For decades, custody disputes have often been approached as a contest between two parents:
Who should get custody?
Perhaps we need to ask a different question:
What arrangement best serves the child?
A child is not property to be divided between parents after a marriage breaks down.
And a father does not become a stranger to his child merely because he is no longer living with the mother. Equally, a mother should not lose her importance in a child’s life merely because she is not the custodial parent.
Our custody jurisprudence has increasingly recognized that the welfare of a minor involves more than physical care. A child may need the love, affection, guidance and meaningful presence of both parents.
This does not mean that every child should automatically have 50/50 custody.
Shared parenting is not a mathematical formula.
There may be circumstances abuse, violence, neglect, parental incapacity, serious conflict or other genuine risks where restrictions are necessary.
But where such circumstances do not exist, we should be cautious about turning parental separation into parental disappearance.
The real question in family justice should therefore not be:
“Which parent wins?”
It should be:
“How can we ensure that this child loses as little as possible from the breakdown of the parents’ relationship?”
That, in my view, is where the conversation about shared parenting in Pakistan must begin.

Fahad Ahmad Siddiqi
Advocate Supreme Court of Pakistan

In custody disputes, we often describe one parent as the “custodial parent” and the other as the “non-custodial parent.” The terminology can quietly shape the way we think. One parent becomes the parent who has the child. The other becomes the parent who is given access.

But custody determines residence and day-to-day care. It does not determine who remains a parent. A child may live primarily with one parent while continuing to be meaningfully parented by both.

This is not merely a philosophical proposition. Pakistani custody jurisprudence has increasingly recognised that the welfare of a minor encompasses the love, affection, care and guidance of both parents. In Mst. Madiha Younus v. Imran Ahmed (2018 SCMR 1991), the Supreme Court approved a comprehensive arrangement under which custody remained with the mother while the father had substantial periods of interim custody, including weekends, vacations and family occasions.

The jurisprudence therefore points to an important distinction: custody with one parent does not necessarily mean marginalisation of the other. In Shahida Adnan v. Additional District Judge (2021 YLR 1915), the Lahore High Court reiterated that a parent does not lose the right of association merely because custody has been entrusted to the other parent, emphasising the child’s need for the love and affection of both parents.

Meaningful parenting is not necessarily measured in hours spent in a courtroom, a visitation room or under supervision. It can mean ordinary life: taking a child to school, helping with homework, attending a doctor’s appointment, sharing a weekend, celebrating a birthday, or simply being available when the child needs a parent.

This is why visitation should not become a legal substitute for parenthood.

The question, therefore, should not always be: “How much access should the non-custodial parent receive?” A more child-centred question may be: “How can both parents continue to parent this child safely and meaningfully after separation?”

Of course, the answer must always depend upon the welfare of the child. Where genuine risks exist, restrictions may be necessary. But where they do not, parental separation should not automatically result in the transformation of one parent into a visitor.

Our constitutional and family-law jurisprudence also recognises that custody and visitation disputes are ultimately governed by the welfare of the minor. The judicial task is therefore not simply to allocate parental possession, but to protect the child’s continuing relationship with both parents where that relationship is consistent with the child’s welfare. A child may have one primary residence without having only one parent.

That distinction should matter to family justice.

