THE DOCTRINE OF JUDICIAL REVIEW

By :
SYED MUHAMMAD NAJMUL SAQIB MUMTAZ

Advocate, LL.M. (Previous) (Part-1)

Bahauddin Zakariya University Multan.

MEANINGS , DEFINITIONS OF "JUDICIAL REVIEW":

1.    According To Black's Law Dictionary (Seventh Edition):

According to this dictionary, it is:

(a)   the Court's power to review the actions of other branches or levels of government; especially the Court's power to invalidate legislative and executive actions as being unconstitutional;

(b)   the Court's review of a lower Court's or an administrative body's factual or legal findings.

3.    A Judicial Power in Action:

It is a doctrine according to which the Courts are entitled, in the exercise of the "judicial power" of the State, to examine and decide the question--

(a)   of the Constitutional validity of any law, be it the result of primary or subordinate legislation; and

(b)   of the Constitutional validity or lawfulness of a decision, action or inaction of a person or body in relation to the exercise of a public function (1).

4.    English Civil Procedure (Amendment) Rules 2000:

In its Section 54.1, it is defined as:

A claim for judicial review means a claim to review the lawfulness of:

(a)   an enactment;

(b)   a decision, action or failure to act in relation to the exercise of a public function.

5.    According To Lord Bingham:

"It is the power of the Court to see that public powers are lawfully exercised".

6.    According To Lord Lindley:

In Roberts Gwyfai Vs District Council, according to him:

"There is no duty of the Court which is more important to observe and no power of the Court which is more important to enforce than its power of keeping public bodies within their rights".

7.    According To Chief Justice Coke:

In Bonham's case in 1610, he maintained that:

"When an Act of Parliament is against common right and reason, or repugnant, or impossible to be performed, the common law will control it and adjudge, such Act to be void".

IMPORTANCE:

The power of judicial review, or the authority to declare legislative enactments void, it was said by Justice Iredell in 1878, is:

"Of a delicate and awful nature".

Marshall CJ said:

"No tribunal can approach such a question without a deep sense of its importance and of the awful responsibility involved in its decision" (2).

Whether or not it is right to describe the power of judicial review as awesome, there seems to be no doubt that to see judicial review in action is to witness the judicial power, and hence, the administration of justice at its best.

POSTULATES OF THE DOCTRINE OF JUDICIAL REVIEW:

The doctrine of judicial review pre-supposes the truth of the following propositions:

(a)   Constitution is a law which is enforceable by Courts.

(b)   It is a law of higher obligation than the ordinary law.

(c)   In the event of conflict between Constitution and ordinary law, it is for the Courts to declare the ordinary law, on the ground of its repugnance to higher law, as void (3).

DIVINE ASPECT OF JUDICIAL REVIEW (JUDICIAL REVIEW IN ISLAM):

For Muslims, judicial review is part of the Divine Law (Holy Quran).

The Holy Quran ordains:

"O ye who believe, Obey Allah, and obey the Messenger and those charged with authority among you. If you differ in anything among yourselves, refer it To Allah and His Messenger, if you do believe in Allah and the Last Day: That is best and most suitable for final determination" (4).

HISTORICAL PERSPECTIVE (THE ESTABLISHMENT OF JUDICIAL REVIEW):

So fundamental is the doctrine of Judicial Review of legislation that a few brief remarks about its genesis and the circumstances in which it arose to the position of its present power would not be out of place.

Justice Marshall's Contribution:

"If American law were to be represented by a single figure, skeptic and worshipper alike would agree that figure could be one alone, and that one, John Marshal. Marshal found the Constitution paper and he made it power" (5).

True to the saying "cometh the hour, cometh the man", came the appointment of John Marshall as the Chief Justice of the US Supreme Court in 1801.

"He was so singularly fitted for the office of Chief Justice and rendered such incomparable services in it, that the Americans have been wont to regard him as a special gift of favouring Providence" (6).

His appointment proved the maxim attributed to Napoleon that:

"The tools belong to the man who can use them".

But having said all that, we should be cognizant of the fact that the doctrine of judicial review was in vogue much before Marbury Vs Madison case.

The Doctrine Has Ancient Roots:

1.    That the doctrine of judicial review was not the invention of John Marshall is proved by the fact that the classic tradition of juristic thought in which the lawyers and judges of that time were steeped, owed much of its vitality and vogue to the writings of Blackstone whose "Commentaries on the Laws of England" had been reprinted five years before the Declaration of Independence in America.

