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Huzaima Bukhari & Dr. Ikramul Haq
Raising the living standard and socio-economic uplift of industrial workers is the cornerstone of the Government policy, which is being achieved by providing the basic and other social amenities of life to workers in the country.WWF has been playing vital and progressive role in providing various important services to the industrial workers. WWF has established many housing schemes for workers throughout the country and development works of new schemes are under progress. In medical sector, WWF has established hospitals and dispensaries in the areas of workers’ concentration. As for the education sector, primary to higher secondary level educational and training institutions have been established and being run all over the country. WWF also awards fully funded scholarships to the talented children of industrial workers. A number of other welfare activities such as marriage grant and death grant are also being run by WWF—Syed Zulfiqar Abbas Bukhari, Special Assistant to Prime Minister/Minister of State
It is settled law and an express command of the Constitution that the law enunciated by the august Supreme Court becomes binding precedent for all forums of the country. All the executive and judicial authorities and forums are constitutionally obliged to implement the orders of and the principles and law laid down by the Supreme Court. Even if a review is pending against a judgment the same shall be binding unless it has been reviewed and a different conclusion is reached by the august Supreme Court. A judgment of the apex Court would have due effect and deference if it decides a question of law or is passed on the basis of law and/or enunciates a principle of law—Khan Gul Khan and others versus Daraz Khan [2010 SCMR 539], Muhammad Tariq Badr and another versus National Bank of Pakistan and others [2013 SCMR 314], Sindh High Court Bar Association through its Secretary and others versus FOP through M/O Law and Justice, Islamabad and others [PLD 2009 SC 879], Commissioner Income Tax versus Habib Bank Ltd. ANZ and Grindlays Bank” [2015 PTD 619], Pakistan Telecommunication Employees Trust (PTET) through M.D. Islamabad and others versus Mohammad Arif and others [2015 SCMR 1472] and Nazir Ahmed and others versus The State and others [PLD 2014 SC 241]
On October 10, 2018, the Federal Minister for Inter Provincial Coordination, Dr Fehmida Mirza, chaired a meeting for resolving issues of Employees Old Age Benefits Institute and Workers Welfare Fund in the wake of the Constitution (Eighteenth Amendment) Act, 2010 [18th Amendment] that made many changes in the Constitution of Republic of Pakistan [“the Constitution”] that included omission of entire Concurrent Legislative List and certain amendments in the Federal Legislative List contained in the Fourth Schedule to the Constitution. The meeting was also attended by Syed Zulfiqar Abbas Bukhari, Special Assistant to Prime Minister/Minister of State for Overseas Pakistanis & Human Resource Development and representatives of Employers’ Federation of Pakistan and Pakistan Workers Federation from the provinces and Islamabad.
The meeting discussed in detail the issues faced by the Workers Welfare Fund and Employees’ Old Age Benefits Institution (EOBI) after the 18th Amendment. Dr. Fehmida Mirza observed: “We are not against devolution or provincial autonomy but we need the welfare of our workers”.
The representatives of workers emphasised the view that social security net should not be distributed among the states; rather it should be managed through the centre and implemented by the provinces. The trans-provincial fund, assets, institutions and the programs run by EOBI and Workers Welfare Fund (WWF) are difficult to be divided among the provinces. Besides, the migration of the workers would be a big challenge, if the subject considered is to be devolved, the welfare of the workers would be affected.
The Federal Minister for Inter Provincial Coordination said that the workers were the main stakeholders in this and the due importance must be given to their view point as well. She directed the participants to formulate their strategy and submit their point of view in a documented form, adding: “We believe in cooperative federalism, we need to strengthen each other, the government is committed to devise a mechanism based on consensus, to ensure the welfare of the workers.” The representative of workers thanked the Minister for providing them with the opportunity to bring forward their view point, while the next meeting in this regard will be scheduled soon”. What happened thereafter is not made public. It appears the deadlock persists between federation and federating units on the issue.