Fahad Ahmad Siddiqi
Advocate Supreme Court of Pakistan

The question of when a child is ‘old enough’ to be heard in custody proceedings is deceptively simple. In Pakistan, Section 17(3) of the Guardians and Wards Act, 1890 permits courts to consider the preference of a minor ‘old enough to form an intelligent preference,’ yet provides no objective criterion for determining when such capacity exists. This ambiguity has contributed to inconsistent and discretionary approaches to child participation, while risking the treatment of a child’s preference as an isolated evidentiary fact rather than a product of developmental maturity, lived relationships, and family circumstances. This paper argues that ‘old enough’ should not be determined by chronological age alone, but through the doctrine of evolving capacity, informed by Pakistani statutory law, constitutional values, Islamic legal tradition, the United Nations Convention on the Rights of the Child (UNCRC), and contemporary developmental psychology and neuroscience. Article 12 of the UNCRC recognizes the right of a child capable of forming views to express them freely in matters affecting the child and requires those views to receive due weight according to age and maturity. The Supreme Court of Pakistan’s emerging rights-based approach to custody and guardianship provides an important doctrinal foundation for interpreting Section 17(3) consistently with these principles. Drawing upon Piaget, Erikson, and Kohlberg, together with neuroscientific insights concerning cognition, executive functioning, risk assessment, and emotional development, the paper proposes that courts assess “intelligent preference” through functional maturity rather than an arbitrary age threshold. Relevant indicators include the child’s ability to communicate a choice, understand relevant information, reason independently, and appreciate its consequences. The paper advances a further proposition: a child’s right to be heard cannot be meaningfully separated from the opportunity to maintain meaningful relationships with both parents. A preference formed after prolonged custodial isolation, restricted visitation, parental alienation, or unequal relational exposure may reflect circumstance rather than an autonomous and adequately informed choice. Hearing the child without addressing these conditions risks recording the effects of an imbalanced custodial environment rather than authentically assessing the child’s wishes. Accordingly, the paper proposes a rights-based procedural framework in which shared parenting or substantially balanced parental contact operates as a safeguard for genuine child participation. It recommends a rebuttable presumption of meaningful parental contact during custody litigation, structured opportunities to maintain relationships with both parents, multidisciplinary maturity assessments, child-sensitive judicial procedures, neutral psychological or parenting evaluations, and specialized training for judges and guardians ad litem. The paper ultimately reframes ‘intelligent preference’ not as a threshold-based privilege that arises only with age, but as an exercise of child agency that requires appropriate developmental and relational conditions. The legal process should protect the child’s opportunity to experience and maintain meaningful relationships with both parents before placing decisive weight on the child’s preference. Shared parenting, therefore, is not merely a question of parental equality; it may constitute a procedural safeguard for authentic child agency and a more reliable determination of the child’s best interests.

Dear Esteemed Seniors and Learned Colleagues,

The ongoing evolution of family law jurisprudence increasingly challenges our traditional approach to domestic litigation. While Section 5 of the West Pakistan Family Courts Act, 1964 read with its Schedule vests exclusive jurisdiction over child custody, our foundational substantive law remains the colonial-era Guardians and Wards Act, 1890.

Despite Section 17 of the 1890 Act enshrining the “welfare of the minor” as the paramount consideration, our structural approach often defaults to an all-or-nothing binary: awarding physical custody to one parent while reducing the non-custodial parent to basic, restrictive visitation schedules under Section 12 interlocutory orders.

I would highly value the intellectual insights of this distinguished forum on the following statutory and procedural questions regarding Shared Parenting:

Statutory Harmonization
: Given that Section 25 of the Family Courts Act, 1964 deems the Family Court to be a District Court for the purposes of the Guardians and Wards Act, 1890, does our existing statutory framework allow enough judicial discretion to mandate joint physical residency, or is a legislative amendment specifically defining “Shared Parenting” required?

Rethinking Visitation Realities:
Can the standard two hours once or twice a month and that too within the court premises, restrictive visitation setups routinely ordered by Guardian Courts truly satisfy the comprehensive definition of “welfare” as interpreted by modern apex court rulings? Or does it run counter to the child’s psychological development?

Pre-Trial Reconciliatory Frameworks:
How can we better utilize the pre-trial and reconciliation provisions under Section 10 of the Family Courts Act, 1964 to transition high-conflict custody disputes away from adversarial litigation and toward structured, court-monitored Shared-Parenting agreements?

With the profound legal acumen concentrated in this group, your learned perspectives on modernizing our application of these centuries-old statutes would be highly illuminating.

Regards,
Fahad Ahmad Siddiqi
ASC

Introduction

Parental alienation constitutes a multifaceted psychological phenomenon that most commonly arises in the context of high-conflict custody disputes. Initially conceptualized by R. A. Gardner as Parental Alienation Syndrome, the construct describes situations in which a child persistently rejects one parent as a result of intense interparental conflict, combined with systematic indoctrination by the favored parent and the child’s own active participation in denigrating the targeted parent (Iacobescu, 2021). Central to this process is the child’s adoption of a “campaign of denigration,” characterized by persistent negative beliefs and hostile assertions toward the alienated parent that lack independent justification and closely mirror the language and attitudes of the alienating parent, who is frequently the primary custodial caregiver (Chung, 2018). Importantly, the identification of parental alienation is grounded in observable behavioral patterns rather than subjective parental claims, emphasizing the child’s internalization of externally imposed narratives.