2.    The origin of the doctrine of judicial review has been traced back to the dictum of Sir Edward Coke who is regarded as the greatest of the 17th century authorities on the Common Law of England. He contended that Magna Charta had embodied certain fundamental principles of rights and justice, and that the common law contained a further expression of the same principles.

Dr. Bonham's Case (1610):

In this famous case, decided in 1610, Sir Edward Coke, then Chief Justice of England, in an appeal, preferred by Dr. Bonham charged for having violated the statute, adjudged the appellant to be "not guilty" upon the ground that the law in question was void, his reasons being:

"And it appears in our books, that in many cases, the common law will control acts of Parliament, and sometimes adjudge them to be utterly void; for when an act of Parliament is against common right and reason, or repugnant, or impossible to be performed, the common law will control it and adjudge such act to be void".

SCOPE OF JUDICIAL REVIEW:

As has been defined, judicial review can question the validity of:

-     legislation (primary or subordinate), and

-     administrative actions.

1.    JUDICIAL REVIEW OF PRIMARY LEGISLATION:

Primary Legislation:

Primary Legislation is legislation made directly by the legislature or the authority in whom the power to legislate for the time being vests.

Subordinate Legislation:

It is a law made by an authority acting under a power granted by a primary legislation.

BASIS AND RATIONALE OF JUDICIAL REVIEW OF LEGISLATION:

In England:

In England, Lord Coke would have liked it to be a Constitutional rule that "when an Act of Parliament is against common right and reason, or repugnant, or impossible to be performed, the common law will control it, adjudge such Act to be void"; but that was not to be, and there was no such thing as judicial review of Acts of Parliament.

The reason is that England is not governed by a written Constitution and there is no difference in authority between one statute and another.

In America:

Ever since the landmark case of Marbury vs Madison, in which the great Chief Justice John Marshall first asserted the power to pass upon the Constitutionality of legislative acts, and thereby, as Chief Justice Earl Warren has put it, "rooted this fundamental principle in American Constitutional law as our original contribution to the science of law".

In India:

Marbury vs Madison principles have been followed in all the countries governed by written Constitutions. They were re-echoed in a very early Indian case decided by the Calcutta High Court namely Empress Vs Burah (ILR 3 Cal. 63).

In Pakistan:

In Pakistan, they were applied, among others, in the:

1.    Province of East Pakistan vs Muhammad Mehdi Ali Khan (PLD 1959 SC 387);

2.    Fazlul Quader Chaudhry vs Muhammad Abdul Haq (PLD 1963 SC 486);

3.    Abul Ala Maudoodi case (PLD 1964 SC 673); and

4.    Sabir Shah vs Shad Muhammad (PLD 1995 SC 66).

The Grounds of Challenge to Primary Legislation:

In the words of Chief Justice Marshall in Marbury vs Madison, "It is the theory of a written Constitution that an Act of the legislature, repugnant to the Constitution, is void".

In Pakistan:

In Pakistan, as in India, we have a written Constitution and the Constitution is the supreme law of the land. We have adopted the English Parliamentary system but not the English doctrine of the absolute supremacy of Parliament in matters of legislation. In this respect, we have followed the American Constitution and the systems modelled on it.

Judicial Review of Constitutional Amendments:

In United States of America:

In the USA, all the questions relating to Constitutional amendments are considered as political and non-justiciable. Even as regards the ground that the Constitutional amendment has been passed in contravention of a procedural requirement, the settled law in America is that this question is a non-justiciable political question to be determined exclusively by the Congress and that the Courts have no proper role to, play in reviewing amendment process issues.

In India:

Basic Structure Doctrine:

In India, the Supreme Court had developed the Basic Structure Theory which has since the Kesavananda Bharati case (7), been firmly rooted in the Constitutional law of India. This case is also an authority for the view that if in making an amendment, the special procedure prescribed by the Constitution has not been complied with, the amendment is invalid.

In Islamic Republic of Pakistan:

Although the Courts in Pakistan have not recognized the Basic Structure Doctrine, the Courts in Pakistan consistently held (In Abdul Wali Khan case "PLD 1976 SC 57" and in Pakistan Lawyers Forum vs Federation of Pakistan "PLD 2005 SC 719") that a Constitutional Amendment can only be challenged if it has been enacted in a manner not stipulated by the Constitution itself.

2.    JUDICIAL REVIEW OF ADMINISTRATIVE ACTIONS:

General Scope:

In the exercise of its judicial review jurisdiction, the High Court is concerned only with the lawfulness of what the public officers do.

