The Passport Control List travel ban imposed on a Pakistani citizen without proper legal process is unlawful, the Islamabad High Court (IHC) has ruled. In a five-page written judgment, Justice Muhammad Azam Khan ordered authorities to remove the name of citizen Zain Ateeq from the Passport Control List (PCL), finding no valid legal reason for keeping him on it.
What Is the Passport Control List?
The Passport Control List (PCL) is a system managed by the Directorate General of Immigration and Passports (DGIP) in Pakistan. In Pakistan, the PCL, formerly known as the Black List, is used to monitor and potentially restrict the travel of individuals based on security or legal reasons. It is managed by the Directorate General of Immigration and Passports.
Although similar to the Exit Control List (ECL), the PCL specifically deals with passport regulation, not direct travel bans. When a person’s name appears on the PCL, they may be denied passport renewal or stopped from leaving the country at the airport, often without any prior warning.
In many cases, individuals only learn about their PCL status when passport renewal or travel is denied. This has left some Pakistanis stranded abroad, unable to renew their documents at Pakistani embassies.
The Zain Ateeq Case Explained
Justice Muhammad Azam Khan issued a detailed five-page judgment in the case of citizen Zain Ateeq, whose name was added to the PCL after he was deported from Türkiye in July 2022.
Upon the petitioner’s request, the Federal Investigation Agency (FIA) recommended removing his name from the PCL after more than two years. However, the Passport Authority dismissed the request without sufficient justification.
The court ordered the authorities to remove his name from the Passport Control List, observing that no competent authority had formally decided to keep him on the list. It also noted that there was no evidence of any criminal conviction or pending criminal case against him in either Pakistan or Türkiye.
The court further ruled that although the passport authority holds final authority in such matters, recommendations made by the FIA cannot be ignored without reasonable and solid grounds.
IHC Passport Control List Ruling: The Key Points
The judgment lays down several important principles that affect how authorities can use the PCL going forward.
- A person deported for illegal entry or any other prohibited act cannot be kept on the PCL indefinitely without proper legal approval.
- Travel restrictions may only be imposed through lawful authority and the prescribed legal procedure, as the court reiterated by referring to the Shireen Mazari case.
- In the absence of any pending criminal proceedings, conviction, or other valid legal grounds, there is no justification for continuing the travel restriction against the petitioner.
- The power to place an individual on the Passport Control List is not unlimited and must be exercised in a lawful, reasonable, and transparent manner.
A Pattern of Courts Pushing Back
This ruling is not an isolated event. Pakistani courts at multiple levels have been pushing back against what they see as arbitrary use of travel restriction lists, and the Islamabad High Court’s Passport Control List travel ban ruling fits into a broader legal trend.
In a separate case in June 2026, the IHC declared it illegal to place individuals on the PCL solely because they were deported from a foreign country for overstaying their visa, holding that deportation due to visa overstay alone does not justify the imposition of travel restrictions.
Earlier in May 2026, the IHC ordered the removal of YouTuber Rajab Butt’s name from the PCL, ruling that such restrictions must be imposed fairly and within legal limits. Justice Azam Khan directed relevant institutions to immediately remove the petitioner’s name from the PCL, provided there is no other legal restriction or order from a competent court.
The Peshawar High Court also weighed in, with a bench holding that no travel restriction could lawfully exist without either a prior or, in cases of extreme urgency, a contemporaneous show cause notice, which must then be followed by a comprehensive reasoned order.
Even the Lahore High Court had earlier moved in this direction. The LHC set aside the federal government’s power to inactivate a citizen’s passport and impose a travel ban of five years or more by placing a person on the Passport Control List, judging that this authority was beyond the scope of the parent law. That LHC ruling was later suspended by the Federal Constitutional Court pending appeal, showing the legal debate is still ongoing at the highest levels.
What Does This Mean for Pakistani Citizens?
For ordinary Pakistanis, this ruling is a reminder that being placed on the Passport Control List is not necessarily the end of the matter. Courts have consistently held that the right to travel is a constitutional right protected under Article 15 of Pakistan’s Constitution, which guarantees freedom of movement subject only to reasonable restrictions imposed by law.
Restricting a citizen’s right to travel and employment abroad without any criminal basis violates constitutional guarantees, with courts citing violations of Articles 4, 9, 10-A, 15, 18 and 25 of the Constitution.
Critics argue that the PCL is sometimes misused for political victimisation, targeting opposition leaders, journalists, or activists. The IHC ruling adds judicial weight to arguments that such use is unlawful.
Citizens who believe they have been wrongfully added to the PCL can file a petition before the relevant High Court. Citizens wrongfully included in the PCL can seek administrative and judicial remedies to restore their rights.
Frequently Asked Questions
What is the Passport Control List (PCL) in Pakistan?
The PCL is a list managed by the Directorate General of Immigration and Passports. It can be used to block passport renewal or stop a person from leaving Pakistan. It is different from the Exit Control List (ECL), which directly bans travel.
Can the government add anyone to the PCL without a reason?
No. According to multiple court rulings, including this latest IHC judgment, a Passport Control List travel ban must be backed by legal authority, a valid reason such as a criminal case or security concern, and proper due process. Deportation alone is not sufficient grounds.
What should a citizen do if their name is on the PCL wrongly?
They can first submit a written request to the Ministry of Interior or the DGIP with supporting documents. If that does not work, they can approach the relevant High Court by filing a constitutional petition, as Zain Ateeq did successfully.
Is the government allowed to keep a name on the PCL indefinitely?
Periodic reviews are mandatory to avoid indefinite restrictions. Names cannot remain on the list indefinitely, and periodic review every three to six months is required by law. Courts have repeatedly held that indefinite travel restrictions without review violate fundamental rights.