Furthermore, parental alienation generates profound psychological strain for the child, who is placed in an environment of chronic relational conflict. To manage this distress, children may engage in a maladaptive cognitive process that resolves emotional ambivalence by rigidly aligning with one parent while rejecting the other (Moon et al., 2020). This polarized pattern of attachment reflects a form of cognitive dissonance reduction, wherein the child simplifies complex emotional experiences into an absolute dichotomy of loyalty and rejection. Such psychological splitting is particularly evident during or following divorce proceedings marked by intense hostility, where the child’s need for emotional security may override the capacity for nuanced or integrated perceptions of both parents (Moon et al., 2020). Consequently, the child’s rejection of one parent may function less as an autonomous judgment and more as a coping mechanism in response to overwhelming interparental conflict.

Empirical research increasingly identifies parental programming and indoctrination as the central mechanisms driving the alienation process, framing these behaviors as psychologically abusive rather than merely adversarial parenting practices (Petruschevici et al., 2024). This form of emotional manipulation has gained recognition as a variant of child maltreatment, given its potential to disrupt identity formation, undermine self-esteem, and impair long-term psychological development (Chung, 2018). Despite growing acknowledgment of its harmful effects, gaps remain in the standardization of diagnostic criteria and intervention strategies, highlighting the need for further empirical investigation into effective prevention and treatment approaches. Addressing these gaps is essential for improving clinical, legal, and child-protective responses to parental alienation in high-conflict family systems.

While the psychological literature on parental alienation has developed largely within Western jurisdictions, similar welfare-based concerns increasingly surface within the legal framework governing child custody and visitation in Pakistan. Under the Guardians and Wards Act, 1890, the overriding consideration in all guardianship and custody determinations is the welfare of the minor, a concept that Pakistani superior courts have repeatedly interpreted to include the child’s emotional security, psychological stability, and sustained relationship with both parents. Although the statute does not expressly employ the terminology of parental alienation, judicial interpretation has recognized that obstruction of visitation and deliberate erosion of a child’s bond with a parent may amount to conduct detrimental to welfare, thereby engaging the court’s corrective jurisdiction. This convergence between psychological harm and legal welfare standards provides an important contextual bridge between empirical research and family law adjudication in Pakistan[1].

Psychological Consequences of Parental Alienation in Children

Parental alienation exerts profound psychological effects on children, influencing multiple domains of emotional, cognitive, and behavioral functioning. Empirical evidence consistently demonstrates that children exposed to alienating behaviors are at heightened risk of developing internalizing symptoms, including depression, anxiety, diminished self-esteem, and pervasive feelings of guilt and abandonment (Gani et al., 2020). These symptoms often emerge early and may persist over time, indicating both immediate distress and enduring developmental vulnerability. Furthermore, alienated children frequently exhibit separation anxiety, impaired social competence, and notable behavioral difficulties, which can further compromise their psychosocial adjustment (Sirbu et al., 2020).

Beyond emotional distress, parental alienation significantly disrupts children’s identity formation and self-perception. Continuous exposure to conflicting narratives and emotional manipulation may lead children to distrust their own thoughts, emotions, and lived experiences. Consequently, they often develop an unstable sense of self, characterized by low self-worth, chronic insecurity, and impaired autonomy (Verhaar et al., 2022). Notably, when children internalize the hostility expressed by the alienating parent toward the targeted parent, this process may extend inward, resulting in self-directed negativity, reduced subjective well-being, and feelings of helplessness and rejection (Roma et al., 2021). Such patterns suggest that parental alienation may interfere with the normative development of individuality and emotional resilience (Kruk, 2018).

In addition to internalizing difficulties, externalizing behaviors represent a critical area of concern (Fares et al., 2023). Research indicates that alienated children are more likely to display attention deficits, aggression, impulsivity, substance misuse, and oppositional behaviors toward authority figures (Miralles et al., 2021). These children may also adopt manipulative interpersonal strategies and develop distorted understandings of familial roles and relationships, reflecting maladaptive coping mechanisms within a conflicted family environment (Isaila et al., 2022). Academic functioning is frequently compromised, with declines in school performance often accompanied by sleep disturbances and disordered eating patterns, further illustrating the pervasive impact of alienation on daily functioning (Koukoulis et al., 2022).