"The public officers are accountable to Parliament for what they do so far as regards efficiency and policy and of that Parliament is the only judge; they are responsible to a Court of justice for lawfulness of what they do and of that the Court is the only judge" (8).

Position in Pakistan:

"Where an administrative executive officer acts under a law, the High Court will control the action by an appropriate order if he:

-     goes out of law, i.e. exercises a jurisdiction not vested in him by law;

-     wrongly denies or omits to exercise a jurisdiction; and

-     where the law under which he acts prescribes the manner in which he is to act materially departs from that law" (9).

Justification for Treating Subordinate Legislation with Administrative Actions:

The justification for treating the subject of subordinate legislation along with administrative actions in general is that subordinate legislation is merely one form of administrative action and both, in American and British systems, judicial review of subordinate legislation is subject to normal law governing review of administrative action.

Doctrine of Ultra Vires:

It's Meanings:

Ultra Vires is a Latin word which means;

"Beyond Power".

It's Concept:

It is axiomatic that a public authority which derives its existence and its powers from statute cannot validly act outside those powers.

The doctrine of Ultra Vires covers all the defects which may lead to administrative actions - subordinate legislation included being invalidated in the Courts.

Grounds for Ultra Vires:

(a)   Contravention of the Constitution;

(b)   Inconsistency with or Contravention of the Enabling Statute;

(c)   Affecting jurisdiction of Courts;

(d)   Contravention of a Law other than the Enabling Enactment;

(e)   Affecting Vested Rights; Retrospectivity;

(f)   Bad Faith or Mala fides; and

(g)   Unreasonableness.

RELATIONSHIP BETWEEN JUDICIAL POWER, JURISDICTION AND JUDICIAL REVIEW:

"Before a Court can claim to exercise judicial power, it must have jurisdiction; for jurisdiction is the authority of a Court to hear a case and hence to exercise judicial power" (10).

Theory of Jurisdiction and Judicial Review:

It is well to bear in mind that Judicial Review has grown out of the theory of jurisdiction and traditionally judges in America, England and other common law countries have for centuries been accustomed to using the expressions "jurisdiction", "without jurisdiction", "within jurisdiction", "excess of jurisdiction" in the exercise of their power of judicial review.

INTERPRETATION AND ITS RELATION WITH JUDICIAL REVIEW:

Judicial power is the power to decide and that includes the power to interpret. The core function of a judge is to decide by applying the law to the facts of the case before him. That necessarily involves interpretation of the law in order that it may be so applied.

"Interpretation is at the heart of judicial review; and judicial review, so to say, is essentially a matter of interpretation" (11).

NEXUS BETWEEN JUDICIAL REVIEW AND FUNDAMENTAL RIGHTS:

In countries with written Constitutions, fundamental rights form part of the written Constitution and any law or executive action which is inconsistent with fundamental rights, will come under judicial review.

Effect of Violation of Fundamental Rights:

Ever since that land mark case of Marbury Vs Madison in which the power to pass upon the Constitutional validity of legislative acts was first asserted, it has been a firmly rooted principle that a written Constitution is the fundamental and paramount law of the nation "and consequently, the theory of every such government must be such that an act of Legislature, repugnant to the Constitution is void".

It makes, like Article 13, clauses (1) and (2) of the Indian Constitution, provisions expressly declaring laws inconsistent with or in contravention of the Fundamental Rights, which are part of the written Constitution, to be void.

Article 8 of Constitution of Islamic Republic of Pakistan, 1973:

It says in its clauses (1) and (2):

(1)   Any law, or any custom or usage having the force of law, in so far as it is inconsistent with the rights conferred by this chapter (of Fundamental rights), shall to the extent of such inconsistency, be void;

(2)   That State shall not make any law which takes away or abridges the rights so conferred and any law made in contravention of this clause shall, to the extent of such inconsistency, be void.

JUDICIAL REVIEW AS DEVELOPED IN DIFFERENT COUNTRIES:

Here we will observe the status of judicial review in different countries.

1.    Judicial Review in Great Britain:

Introduction:

Judicial review is a procedure in English Administrative Law by which English Courts supervise the exercise of public power.

Unlike the United States and some other jurisdictions, English law does not know judicial review of primary legislation (laws passed by Parliament), save in a few cases where primary legislation is contrary to EU law and the European Convention of Human Rights. A person wronged by an Act of Parliament therefore cannot apply for judicial review unless this is the case.

2.    Judicial Review in United States of America:

In America, there is a written Constitution, and judicial review is the doctrine according to which Courts are entitled to rule upon the Constitutionality of an action taken by a co-ordinate branch of government. Thus there, judicial review extends to legislative enactments also.