It is obvious the Minister for Inter Provincial Coordination and Special Assistant to Prime Minister/Minister of State for Overseas Pakistanis & Human Resource Development were not even aware of the fact that since 2006 amendments made in various labour laws to broaden their scope were struck down by the Supreme Court in its order of November 10, 2016 reported as Workers Welfare Funds m/o Human Resources Development, Islamabad through Secretary and others v East Pakistan Chrome Tannery (Pvt.) Ltd through its GM (Finance), Lahore etc. and others[(2016) 114 TAX 385 (S.C. Pak.)] and till today no remedial measures have been taken to retrieve losses caused to the Funds/Institutions established under these laws for the welfare of millions.
The Supreme Court held in [(2016) 114 TAX 385 (S.C. Pak.)] as under:
“2. The facts pertaining to these matters are broadly divided into three categories for ease of reference. The first set of facts are that Sections 2 and 4 of the Worker Welfare Ordinance, 1971 (Ordinance of 1971) were amended by Section 12 of the Finance Act of 2006 and subsequently by Section 8 of the Finance Act of 2008 which broadened the scope of the obligation on industrial establishments to contribute towards the Workers’ Welfare Fund established under Section 3 of the Ordinance of 1971. The said amendments (and notices demanding enhanced payment by virtue of the amendments) were challenged through writ petitions before various High Courts of the country. It is pertinent to mention that there are divergent views of the learned High Courts on this question. The view of the learned Lahore High Court in the judgment dated 19.8.2011 reported as East Pakistan Chrome Tannery (Pvt.) Ltd Vs. Federation of Pakistan and others (2012) 105 TAX 81 (H.C. Lah.) = (2011 PTD 2643) is that the levy in question was a fee and not a tax, therefore the amendments made by the Finance Acts of 2006 and 2008 to the Ordinance of 1971 could not have been lawfully brought through a money bill, rather should have been brought through the regular legislative procedure under the Constitution. The learned Peshawar High Court, vide judgment dated 29.5.2014, followed suit. Subsequently the learned Peshawar High Court disposed of numerous tax references on the basis of this decision, against which the appeals are before us. We would like to point out at the very outset that as regards those cases in which the revenue authorities/collecting agencies have assailed the judgment of the learned Peshawar High Court, although no rights of the collecting agencies have been affected as their job is to merely collect contributions for the Workers’ Welfare Fund, we are nevertheless deciding those cases as well keeping in view the importance of the matter and the conflicting judgments impugned before us. There is a contrary view of the Full Bench of the learned High Court of Sindh expressed in the judgment dated 1.3.2013 reported as Shahbaz Garments (Pvt.) Ltd Vs. Pakistan through Secretary Ministry of Finance, Revenue Division, Islamabad and others (2013) 107 TAX 89 (H.C. Kar.) = (PLD 2013 Kar 449) (Full Bench judgment) to the effect that the levy in question was a tax and not a fee, therefore the amendments made by the Finance Acts of 2006 and 2008 to the Ordinance of 1971 were lawfully brought through a money bill. The aforementioned judgments have been challenged by the parties before us.
3. The second set of facts are that various provisions of the Employees Old Age Benefits Act, 1976 (Act of 1976) pertaining to contributions to be made there under were amended by Section 9 of the Finance Act of 2008 effectively widening the scope of the obligation on employers to contribute towards the Employees’ Old-Age Benefits Fund established under Section 17 of the Act of 1976. These amendments were challenged through constitution petitions before the learned High Court of Sindh which, through its judgment dated 3.10.2012 reported as Soneri Bank Limited through Jaffar Ali Khan and others Vs. Federation of Pakistan through Secretary Law and Justice Division, Pak Secretariat, Islamabad and others (2013 PLC 134), held that the levy in question was a fee and not a tax, therefore the amendments made by the Finance Act of 2008 to the Act of 1976 could not have been lawfully brought through a money bill.
4. The third set of facts are that various provisions of the Workmen Compensation Act, 1923, the West Pakistan Industrial and Commercial Employees (Standing Orders) Ordinance, 1968 (Ordinance of 1968), the Companies’ Profit Workers’ Participation Act, 1968 (Act of 1968), the Minimum Wages for Unskilled Workers Ordinance, 1969 (Ordinance of 1969) and the Act of 1976 were amended through the Finance Act of 2007 which amendment(s) in effect broadened the scope of the obligation of the employers in the respective statutes (the obligation(s) in each statute shall be discussed during the course of the opinion). These amendments were challenged through a constitution petition before the learned High Court of Sindh which, through its judgment dated 26.2.2011, held that the changes sought to be made by amendments through the Finance Act of 2007 did not fall within the purview of Article 73(2) of the Constitution, hence, the said amendments could not have been lawfully brought through a money bill. All the aforementioned judgments have been challenged before us”.
