Islamabad High Court Strikes Down Rule Letting Agencies Put Travellers on the PCL

A government agency can no longer put your name on Pakistan's Passport Control List just by recommending it. The Islamabad High Court has struck down the words in the Passport Rules 2021 that allowed this, in a judgment by Justice Inaam Ameen Minhas announced on 14 September 2026 and reported in the press on 26 September.

The case started with a man who was offloaded at Islamabad International Airport on his way to Umrah. He had a valid passport, a Saudi visa and a confirmed ticket. Nobody told him why. We read the full judgment, Writ Petition No. 1523 of 2026, on the court's own website.

The court struck out one sentence of Rule 22(2)(b)

The court declared one sentence of Rule 22(2)(b) of the Passport Rules 2021 "ultra vires", meaning beyond the power of the law it was made under, and of no legal effect. The sentence let names go on the Passport Control List on the recommendation of government agencies or departments.

These are the exact words the court removed: "The names of persons included in the category under this clause may also be placed on the recommendations of government agencies or departments."

The judge gave four reasons. The Passports Act 1974 has no travel control list. The sentence skipped the rule's own condition of a prior passport refusal. It named no officer to decide. And it gave no notice, hearing or reasons, so a citizen found out only at the counter.

The court held this broke Articles 4, 9, 10A and 15 of the Constitution, which protect liberty, fair process and the freedom to travel.

The case began with an offloading on the way to Umrah

The petitioner was offloaded on 18 December 2025. The record showed his name had been put on the list on 24 December 2024, on a recommendation from the INTERPOL office in Pakistan passed on by the Federal Investigation Agency (FIA). He had earlier been deported from the United Kingdom after serving a sentence there.

His passport was never cancelled. The order refusing to remove his name cited Pakistan's image abroad and deterrence. The judge said neither ground appears in the Act or the Rules.

The court said it did not play down the seriousness of the old offence. "But gravity does not supply jurisdiction," the judgment says. A travel ban needs a lawful authority, a clear legal provision, notice and a reasoned order.

The judge also noted that petitions from people with valid passports and visas, offloaded without notice or reasons, reach the court "with alarming frequency". That is why he ruled on the rule itself, not just on this one man.

The PCL, the ECL and immigration lists are different things

Pakistan uses more than one list to stop people leaving. They come from different laws and have different ways out. This ruling touches only one sentence of the Passport Control List rules. It does not touch the Exit Control List.

IBMS is the Integrated Border Management System that immigration officers check at the counter. Section 2 of the 1981 Ordinance lets the Federal Government stop a person leaving even with valid travel documents.

What changes for travellers, and what does not

For travellers, the change is that an agency's recommendation alone is no longer a lawful reason to put you on the PCL. A named authority must decide, under a clear rule, after notice and with reasons. Category A and the Exit Control List stay as they were.

The court also said the right tool already exists. If the state thinks someone should not hold a passport, section 8 of the Passports Act lets it cancel, impound or confiscate it. That normally needs a written show cause notice first. What the law does not allow is leaving the passport valid while blocking its use from a list the holder is never told about.

Copies went to the Interior Secretary and the heads of the passport department and the FIA, with an order to keep the list in line with the Act. We have seen no official word yet on an appeal.

None of this changes your passport itself. If you are renewing, the official passport fees still apply, and the reported switch to e-Passports means machine-readable passports end on 15 October. The ruling does not touch the official blue passport either.

Steps to take if you are stopped at the airport

If immigration stops you, ask which list you are on and on whose order. Then use the review route that list's law gives you. If no reasoned order comes, you can take the matter to a High Court, as this petitioner did twice.

1. Ask the officer which list shows your name. Note the date, time and flight.
2. Keep your boarding pass, ticket and visa. They prove you were offloaded.
3. If it is the ECL, send a written review request to the Ministry of Interior within 15 days of the order, under section 3 of the 1981 Ordinance.
4. If it is the PCL, apply in writing to the Director General, Immigration and Passports, for removal. Ask for a written, reasoned decision.
5. If you get no decision, or one with no reasons, speak to a lawyer about a writ petition under Article 199 of the Constitution.

Common questions

What did the Islamabad High Court decide about the PCL?

It struck out the sentence in Rule 22(2)(b) of the Passport Rules 2021 that let names go on the Passport Control List on the recommendation of government agencies or departments.

When was the judgment announced?

It was announced in open court on 14 September 2026. It was reported in the press on 26 September 2026.

Does the ruling remove everyone from the PCL?

No. It ordered only the petitioner's name removed, within 15 days. Others must seek removal themselves.

Is the Exit Control List affected?

No. The ECL runs under the Exit from Pakistan (Control) Ordinance 1981, which this case did not decide.

Can the government still stop someone from travelling?

Yes, but only through a lawful route, such as cancelling or impounding a passport under section 8 of the Passports Act after notice, or a Federal Government ECL order.

Last checked and sources

Last checked on 27 September 2026. The facts, the words struck out, the reasons, the dates and the orders are from the judgment in Writ Petition No. 1523 of 2026 on the Islamabad High Court website, approved for reporting. Rule 22 and section 8 of the Passports Act 1974 are as quoted in it. The ECL rules are from the Exit from Pakistan (Control) Ordinance 1981 as published by the FIA. We found no official statement on an appeal.