Courts in the United States have the power of judicial review. This power is based fundamentally on the tripartite nature of governmental power as enunciated in the United States Constitution.

"The judicial Power of the United States, shall be vested in one Supreme Court, and in such inferior Courts as the Congress may from time to time ordain and establish... The judicial Power shall extend to all Cases, in Law and Equity, arising under this Constitution..." (12).

The Supreme Court:

The ultimate Court for deciding the Constitutionality of federal or state law under the Constitution of the United States is the Supreme Court of the United States. The doctrine of judicial review was first announced as part of federal law in 1803, by the Supreme Court decision Marbury v. Madison.

MARBURY vs MADISON (1803) 5 US (1 Cranch) 137:

Marbury v. Madison, 5 U.S. (1 Cranch) 137 (1803) is a landmark case in United States law and the basis for the exercise of judicial review in the United States, under Article Three of the United States Constitution.

Brief Facts of the Case:

The case resulted from a petition to the Supreme Court by William Marbury, who had been appointed as Justice of the Peace in the District of Columbia by President John Adams shortly before leaving office, but whose commission was not delivered as required by John Marshall, Adams' Secretary of State. When Thomas Jefferson assumed office, he ordered the new Secretary of State, James Madison, to withhold Marbury's and several other men's commissions. Being unable to assume the appointed offices without the commission documents, Marbury and three others petitioned the Court to force Madison to deliver the commission to Marbury.

Decision:

The Supreme Court denied Marbury's petition, holding that the statute upon which he based his claim was unconstitutional.

MCCULLOH VS MARYLAND 17 vs (4 Wheat) 316:

In this case, the doctrine of judicial review was reinforced and applied to "the supremacy of the Federation over States".

3.    Judicial Review in Pre-Partition India:

In pre-independence India, only three High Courts at the Presidency towns of Calcutta, Madras and Bombay had the power to issue the prerogative writs. By the charters of the three Supreme Courts created in pursuance of the Regulation Act of 1773, those Supreme Courts were vested with the powers of the Court of King's Bench which included the power to issue the prerogative writs.

4.    Judicial Review in India:

The Courts in India exercise the power of judicial review by virtue of this power being conferred on them by Articles 32 and 226 of the Indian Constitution.

Judicial Review Is A Part Of Basic Structure Of The Indian Constitution:

The Supreme Court of India has held in a host of cases that:

"The doctrine of judicial review is the power inherent and intrinsic in the Supreme Court and High Courts of India, and even a Constitutional amendment cannot divest these Courts of their power of judicial review".

5.    Judicial Review in Islamic Republic Of Pakistan:

The Supreme Court and High Courts of Pakistan exercise the power of judicial review by virtue of powers conferred upon them Articles 184(3) and 199 respectively of the Constitution of Islamic Republic Of Pakistan, 1973.

STANDARD OF REVIEW:

In the United States:

In the United States, unconstitutionality is the only ground for a federal Court to strike down a federal statute.

If a state statute conflicts with a valid federal statute, then Courts may strike down the state statute as a violation of the Supremacy Clause. But a federal Court may not strike down a statute absent a violation of Federal law or of the federal Constitution.

Nevertheless, the federal Courts have not departed from the principle that Courts may only strike down statutes for unconstitutionality.

PROCEDURE IN JUDICIAL REVIEW PROCEEDINGS:

Procedure Including Evidence:

Because judicial review proceedings are in the nature of summary proceedings, matters involving a conflict of fact and a conflict of evidence which would require investigation and would involve discovery and cross-examination are considered unsuitable for disposal on an application for judicial review.

Procedure Including Evidence:

Article 199 doesn't prescribe any period of limitation for applications under this Article. The Limitation Act 1908 also doesn't apply to the proceedings under Article 199.

JURISDICTIONAL REQUIREMENTS IN USA:

In the Constitution of the United States, Article III confines federal Court jurisdiction to "cases" and "controversies". Interpreting this jurisdictional requirement, the Courts have established self-imposed limitations on its power of judicial review. They are as follows:

1.    The Rule against Advisory Opinions:

It means, against extra-judicially deciding a question.

The earliest instances of cases in which this rule was propounded are Hayburn's case of 1792 and Muskrat vs US (219 US 346). The basis of this rule is the doctrine of separation of powers.

2.    Mootness:

The Courts cannot decide moot questions; they can only decide actual cases and controversies.

3.    Ripeness, Prematurity and Abstractness:

Until the controversy has become concrete and focused, it is difficult for the Court to evaluate the practical merits of the position of each party.

