The controversial additional note by Justice Ali Baqar Najafi in the judgment of Noor Mukadam’s murder has sent ripples through Pakistan’s fragile structures of gender justice. The trial court had dismissed the killer Jafar’s statement under Section 384 of the Pakistan Penal Code and rightly convicted him. Yet Justice Najafi, under a self-styled mantle of moral righteousness, appended a moral commentary.
In his note, he implied that the murder was evidence of a “vice spreading in upper society,” namely ‘live‑in relationships’. By shifting focus from the crime and the criminal to what he described as a decadent social practice, Justice Najafi indirectly placed part of the blame on the victim. This reasoning, emanating from the bench, lends social legitimacy to moral judgments and undermines the rule of law.
The response from the Senate’s subcommittee on human rights was swift: it condemned the remarks as “ridiculous” and questioned what message is being sent when a judge himself blames the victim. Their statement strikes at the heart of the matter: such victim‑blaming reduces women’s lives to moral liabilities and diminishes the seriousness of violence against women.
Yet, while public outrage has largely centred on this high‑profile case, the broader issue is far graver: thousands of women murdered or subjected to violence each year continue to be largely ignored.
The real tragedy is that the vast majority of women killed in Pakistan have no connection to ‘live‑in relationships’. Their deaths are rooted in domestic violence, so-called honour crimes, abductions, forced marriages, tribal or feudal practices, or assertions of power and control. These victims rarely make headlines, seldom receive judicial sympathy, and rarely benefit from sustained public outrage. They die anonymously, their deaths recorded, if at all, as just another statistic in a flawed criminal-justice ledger.
The question remains: why does a single high-profile murder ignite national debate over values and morality, while hundreds, even thousands, of others slip into silence?
Official data paints a grim and urgent reality. Between 2021 and 2024, more than 7,500 women were murdered across the country, including 1,553 killed in the name of honour. During the same period, police recorded 17,771 cases of rape, including gang rapes; 9,799 cases of domestic violence; and 632 cases of sexual harassment at workplaces. The total reported cases of violence against women in these four years reached 173,367.
Until the state moves beyond selective indignation and moral posturing to deliver justice consistently, statements like those of Justice Najafi will remain symptomatic of a larger malaise
These are not occasional tragedies but a systemic epidemic. The steady climb in reported cases, from around 30,757 in 2021 to nearly 62,000 in 2024, indicates either growing awareness or, more likely, an intensifying environment of danger, particularly for women living without public visibility or support.
In 2024 alone, a report by a major civil society organisation documented 32,617 cases of gender-based violence nationwide. These included 5,339 rapes, 24,439 abductions or kidnappings, 2,238 cases of domestic violence, and 547 honour killings. Punjab emerged as the worst-affected province, reporting 26,753 incidents, including 4,641 rapes, 225 honour killings, 20,720 kidnappings or abductions, and over a thousand domestic-violence cases. Khyber Pakhtunkhwa, Sindh, Balochistan, and the Islamabad Capital Territory also recorded hundreds of cases under each major category.
Even more striking is the failure of the justice system: national conviction rates remain abysmally low. For rape and honour killings, the rate is around 0.5 per cent; for kidnappings or abductions, approximately 0.1 per cent; and for domestic-violence cases, around 1.3 per cent. In Punjab, despite reporting 225 honour-killing cases, only two convictions were recorded. In Sindh, despite a substantial number of cases, there were no convictions for honour killings, rapes, or abductions. Balochistan fared little better.
These figures reflect not just the failure of individual police investigations but a structural collapse: inadequate evidence collection, societal pressure on victims, weak forensic capacity, prolonged judicial delays, and a pervasive climate of impunity. To call these figures shocking would be an understatement; they represent a national shame.
The magnitude of this violence, coupled with such low conviction rates, shows that perpetrators operate with near-total impunity. Every low-profile domestic murder or forced killing becomes yet another example of institutional neglect.
When a judge chooses to moralise such a crime rather than condemn it unequivocally, the state not only fails to protect women but implicitly sends a message that certain women deserve less protection. This encourages targeting of vulnerable women—those lacking public voice, social capital, or modern lifestyles—whose deaths are unlikely to make headlines.
These tragedies amount to nothing less than a structural elimination of women’s dignity and rights.
Public outrage, media coverage, and activism have historically focused on high-profile cases: the murder of a social-media personality, the brutal killing of a university student, or an especially gruesome honour-killing video going viral. These moments stir anger, demand justice, and occasionally prompt token arrests. Yet lasting change remains elusive. Political and judicial institutions treat victims unevenly: those with resources, social visibility, or media backing may see justice delayed but pursued; others are abandoned.
The shootings of Bano Bibi and her partner in Balochistan, following their choice to marry, sparked a brief uproar when the video surfaced; suspects were arrested, yet the systemic culture of honour killings persists, particularly in rural and tribal areas where the state’s writ is weak.
Moralising by judges or religious conservatives, framing such violence as a response to immorality, only worsens the problem. It transforms perpetrators into avengers of honour, victims into sinners, and society into silent spectators. Meanwhile, thousands of women never involved in ‘live-in relationships’ continue to be killed, kidnapped, abused, or harassed—but remain invisible. Their lives are erased quietly, without commentary, correction, or justice.
What is needed is not moralising condemnations but systemic reform: strengthening police investigations, building forensic capacity, instituting robust victim-support mechanisms, enforcing gender-sensitive laws without bias, and holding judges accountable for victim-blaming. The penal code makes no distinction between a murder committed in a “live-in” context and one committed under tribal or domestic pressure.
Every murder deserves equal legal gravity, irrespective of moral judgments. The real task for the state, courts, and civil society is to treat every woman as a full human being, not as a moral barometer of society.
The outrage over a single case must not distract from the thousands of silent deaths that reveal the true scale of violence against women in Pakistan.
Until the state moves beyond selective indignation and moral posturing to deliver justice consistently, statements like those of Justice Najafi will remain symptomatic of a larger malaise. The price of moral grandstanding is measured in murdered women whose names are never spoken, whose stories are never told, and whose killers go free.