# Approvers and accomplices in 9 cards.

> Yes. Under Article 16 of the Qanun-e-Shahadat an accomplice is a competent witness, except in hadd cases, and a conviction on his word alone is not illegal. But Article 129(b) and the courts ask for corroboration as a rule of prudence.

- Topic: Law study
- For: Law students
- A 12-slide carousel: https://failegal.site/media/approvers-and-accomplices-in-9-cards
- Published by FAI Legal on 2026-10-23

## The law.

Article 16, Qanun-e-Shahadat.

> "An accomplice shall be a competent witness against an accused person, except in the case of an offence punishable with had; and a conviction is not illegal merely because it proceeds upon the uncorroborated testimony of an accomplice." (Qanun-e-Shahadat Order, 1984 · Article 16)

## The rule. Cards 1 to 3.

Article 16.

- **Competent** An accomplice can testify against the accused. (Art. 16)
- **Except** Not in an offence punishable with hadd. (Art. 16)
- **Not illegal** A conviction on his word alone is not illegal. (Art. 16)

## The caution. Cards 4 to 6.

Article 129(b) and the cases.

- **Presumption** Unworthy of credit unless corroborated in material particulars. (Art. 129(b))
- **Prudence** Courts seek corroboration as a rule of prudence. (1993 SCMR 785)
- **Double test** Reliable in itself, and corroborated independently. (PLD 2002 Kar. 152)

## The pardon. Cards 7 to 9.

Section 337, CrPC.

- **The deal** Pardon on a full and true disclosure of the offence. (s.337(1))
- **Hurt or qatl** No pardon without the victim's or heirs' permission. (s.337(1))
- **Witness** He must be examined as a witness at the trial. (s.337(2))

## Quick quiz. The co-accused.

Guess first, then swipe for the answer.

- **A. Yes, it prejudices him**
- **B. No, he can cross-examine**
- **C. Only in the High Court**

## Answer: B. 2016 PCrLJ 714.

Lahore High Court.

- **The holding** With the heirs' permission, the co-accused could not challenge the pardon.
- **His remedy** Ample opportunity to cross-examine the approver.

## How much corroboration?

PLD 2020 Lah. 690, Lahore High Court.

- **No formula** It depends on the crime, the evidence and his part in it.
- **Must cover** The general story, and the accused's identity and part in the crime.

## Custody until trial.

Section 337(3), CrPC.

- **The rule** Unless already on bail, he stays in custody until the trial ends.

## Mix-ups to avoid.

Three lines examiners test.

- **Competent, not credible** Art. 16 lets him testify. Art. 129(b) weighs his word.
- **Law vs prudence** Corroboration is prudence, not a legal bar.
- **Hadd** The one place Art. 16 shuts him out.

## Stuck on approvers?

Ask FAI. It answers with the exact article and the judgments that explain it.

- **Explain Article 16 and Article 129(b) Qanun-e-Shahadat with Supreme Court cases.**
- **When can a court tender a pardon under section 337 CrPC?**

## Sources

- Qanun-e-Shahadat Order, 1984 · Article 16: Accomplice

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