The leading case on ripeness is United Public Workers Vs Mitchell (330 US 75).

4.    Standing:

In Allen vs Wright (468 US 737), it was held that the requirement of Standing is perhaps the most important of the jurisdictional doctrines. This doctrine implies that the Courts should be satisfied that they have jurisdiction and that the parties have the standing.

The leading cases in this matter are Fothingham vs Mellon (262 US 447), and Flast vs Cohen (392 US 83).

THRESHOLD QUESTIONS:

1.    Other Adequate Remedy:

In England:

In England, it is well established that, "a remedy by way of judicial review is not to be made available where an alternate remedy exists".

In Pakistan:

"Under Article 199 of the 1973 Constitution, the jurisdiction of the High Court is subject to the condition that the High Court is satisfied that no other remedy is provided by law" (13).

2.    Doctrine of Locus Standi:

In England:

Under the English Legal System, "the Courts as the judicial arm of government do not act on their own initiative". The Courts in England, in exercising the power to grant prerogative writs, have always reserved the right to be satisfied that the applicant has some genuine locus standi to appear before it.

Public Interest Litigation in England:

Recent cases show that the Courts in England have shown "an expansionist view towards locus standi in respect of public interest challenges".

Doctrine of Standing in America:

There is no specific provision in American Constitution corresponding to Article 199 of the Constitution of Pakistan requiring that there must be an application by an aggrieved person or aggrieved party. The "Doctrine of Standing" is one of the doctrines which cluster about Article III of the American Constitution which confines the federal Courts to adjudicating actual cases and controversies and is perhaps the most important of the jurisdictional doctrines.

Doctrine of Standing in Pakistan:

The words "on the application of any aggrieved party", "on the application of any aggrieved person" as they occur in Article 199 of the Constitution of Islamic Republic of Pakistan, 1973 are clearly redolent of the presence of the doctrine of Locus Standi in Pakistan.

Public Interest Litigation and Locus Standi:

In the cases of

(a)   Benazir Bhutto vs Federation of Pakistan, (14) and

(b)   Ardeshir Cowasjee vs Karachi Building Control Corporation, (15)

It has been observed that the concept of locus standi has undergone material change in case of public interest litigation; and, indeed, there is a greater need to allow liberal cases "under a generous conception of locus standi".

3.    Territorial Jurisdiction:

"Territorial jurisdiction is the power of a Court or Tribunal considered with reference to the territory within which it is to be exercised. It means the geographical limits within which the judgments and orders of a Court can be enforced and executed. The object of defining the territorial limits of the Courts and Tribunals generally is to avoid a clashing of jurisdiction".

Under Article 199 of our Constitution, the jurisdiction of the High Courts is territorial.

4.    Fairness:

"Public authority must, in the performance of their public law functions, act fairly and justly, is a universal rule vouched by high and respectable judicial authority" (16).

5.    Natural Justice:

Natural justice, it has been said, is only "fair play in action".

For our purpose, it is sufficient to say that natural justice consists of the rule against bias and the right to be heard.

6.    The Right to Be Heard:

This right may be founded upon a statute or a statutory instrument or it may rest upon the maxim "Audi Alteram Partem".

It is one of the principles of justice that no man should be condemned without being heard.

7.    The Rule against Bias:

"The rule against bias" is the second pillar supporting natural justice. It is commonly captured in the phrase "nemo judex in sua causa", which means that "nobody may be judge in his own cause".

8.    Duty to Give Reasons:

Natural Justice demands that:

(a)   the applicant be informed of the nature of the case against him; and

(b)   he should be given a reasonable opportunity to be heard.

It is well established rule that if opportunity to be heard is to have any value in practice, the decision maker must assign or .identify the reasons for any adverse decision.

9.    Duty to Communicate the Adverse Order:

Notice of a decision is required before it can have the character of a determination with legal effect because the individual concerned must be in a position to challenge the decision in the Courts if he or she wishes to do so. This is not a technical rule. It is simply an application of the right of access to justice.

10.   Unreasonableness:

In Government of Pakistan vs Dada Ameer Haider Khan (PLD 1987 SC 504), the respondent was refused a passport, and the reasons given by the government before the High Court were that the respondent was on old political worker having "communist thoughts". In upholding the decision of the High Court, the Supreme Court observed:

"We don't think that this reason was a reasonable ground on which a citizen's liberty to travel abroad could be curtailed".

11.   Mala-fides:

The Supreme Court and the High Courts in their judicial review jurisdiction can always pronounce an act to be mala fide and therefore void, and their jurisdiction to do so cannot be taken away.

