Regarding task force for religious tolerance, the federal and provincial bodies have been formed, accompanied by sporadic awareness campaigns and a National Assembly resolution in 2022. However, these initiatives remain symbolic and as a result, extremism remains unchecked, continuing to provoke attacks on minority communities undermining communal harmony. Some progress in curriculum reform—with removal of certain objectionable content from textbooks. In 2023, the National Curriculum Council approved no-objection certificates for religious education books tailored to major minority faiths, scheduled for implementation in federal institutions from 2025. Nonetheless, persistent bias in core subjects such as Urdu and social studies compel non-Muslim students to study content inconsistent with their beliefs, in violation of Article 22(1). This alienation reinforces exclusionary narratives and obstructs national unity.
Efforts to combat hate speech have seen limited advancement under existing laws, yet prosecutions remain rare and comprehensive data collection is lacking. The misuse of blasphemy laws continues unabated, with 344 accusations recorded in 2024, up from 329 in 2023. Since 1987, such allegations have resulted in 104 extrajudicial killings. Incidents such as 2023 Jaranwala attacks on 21 churches and the 2024 lynching of Christian citizen Lazar Masih in Sargodha illustrate how unchecked incitement enables mob violence, destabilizing society at large. Deployment of police units to protect places of worship has been uneven. Sindh has shown relatively better resourcing, while Balochistan lacks in such measures entirely. Punjab still relies on adhoc arrangements. This incomplete implementation leaves religious sites vulnerable, seen during the 2022 vandalism of the Teerah temple, intrusions at 13 temples in Sindh and 308 cases of grave desecration reported in 2024.
Enforcement of 5% employment quota for minorities remains another critical yet poorly implemented directive. The One-Man Commission on Minorities’ Rights, constituted in January 2019 and headed by former Inspector General Dr. Shoaib Suddle, emerged as the most effective judicial mechanism for minority protection despite lacking executive authority. It has exposed non-compliance with job quota, facilitated the recovery of over 3,500 hectares of encroached minority properties, highlighted neglect of Hindu holy sites, challenged discriminatory job advertisements, addressed forced conversions and criticized ineffective government institutions. These efforts have intensified demands for transforming the Commission into a permanent statutory body with executive powers. Recently, approval of the National Commission for Minorities’ Rights (NCMR) Bill, 2025 marks a significant institutional development. It will enhance monitoring, accountability and independent oversight in line with constitutional guarantees and international human rights obligations. Nonetheless challenges still persist. Forced conversion cases—83 reported in 2024, down from 136 in 2023—continue to disproportionately affect underage Hindu and Christian girls. Quaid-e-Azam Muhammad Ali Jinnah’s address of August 11, 1947, echoes in spirit of the Jillani judgment reaffirming that faith is a private matter and all citizens are equal before the state. Fulfilling this verdict remains essential to realizing that vision and building a cohesive and inclusive Pakistan.
—The writer is Executive Director, Parliamentarians Commission for Human Rights (PCHR), Islamabad.