Sections 2 and 4 of the Workers Welfare Ordinance, 1971 were amended by the Finance Act of 2006 and subsequently by the Finance Act of 2008 to broaden the scope of the obligation on industrial establishments to contribute towards the Workers’ Welfare Fund, established under Section 3 of the Ordinance of 1971. These amendments were declared ultra vires Constitution by Lahore High Court in East Pakistan Chrome Tannery (Pvt.) Ltd v Federation of Pakistan and others (2012) 105 TAX 81 (H.C. Lah.). This order was endorsed in 2016 by the Supreme Court in order cited above. Theissue was whether WWFis a fee or tax. The Supreme Court said it was ‘fee’ and not ‘tax’ and, therefore, the amendments made by the Finance Acts of 2006 and 2008 as Money Bill were unlawful.
Through the Finance Act 2008, various provisions of the Employees Old Age Benefits Act, 1976 pertaining to contributions to be made thereunder, were also amended widening the scope of obligation on employers to contribute towards the Employees’ Old-Age Benefits Fund established under Section 17 of the Act of 1976. These amendments were challenged through constitution petitions before the Sindh High Court which, through its judgment dated 3.10.2012 reported as Soneri Bank Limited through Jaffar Ali Khan and others v Federation of Pakistan through Secretary Law and Justice Division, Pak Secretariat, Islamabad and others(2013 PLC 134), held that the levy was a fee and not a tax, therefore, the amendments made by the Finance Act of 2008 could not have been lawfully brought about through a Money Bill. This view of Sindh High Court was also upheld by the Supreme Court.
Through the Finance Act of 2007 various provisions of the Workmen Compensation Act, 1923, the West Pakistan Industrial and Commercial Employees (Standing Orders) Ordinance, 1968, the Companies’ Profit Workers’ Participation Act, 1968, the Minimum Wages for Unskilled Workers Ordinance, 1969 and the Act of 1976 were amended through the Finance Act of 2007 to broaden the scope of the obligation of the employers in the respective statutes. These amendments were challenged before the High Court of Sindh which, through its judgment dated 26.2.2011, held that the amendments through the Finance Act of 2007 not falling within the purview of Article 73(2) of the Constitution could not have been lawfully inserted through Money Bill. The judgments of Lahore and Sindh High Courts were challenged in the Supreme Court that upheld the same in (2016) 114 TAX 385 (S.C. Pak.)] with the conclusion: “There may very well be certain levies/contributions that do not fall within the purview of Article 73(3) but still do not qualify the test of Article 73(2) and therefore cannot be introduced by way of a Money Bill, and instead have to follow the regular legislative procedure………….”.
The above shows the sheer incompetence of our governments and parliamentarians that they could not distinguish which laws are to be presented as Money Bill and which one should go to both the Houses. The beneficial amendments made wrongly in labour laws for the working classes over a decade back have not been corrected by Pakistan People Party (PPP) and Pakistan Muslim League (Nawaz) during the “Decade of Democracy” [2008-18] and by the coalition government of Pakistan Tehreek-i-Insaf (PTI) since coming into power in August 2018. It can be termed as the worst expression of callousness towards the labourers. All the parties during election claims claim to be champions of the cause of the downtrodden but in reality this is merely for lip service. The PMLN and PPP got ten years to rectify the mistake pointed out by the courts but they remained unmoved. The same apathy is demonstrated by the PTI Government. This confirms that when the matter comes to welfare of the workers, our legislators are totally insensitive but when issue is of raising their own salaries, laws are passed within a few minutes in the Senate and National Assembly. They did not bother that their lapse has affected over half a million pensioners under EOBI and some five million workers of various categories including women, registered for contributions.
Before the 18th Amendment, the Federal Board of Revenue (FBR) had the power to collect contributions under Workers’ Welfare Funds Ordinance, 1971 (WWF) and Profits (Workers’ Participation) Act, 1968 (WPPF) from across the country. After the 18th Amendment, the powers were devolved to the provinces. The Sindh Assembly was the first province to pass the Sindh Workers Welfare Fund Act, 2014 to collect WWF and the Sindh Companies Profits (Workers’ Participation) Act, 2015 to collect WPPF. The Punjab Assembly following the Sindh Assembly enacted Punjab Workers Welfare Fund of 2019.
