Rahumath Umma V Anser and Others – SLR – 376, Vol 2 of 2003 – sllr 2003 volume 2 page 376

In the case between the plaintiff-respondent (initiator of a partition action) and the 3rd defendant-appellant (claiming an irrevocable right under a deed of gift), the court addressed the revocability of a 1977 deed of gift, later revoked by a 1980 deed, in the context of Muslim Law and the interpretation of section 3 of the Muslim Intestate Succession Ordinance, No. 10 of 1931. The central issue concerned whether the 1977 deed could be deemed irrevocable in the absence of express language to that effect. It was held that, under section 3 and its proviso, a deed of donation is revocable unless the deed explicitly states it is irrevocable. The appeal was dismissed, reaffirming the principle that statutory requirements, rather than personal law or implied irrevocability, determine the effec