12.   Judicial Review in National Security and Emergency Matters:

In such a situation, the Court must observe the limits dictated by law and common sense, but at they same time, the Courts don't abdicate their judicial function.

13.   Question of Fact:

In the exercise of their judicial review jurisdiction, the Courts are concerned with the lawfulness of the actions of public authorities; they are primarily concerned with the "questions of law" and they give scant regard to "questions of fact".

Judicial Review and National Supremacy:

Even many persons who have criticized the concept of judicial review of congressional acts by the federal Courts have thought that review of state acts under federal Constitutional standards is soundly based in the supremacy clause, which makes the Constitution and Constitutional laws and treaties the supreme law of the land.

IS JUDICIAL REVIEW UNDEMOCRATIC?

Ever since the decision in Marbury vs Madison, there has been a lively debate as to the legitimacy of the power of judicial review.

The Earliest Opposition:

The earliest opposition came from no less a person than Thomas Jefferson, who was President of America at the time of the decision of Marbury vs Madison. He expressed himself thus in a letter:

"You seem to think it developed on the judges to decide on the validity of the sedition law. But nothing in the Constitution has given them a right to decide for the Executive, more than the Executive to decide for them. The instrument (the Constitution) meant that its co-ordinate branches should be checks on each other. But the opinion which gives to the judges the right to decide what laws are Constitutional, and what not, not only for themselves in their spheres of action, but for the legislature and executive, in their own spheres, would make the judiciary a despotic branch".

Position in Pakistan:

This is precisely the position in Pakistan. They are the judicial organ of the State and are so recognized by a written Constitution, namely the Constitution of the Islamic Republic of Pakistan. The system of government under that Constitution is democracy and the Courts are therefore an integral part of that democratic system.

TENSIONS ARISING FROM JUDICIAL REVIEW:

Tension Is Inevitable:

It is natural and inevitable that tensions and frictions will arise from decisions in the applications for judicial review and judges will have their critics. The reasons are not far to seek. They are, among others, that it is in the nature of those exercising political authority to be overweening in its exercise and secondly, judges are the bulwarks of liberty and it is the requirement of their judicial function that they treat the executive on the same footing as any other litigant.

In England:

Thus, as has been noticed by Lord Woolf, in the English Judicial History, one of the periods of such tension was when there was a Labour Government and Lord Denning was the Master of the Rolls.

In America:

In America, the tension was openly voiced when after his landslide victory in the 1936 election, President Roosevelt decided not only to attack the Supreme Court but to do so disingenuously.

In Pakistan:

In Pakistan, the tension, once in the year 1997 rose so high that a three judge Bench of the Supreme Court suspended the operation of a Constitutional Amendment i.e. 14th Amendment; in another matter, a Bench directed the President not to assent to a Bill, which had been duly passed by the National Assembly and the Senate. There were speeches in and out of the National Assembly in respect of the Judges, which gave rise to contempt proceedings (17) culminating in the national humiliation of having the Supreme Court of Pakistan physically attacked during the hearing of the contempt matter against the then Prime Minister and others.

Moderate Judicial Review:

Judicial review won out in early American history after genuine struggles, but the form it won was critical to its success. In a different form, it is likely that it would not have survived. The form it took was "Moderate Judicial Review".

"Great Constitutional provisions must be administered with caution. Some play must be allowed for the joints of the machine and it must be remembered that legislatures are ultimate guardians of the liberties and welfare of the people in quite as great a degree as the Courts" (18).

PROS AND CONS

Although judicial review has become an established part of Constitutional law in the United States, some people disagree with the doctrine, or believe that it is unconstitutional since it is not specifically spelled out in the Constitution.

Proponents of judicial review note that any government based on a written Constitution requires some mechanism to prevent laws from being passed that violate that Constitution. Otherwise, the document would be meaningless, and the legislature, with the power to enact any laws whatsoever, would be the supreme arm of government. •

HOW SUPREMACY OF SOME CONSTITUTIONS IS SECURED THROUGH MEANS OTHER THAN THAT OF "JUDICIAL REVIEW":

It becomes necessary in the context to notice how in countries where the doctrine of judicial review doesn't apply, the supremacy of the written Constitution is maintained.

1.    Swiss Example:

In Switzerland, for instance, the federal judiciary has no power to review the Constitutionality of the federal law. Its powers are confined to adjudicating the Constitutionality of the Cantonal Laws. The Swiss Constitution doesn't establish any clear cut division between the executive and the judicial organs of the State power.