The Sindh High Court (SHC) in its order reports as 2018 CLD 1088 held that the Sindh Companies Profits (Workers’ Participation) Act of 2015 would apply to all trans-provincial companies employing a total of 100 or more workers at any time of the year, and operating across the country irrespective of the regional location of their registrations. It elaborated that the principle of territorial limitation was not violated as it was only to establish parameters that would make the scheme applicable. The condition which related to value of fixed assets of the company, according to SHC, was irrelevant as the same could be located within or outside the Province. It directed that the law in the province of Sindh was to be applied and workers were to get an amount proportionate to their number calculated. The workers in the province of Punjab were to get an amount proportionate to their number calculated at five percent and the same was not discriminatory. It enunciated that the legislative competence was exclusively provincial and territorial extent was limited. According to this judgement, each Province was entitled to legislate in its own manner in respect of a matter that was exclusively within its domain and it was irrelevant as to where the registered office and/or industrial undertaking of trans-provincial company were located i.e. that same could be located in the Province of Sindh or elsewhere and while making computation, the whole of profits made by company were to be used, regardless of where they were earned in the entire country.
In its order, the SHC said the purpose of WPPF was the welfare of labour and there were no problems applying it to all the workers of a company throughout Pakistan. It retained this character on the commencement of the Constitution and up to the 18th Amendment (from 1973 to 2010). “The Act thereafter ‘fractured’ into provincial legislation and was then replaced by the Sindh Act,” the SHC’s order put in plain words. The Sind Revenue Board (SRB) official on the basis of this judgement asserted that the provincial revenue authority was mandated to collect the amount from corporate and industrial units operating within the jurisdiction of the province or their offices or officers working in any other province or within the jurisdiction of the Federal Government. The concluding paragraphs of the judgement are as under:
33. Secondly, on the view that has been taken the specific problem identified by the learned Additional Attorney General, relating to dispute resolution also disappears. It is obvious that in our view, the 1968 Act as applicable in the other Provinces and the Capital respectively will apply there in the same manner as the Sindh Act in this Province, i.e. in respect of all the workers within the relevant territorial domain. Thus, if a worker, say in Punjab, has a dispute with a company that has its registered office here, he does not have to come to this Province for redressal; he can simply invoke the procedure available under the 1968 Act, as applying in Punjab as provincial legislation. The reverse would, obviously, also be true. Thirdly, a potential issue of a variation in the amount of distributable profits would also cease to be a problem. Currently, in each Province and in the Capital, the same percentage of the total profits is to be distributed, being five percent. But of course, that need not always be the case. Since the competence is now exclusively provincial, each Province (or the Federation in respect of the Capital) can vary the amount. Suppose the Sindh Act were to be amended so as to increase the amount to, say, seven percent. What would be the position of a trans-provincial company that had its registered office in, say, Punjab where the amount continued to remain at five percent? Could such a company argue that it was only liable to distribute to the workers in Sindh a proportionate amount calculated on the basis of five percent? In our view, the answer would have to be in the negative. The law in this Province would have to be applied, and workers here would get an amount proportionate to their number calculated at seven percent. Of course, the workers in Punjab would get an amount proportionate to their number calculated at five percent. But would this not be discriminatory? Again, the answer is that it would not. The reason is that the legislative competence is exclusively provincial, and the territorial extent is limited. Each Province is entitled to legislate in its own manner in respect of a matter that is exclusively within its domain.
34. In view of the foregoing discussion, we therefore answer the issue specified in para 2 above, which relates to the third category identified in the order of 19.09.2017, as follows. In the case of trans-provincial companies, it is the Sindh Act that applies, but interpreted, read and applied such that the obligation under the Act is only to make distribution to the workers in this Province, and only of an amount that is proportionate to their number here. It is irrelevant where the registered office and/or the industrial undertaking of the trans-provincial company are located, i.e., they could be located in this Province or elsewhere. Furthermore, in making the computation, the whole of the profits made by the company are to be used, regardless of where they were earned in the country.