The psychological burden of parental alienation is particularly acute during forced visitation and custody exchanges. Such transitions have been shown to provoke intense anxiety and distress, with children often displaying extreme emotional dependency on the alienating parent and marked stress when separated from them (Nambiar et al., 2024). Over time, this chronic stress may manifest in psychosomatic complaints and behavioral dysregulation, positioning children as vulnerable bystanders in parental conflict with tangible consequences for both psychological and physical health (Nambiar et al., 2024).

This psychological vulnerability assumes particular legal significance in jurisdictions such as Pakistan, where superior courts have emphasized that visitation is a right of the child rather than a concession to the non-custodial parent. Pakistani jurisprudence[2] has cautioned that prolonged or unjustified denial of access may itself constitute evidence of conduct adverse to the child’s welfare, especially where such denial entrenches fear, emotional dependency, or hostility toward the absent parent. In this context, the psychological distress documented in alienated[3] children mirrors judicial concerns that custodial arrangements if left unchecked may transform into instruments of emotional harm, reinforcing the need for early and meaningful court intervention.

Given the severity and persistence of these outcomes, a growing body of literature conceptualizes parental alienation as a serious form of emotional child abuse (Harman et al., 2018). Importantly, longitudinal findings suggest that when alienation is not identified and addressed in a timely manner, affected children may develop chronic mental health conditions that extend into adulthood, adversely influencing emotional development, social relationships, and overall quality of life (Baka et al., 2025). Despite increasing recognition of these harms, gaps remain in early detection strategies and evidence-based interventions, underscoring the need for continued research and clinical attention in this area.

Psychological Impact on Targeted Parents

Targeted parents subjected to alienating behaviors frequently experience profound and enduring psychological harm as a result of systematic exclusion from their children’s lives. Empirical evidence consistently indicates that these parents exhibit markedly negative adaptation outcomes, including elevated levels of depression, chronic stress, frustration, fear, helplessness, and pervasive feelings of loss and despair (Poustie, 2018). Such outcomes reflect not only acute emotional distress but also longer-term maladaptive coping patterns. In particular, fathers identified as targets of parental alienation appear especially vulnerable, with studies documenting increased risks of chronic depressive states, social withdrawal, and heightened interpersonal conflict (Roma, 2021). In extreme circumstances, the cumulative psychological burden may escalate to suicidal ideation or suicide attempts, underscoring the severity of the trauma associated with prolonged alienation (Isaila, 2022).

Furthermore, a persistent sense of powerlessness emerges as a central mechanism underlying the psychological distress of targeted parents. As alienating behaviors restrict contact and undermine parental authority, targeted parents often experience a profound erosion of their parental role and identity (Tavares, 2021). This loss is exacerbated by the alienating parent’s control over communication, information, and access to the child, which creates significant relational and informational asymmetries (Marques, 2022). Consequently, the targeted parent’s capacity to influence the parent–child relationship is progressively diminished, reinforcing feelings of helplessness and marginalization. Over time, this sustained disempowerment may alter how targeted parents express affection and maintain emotional bonds with their children, potentially leading to emotional withdrawal as a defensive adaptation (Tavares, 2021).

In addition to psychological distress, targeted parents frequently report adverse physical health outcomes linked to chronic stress exposure. Research indicates that experiences of parental alienation are associated with somatic symptoms such as weight loss, persistent fatigue, and general physical deterioration, often occurring alongside intense feelings of guilt and perceived injustice (Tavares, 2021). These physical manifestations suggest that the stress associated with alienation extends beyond emotional suffering to affect overall physiological functioning. Moreover, the intersection of psychological trauma and social exclusion contributes to a multifaceted pattern of suffering that disrupts both personal well-being and broader social functioning (Kucukkaragoz, 2025).

Despite growing recognition of these consequences, notable gaps remain in the literature. Specifically, longitudinal research examining the long-term psychological and physical trajectories of targeted parents is limited, as is comparative research exploring gender differences and protective factors that may mitigate harm. Addressing these gaps is essential for developing evidence-based interventions and informing legal and clinical responses aimed at reducing the enduring impact of parental alienation on targeted parents.

Beyond statutory considerations, parental alienation and visitation denial also engage broader constitutional concerns within Pakistan’s legal framework. Judicial interpretations of the constitutional right to life and dignity increasingly encompass the right to family life and emotional integrity, particularly in matters involving children. Procedural delays[4], interim injunctions, and ineffective enforcement mechanisms common features of protracted family litigation may inadvertently facilitate de facto alienation, allowing psychological harm to intensify over time. This procedural dimension resonates with empirical evidence demonstrating that the duration of alienation is directly correlated with the severity of long-term psychological consequences, underscoring the need for timely and welfare-oriented legal responses.