2.    French Example:

In the Constitution of the fourth French Republic, it is for the Constitutional Committee created under Article 91 to say whether the laws passed by the National Assembly imply amendment of the Constitution. It would be noticed that interpretation of the Constitutionality of the impugned law doesn't partake either of the method provided in the Constitution of the United States (namely by means of judicial review, nor again does it conform to the English Constitutional practice (that is of rendering the Parliamentary legislative Acts immune from challenge).

Conclusion:

The cases of Swiss and French Constitutions have been referred in an attempt to show that the procedure of judicial review is not the only device of conserving the supremacy of a written Constitution.

REFERENCES

1.    Judicial Review of Public Actions by Justice (R) Fazal Karim.

2.    McCulloh Vs Maryland:

3.    FUNDAMENTAL LAW of Pakistan by A.K.Brohi

4.    In Sura 4:59

5.    Oliver Wendell Homes, himself a great and celebrated judge.

6.    James Bryce in his book, "The American Common Wealth":

7.    AIR 1973 SC 1461

8.    Diplock LJ in IRC vs National Federation of Self-Employed (1981) 2 All ER 93.

9.    Chief Justice Munir in Tariq Transport Company Case (PLD 1958 SC 437).

10.   Fauji Foundation Vs Shamim-ur-Rehman (PLD 1983 SC 457):

11.   Christopher Wolfe in his book "The Rise of Modern Judicial Review".

12.   Article III of United States Constitution.

13.   Muhammad Arif vs Income Tax Officer (PLD 1989 SC 109):

14.   PLD 1988 SC 416

15.   1999 SCMR 2883.

16.   Airport Support Service vs Airport Manager (1998 SCMR 2268):

17.   Masroor Ahsan vs Ardeshir Cowasjee (PLD 1998 SC 823).

18.   Holmes J in Missouri, Kansas and Texas Ry. Vs May (194 US 267):

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.    Tarek S. Zaheer and M. Kabir Hassan, Financial Markets Institutions and Instruments, a Comparative Literature Survey of Islamic Finance and Banking, vol.10, No.4 Black wall Publishers, p.158-159

.    Usmani M.I., Meezan Bank's Guide to Islamic Banking, 2002, Darul-Ishaat Karachi, Pakistan, p. 13

.    M. Ariff and M.A. Mannan (ed.). Developing a System of Financial Instruments, "The role of Shariah Based Financial Instruments in a Muslim Country", D.M. Qureshi, 1990, Islamic Development Bank, Islamic Research and Training Institute, p.53

.    Mudaraba is also known as Qirad and Muqaradah.

.    5 Shirazi, H., (tr.) Islamic Banking, 1990, Butterworths (London), p.31.

.    EI-Sarraf, M.F., Financial Dealings in Islamic Banks, Journal of Islamic Banking and Finance, Karachi, Pakistan, vol. 1, no. 1, 1984, p. 12.

.    Different scholars have given different opinion on that point.

.    There are two types of Mudaraba namely. First is restricted silent partnership in which the capitalist (Rab ul Mal) may specify a particular business or place for the entrepreneur (Mudarib), in that case he shall invest the money in that particular business or place. Second is unrestricted silent partnership, in this type the capitalist (Rab ul Mal) gives full freedom to the entrepreneur (Mudarib) to undertake whatever business he deems fit. The capitalist (Rab ul Mal) may specify only the rule according to which the profit is to be shared.

.    C.R. Tyser, D.G. Demetriades, Ismail Haqqi, (tr.) the Mejelle, the Other Press, Malaysia, vol. 1, p. 490.

.    C.R. Tyser, D.G. Demetriades, Ismail Haqqi, (tr.) the Mejelle, the Other Press, Malaysia, Vol. 1, p.233-234

.    Tarek S. Zaheer and M. Kabir Hassan, Financial Markets Institutions and Instruments, a Comparative Literature Survey of Islamic Finance and Banking, vol. 10, No.4 Black wall Publishers, p. 165

.    Obiyathulla Ismath Bacha, Adapting Mudarabah Financing To Contemporary Realities: A Proposed Financing Structure November 1996

      www.fivepillarsassc.com/documentation/Adapting-Mudarabah.pdf

      accessed on 1st June 2007-06-02 at 3:30 a.m.

.    Obiyathulla Ismath Bacha, Adapting Mudarabah Financing To Contemporary Realities: A Proposed Financing Structure November 1996

      www.fivepillarsassc.com/documentation/Adapting-Mudarabah.pdf,

      accessed on 1st June 2007-06-02 at 3:30 a.m.