On the contrary, the august Supreme Court in the case of Messers Sui Southern Gas Ltd & Others v Federation of Pakistan & Other 2018 SCMR 802 has extensively elucidated that the post-Eighteenth Amendment position vis-à-vis legislative competence of federation and federating units, holding as under:
“2. The Islamic Republic of Pakistan is a democratic State (Federation) with its Federating Units (Provinces) and the Constitution of the Islamic Republic Pakistan, 1973 (Constitution) recognizes and creates a balance between the authority of the Federation and the autonomy of the Provinces, which recognition has been given an iron cladding by virtue of the Eighteenth Amendment, passed vide the Constitution (Eighteenth Amendment) Act, 2010. This Amendment to the Constitution has inter alia introduced a drastic enhancement in the legislative authority of the Provinces by deleting the Concurrent Legislative List (CLL), whereby previously both the Parliament and the Provincial legislatures could legislate on the subjects enumerated therein. The omission of the CLL, left only a single Legislative List in the Constitution which exclusively list subjects that can be legislated upon by the Parliament alone, and by virtue of Article 142(c) of the Constitution any subject not enumerated in these two lists would subject to the Constitution, be within the legislative competence of the Provinces. Entry No. 26 of the erstwhile CLL contained the subjects of “welfare of labor; conditions of labor, provident funds; employer’s liability and workmen’s compensation, health insurance including invalidity pensions, old age pensions”, whereas, Entry 27 of the same dealt with the subjects of “trade unions; industrial and labor disputes”. Thus, prior to Eighteenth Amendment, the subject of labour and trade unions were in the domain of both the Parliament as well as the Provincial Assemblies. The labour laws enacted by the Parliament which were applicable in the Federation as well as the Federating Units. However, after the Eighteenth Amendment, the Parliament enacted the Industrial Relations Act 2012 (IRA 2012) which was challenged before the concerned High Courts (all the provincial High Courts as also the Islamabad High Court) mainly on the ground that the same is incompetently enacted by the Parliament as the subject of labour and the trade unions was no more in the legislative domain of the Parliament rather within the domain of the Provincial Assemblies. All the High Courts held (through judgments impugned herein as also other judgments) in favour of the constitutionality/validity of the IRA 2012.
20. At this juncture it is to be noted that when a provincial legislature is not competent to legislate with regard to the workmen of trans-provincial establishments, obviously the Federation has to interfere in the matter with a Federal Legislation to preserve and protect the fundamental rights of the said workmen ensured under Article 17 of the Constitution. We are in agreement with the observation made by the learned High Court that though in a Federal system, provincial autonomy means capacity of a province to govern itself without interference from the Federal Government or the Federal legislature, but as the Provincial legislature does not possess extra-territorial legislative authority i.e. it cannot legislate regarding the establishments operating beyond the territorial boundaries of that province. In absence of a Federal legislation, the right to form a trade union that can operate beyond the provincial boundaries could not be secured by any provincial law, and as such, any matter or activity of a trans-provincial nature would remain unregulated. The only solution to the above said problem is a Federal legislation. The effect of non-promulgation of IRA 2012 would be that the employer would not recognize the right of the workmen to form a countrywide trade union and carry out unified activities in his establishment at trans-provincial level; and also the number of workmen working in each unit of an establishment working in a certain Province would be counted separately which in turn would have adverse impact on the rights of the workmen, in so far as applicability of benefits and security of job granted under various labour laws are concerned as certain rights granted under various labour laws become available to the workmen depending upon the total strength of the workmen in an establishment. Needless to observe that as mentioned in its preamble, the object of promulgation of IRA 2012 is “to consolidate and rationalize the law relating to formation of trade unions, and improvement of relations between employers and workmen in the Islamabad Capital Territory and in trans-provincial establishments and industry”. Further, as per Section 3 thereof “it shall apply to all persons employed in any establishment or industry, in the Islamabad Capital Territory or carrying on business in more than one province”. Hence, the parliament in its wisdom has intentionally left it for a Province to make legislation concerning the establishments/trade unions functioning only within the limits of that Province, without transgressing the territorial limits of the said Province. Thus, neither does the IRA 2012 in any manner, defeat the object of the Eighteenth Amendment nor does it destroys or usurps the provincial autonomy or the principle on which the Federation was formed under the Constitution; rather it facilitates to regulate the right to form unions at trans-provincial level, which could not be attained through a provincial law.