Long-Term Consequences of Childhood Parental Alienation

A growing body of empirical research indicates that exposure to parental alienation during childhood is associated with profound and enduring psychological and social consequences that frequently persist into adulthood. Adults who report having experienced parental alienation as children consistently demonstrate elevated levels of depression and anxiety, alongside a heightened risk of broader psychopathology, diminished self-esteem, and reduced personal autonomy (Verhaar et al., 2022). These outcomes suggest that parental alienation may disrupt foundational processes of emotional development, thereby increasing vulnerability to long-term mental health difficulties.

Furthermore, evidence indicates a strong association between childhood parental alienation and maladaptive coping behaviors in adulthood. Multiple studies report significantly higher rates of substance misuse and addiction among individuals with histories of alienation, with findings suggesting a direct link between early relational trauma and later substance use disorders (Jaffe et al., 2017). This pattern may reflect attempts to manage unresolved emotional distress or deficits in emotional regulation stemming from chronic childhood stress.

The impact of parental alienation on adult interpersonal functioning and family formation is particularly pronounced. Adults exposed to alienation frequently exhibit insecure attachment styles, marked difficulties in establishing and maintaining close relationships, and substantially higher rates of marital instability and divorce when compared to non-alienated counterparts (Bentley et al., 2020). In addition, many individuals report enduring feelings of loss, abandonment, and guilt, which may undermine trust, emotional intimacy, and relational stability well into adulthood (Isaila et al., 2022). These findings highlight the pervasive influence of early relational disruption on later social functioning.

Of particular concern is the evidence supporting intergenerational transmission of alienation-related behaviors. Research suggests that adults who experienced parental alienation in childhood are at increased risk of encountering similar alienating dynamics involving their own children, whether enacted by intimate partners or extended family members, such as grandparents (Miralles et al., 2021). This cyclical pattern indicates that the psychological consequences of alienation may extend beyond the original affected individual, perpetuating relational harm across generations and reinforcing maladaptive family systems.

Importantly, the severity of childhood alienation appears to be directly associated with the magnitude of adverse adult outcomes. Studies demonstrate that more intense or prolonged exposure to alienating behaviors correlates with greater risks of depression, anxiety, substance use disorders, impaired impulse control, relational dysfunction, and reduced self-worth in adulthood (Jaffe et al., 2017). Supporting this association, recent research has identified a statistically significant negative relationship between childhood parental alienation and adult self-esteem (Petruschevici et al., 2024). This finding is particularly consequential given that self-esteem is closely linked to psychological resilience, academic and occupational success, effective stress management, and reduced behavioral difficulties.

Notably, the psychological harm associated with parental alienation may persist even when reunification with the targeted parent occurs later in life. Evidence suggests that reconciliation does not necessarily reverse the emotional and psychological damage incurred during childhood, underscoring the potential irreversibility of certain outcomes (Verhaar et al., 2022). Collectively, these findings reinforce the conceptualization of parental alienation as a severe form of emotional abuse with long-lasting and potentially lifelong implications for mental health and psychosocial well-being (Bentley et al., 2020). Moreover, they highlight critical gaps in intervention and prevention efforts, emphasizing the need for early identification and targeted support to mitigate long-term harm.

Impact on Family Dynamics and Legal Processes

Parental alienation represents a profound disruption to family systems and poses substantial challenges to legal frameworks intended to safeguard the best interests of children. Empirical research indicates that alienating behaviors frequently emerge in the context of divorce, custody disputes, and broader interpersonal relationship breakdowns, where they negatively affect parent–child relationships and exacerbate adversarial legal processes (Nalbant, 2023). Such behaviors place mothers, fathers, and children in prolonged states of conflict and uncertainty, often intensifying emotional strain throughout legal proceedings.

These alienating behaviors manifest through a range of mechanisms, including emotional manipulation of children, systematic denigration of the targeted parent, and deliberate interference with parenting time. Collectively, these actions foster maladaptive family dynamics that undermine children’s emotional security and psychological well-being (Mateo-Fernandez et al., 2024). Moreover, sustained exposure to these dynamics may disrupt children’s attachment patterns and contribute to long-term emotional distress, highlighting the need for early identification and intervention.