.    Obiyathulla Ismath Bacha, Adapting Mudarabah Financing To Contemporary Realities: A Proposed Financing Structure November 1996

      www.fivepillarsassc.com/documentation/Adapting-Mudarabah.pdf,

      accessed on 1st June 2007-06-02 at 3:30 a.m

.    Humayon A. Dar and John R. Presley, Lack of Profit Loss Sharing In Islamic Banking: Management and Control Imbalances, International Journal of Islamic Financial Services, vol. 2, No. 2, July to September. 2000, p.3-13.

.    Maulana Taqi Usmani, Islamic Finance, Musharakah & Mudarabah www.darululoomkhi.edu.pk/fiqh/islamicfinance/islamicfinance.html - 3k - accessed on 3rd of June at 20:30

.    Saad Abdul Sattar Al-Harran, Islamic Finance: Partnership Financing, 1993, Peladuk Publications, p.75

.    Andrew Cuningham, Islamic Banking and Finance prospects for the 1990s, Middle East Economic Digest (Meed) no. 4, April 1990, p. 14

.    Saad Abdul Sattar Al-Harran, Islamic Finance: Partnership Financing, 1993, Peladuk Publications, p.79

.    Tarek S. Zaheer and M. Kabir Hassan, Financial Markets Institutions and Instruments, a Comparative Literature survey of Islamic Finance and Banking, Black wall Publishers, vol.10, no.4 p. 165-166

.    Saad Abdul Sattar Al-Harran, Islamic Finance: Partnership Financing, Peladuk Publications, 1993, p.79

.    Usmani M.I., Meezan Bank's Guide to Islamic Banking, 2002, Karachi, Pakistan, Darul-Ishaat, p.92

.    Maulana Taqi Usmani, Islamic Finance, Musharakah & Mudarabah www.darululoomkhi.edu.pk/fiqh/islamicfinance/islamicfinance.html - 3k - accessed on 3rd of June at 20:30

.    Mohammad Omar Farooq Partnership, Equity-Financing and Islamic Finance: whither profit-loss-sharing?, August 2006, accessed on 3rd of June 2007 at 20:42 www.globalwebpost.coni/farooqm/writings/islamic/i_econ_fin/if_partnership.doc

.    The practice of Musharaka is different in Pakistan. First, it is a venture in which one party provides the required funds and the other party skills like a conventional Mudaraba. Second is that the risk is limited for the party providing capital.

.    Andrew Cuningham, Islamic Banking and Finance prospects for the 1990s, Middle East Economic Digest (Meed) no. 4, April 1990, p. 14

.    Note: He can suffer loss in case of bankruptcy of borrower

.    Usmani, M.T., An Introduction to Islamic Finance, 1998, Karachi, Pakistan: Idaratul Ma'arif, p.27

.    Said Zafar and Shameela Chinoy, Papers submitted on Islamic Financial Institutions to the Task Force on the Future of the Canadian Financial Services Sector, 8th of October 1997, Khamic Financial Institutions Canada www.fin.gc.ca/taskforce/pdf/ifi2.pdf-accessed on 28th of May 2007 at 23:26

.    Sufyan Gulam Ismail, Islamic Finance Explained,

      www.1stethical.com/IslamicFinanceExplained.pdf accessed on 2nd June 2007 at 20:19

.    Regulatory Impact Assessment for alternative Finance Products,

      www.hmrc.gov.uk/ria/ria-alt-finance.pdf accessed on 2nd June 2007 at 19:59

.    Islamic Finance a Growing Industry in the United States,

      www.unc.edu/ncbank/Articles%20and%20Notes%20PDFs/Volume%2010/KimTacyP DF.pdf accessed on 2nd of June 2007 at20:34

.    Muhammad Amin, the Taxation of Islamic Finance in Major Western Countries, sixth paper 2007, pwc.blogs.com/mohammed_amin/files/.pdf accessed on 2nd of June 2007 at 20:26

.    In Pakistan, the development of term finance certificates has all but eliminated the use of Musharaka. The religious merit of Musharaka is recognised, however, and some banks make a point of taking part in them, especially in capital-starved markets such as Sudan. Nevertheless, for practical purposes, Musharaka remains a highly marginal instrument, despite its attraction for theorists

.    Andrew Cuningham, Islamic Banking and Finance prospects for the 1990s, Middle East Economic Digest (Meed) no. 4, April 1990, p. 14

.    SCB Islamic Home Financing,

      http://www.standardchartered.com/pk/ib/home_finance.html accessed on 1st of June at 2:21