The challenge of parental alienation[5] is further complicated in legal systems that recognize custodial preference based on age and caregiving roles. In Pakistan, while maternal custody during tender years is traditionally favored, courts have consistently held that such preference is neither absolute nor immune from scrutiny. Judicial precedent reflects an emerging recognition that custody, when exercised in a manner that systematically alienates the child from the other parent, loses its moral and legal justification. This judicial stance aligns with psychological findings that sustained exposure to alienating behaviors undermines emotional development and relational security, reinforcing the principle that custodial authority is conditional upon its exercise in a manner that preserves, rather than fractures, the child’s relational world.

Furthermore, the alienation process fundamentally impedes the development of cooperative and functional co-parenting arrangements. As parental conflict escalates, children are increasingly exposed to chronic interparental hostility, which may intensify emotional and psychological harm over time (Jaffe et al., 2017). This cyclical pattern of conflict and harm presents significant difficulties for legal systems, which often rely on traditional custody models that may not fully capture the complexity or subtlety of alienation dynamics. Consequently, courts may struggle to respond effectively to behaviors that are psychologically manipulative rather than overtly abusive.

The severity and sophistication of alienation tactics further complicate legal and clinical responses. Alienating parents may employ strategies such as persistent denigration, distorted portrayals of the other parent, obstruction or boycott of visitation, deliberate misinformation, suggestive influence, and the use of contradictory or double-bind communication (Boch-Galhau, 2021). In more extreme cases, these tactics may escalate to direct psychological threats—such as withdrawal of affection or threats of self-harm—or even physical coercion, including confinement or physical aggression toward the child (Boch-Galhau, 2021). Such practices exacerbate children’s loyalty conflicts and may foster fear, emotional dependence, and submission, rendering children increasingly vulnerable to the alienating parent’s influence.

Given the documented psycho-traumatic and long-term consequences associated with pathological alienation and sustained contact loss, parental alienation cannot be conceptualized as a purely private family matter (Boch-Galhau, 2021). Instead, growing evidence suggests that severe parental alienation constitutes a form of psychological child abuse with enduring developmental and mental health implications. This recognition underscores a critical gap in conventional custody adjudication and highlights the necessity for specialized legal interventions and therapeutic approaches that extend beyond traditional dispute resolution models (Boch-Galhau, 2021). Addressing parental alienation effectively, therefore, requires interdisciplinary collaboration between legal, psychological, and child protection systems to mitigate harm and promote children’s long-term well-being.

Taken together, the psychological evidence surveyed in this article finds strong normative alignment with Pakistani family law when the welfare principle is interpreted holistically. Although parental alienation is not explicitly codified, existing legal doctrines under the Guardians and Wards Act, Islamic family law principles[6], and constitutional jurisprudence provide sufficient analytical tools to identify and restrain alienating conduct. Bridging psychological insight with legal practice does not require doctrinal innovation so much as purposive interpretation, judicial sensitivity, and early intervention. Recognizing parental alienation as a form of emotional harm within custody adjudication is therefore not an expansion of legal authority, but a reaffirmation of the child-centric mandate that underpins both psychological science and family law in Pakistan.

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References

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Chung, P. J. (2018). Parental Alienation Syndrome: A family therapy and collaborative systems approach to amelioration. Journal of Developmental & Behavioral Pediatrics, 39(7), 572. https://doi.org/10.1097/dbp.0000000000000605

Moon, D. S., Lee, M. H., Chung, D. S., & Kwack, Y. S. (2020). Custody evaluation in high-conflict situations focused on domestic violence and parental alienation syndrome. Journal of Korean Academy of Child and Adolescent Psychiatry, 31(2), 66–73. https://doi.org/10.5765/jkacap.200004

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Von Boch-Galhau, W. (2021). Parental Alienation: A Serious Form of Child Psychological Abuse and a Worldwide Health Problem, that Affects Children and Victim Parents all Over the World. International Journal of Psychiatry Research, 4(6). https://doi.org/10.33425/2641-4317.1116

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[1] 2025 PLD 47 SUPREME-COURT

[2] 1989 CLC 1377 LAHORE-HIGH-COURT-LAHORE

[3] 2025 PLD 201 PESHAWAR-HIGH-COURT

[4] 2018 SCMR 427 SUPREME-COURT

Parental bond

[5] 2025 CLC 960 LAHORE-HIGH-COURT-LAHORE

[6] 2025 PLD 247 SUPREME-COURT