23. For the foregoing reasons, the appeals as also the petition are dismissed and it is held as under:–
- the Federal Legislature has extra-territorial authority but no such extra-territorial authority has been conferred to the Provincial Legislature by the Constitution;
- the Federal legislature does, but the Provincial Legislature does not, have legislative competence to legislate to regulate the trade unions functioning at trans-provincial level;
- the matters relating to trade unions and labour disputes, etc., having been dealt with and protected under the International Conventions, are covered under Entries No.3 and 32 of Part-I of the FLL. Thus, the Federal Legislature has legislative competence to legislate in this regard;
- under the command of Entry No.13 in Part-II of the FLL, the Federation has competence to enact laws relating to the inter-provincial matters, Entry No.18 thereof further enlarges the scope of the said Entry; therefore, the Federal Legislature has legislative competence to legislate in this regard too;
- the IRA 2012 neither defeats the object of the Eighteenth Amendment to the Constitution nor does it destroy or usurp the provincial autonomy;
- the IRA 2012 has been validly enacted by the Parliament and is intra vires the Constitution;
- the workers of the establishments/industries functioning in the Islamabad Capital Territory or carrying on business in more than one provinces shall be governed by the Federal legislation i.e. IRO 2012; whereas, the workers of establishments/industries functioning or carrying on business only within the territorial limits of a province shall be governed by the concerned provincial legislations;
- as we have held that the IRA 2012 is valid piece of legislation, it is held that the National Industrial Relations Commission (NIRC) formed under Section 35 of the IRA 2012 has jurisdiction to decide the labour disputes, etc., relating to the employees/workers of companies/corporations/institutions/establishments functioning in more than one Province;
- the IRA 2012, being a procedural law, would be applicable retrospectively w.e.f. 01.05.2010, when the IRO 2008 ceased to exist; and
- M/s Shaheen Airport Services is not a charitable organization and IRA 2012 is applicable to it as it is operating in more than one Province.
[Underlined by us for emphasis]
The above pronouncement of the Supreme Court is not restricted to any particular law and covers all laws, including those relate to welfare of labour and providing social security to citizens. It is binding under Article 189 of the Constitution. Since, the issue relates to trans-provincial applications/operations, in the light of above order of the Supreme Court, through democratic process vide Article 144/147 of the Constitution, all laws related to workers and social security can be federalised rather than ‘fractured’ or fragmented and managed by multiple agencies/institutions in provinces.
It is high time that the Government of PTI should come to the rescue of the affectees by curative amendment or supporting the review petition pending in Workers Welfare Funds m/o Human Resources Development, Islamabad through Secretary and others v East Pakistan Chrome Tannery (Pvt.) Ltd through its GM (Finance), Lahore etc. and others [(2016) 114 TAX 385 (S.C. Pak.)] on the basis of above cited case [2018 SCMR 802]. The better course is that the Ministry of Interprovincial Coordination, in consultation with Ministry of Law should get a Bill prepared in the light of observations of the Supreme Court in the above cited case and ensure retrieval of lost contributions retrospectively that is outstanding from 2006. No party in National Assembly and Senate is going to oppose this Bill or will get exposed as anti-labourer. Recovery of money and its settlement between federal government and provinces can be settled by Ministry of Inter Provincial Coordination under Article 144 of the Constitution.
The curative amendment will bring billions in the national kitty for providing pension, decent housing, free education and health facilities etc. for the beneficiaries of welfare laws. The PTI Government is looking for money for such objectives, not knowing that billions are lying unpaid with industrial undertakings/employers. The legislators have failed to take note of the fact that any provincial assembly, (in Khyber Pakhtunkhwa, PTI has two thirds majority and in Punjab and Baluchistan has coalition governments) by a resolution under Article 144 of the Constitution can ask National Assembly, to enact laws for welfare of workers and social security of citizens. The funds would go into National Fund to provide help to all workers and citizens wherever residing. It is strange that the Law Ministry even did not give this advice even after judgement of Supreme Court on Article 149 of the Constitution in Suo Muto Case 1 of 2020.
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Ms. Huzaima Bukhari, Advocate High Court and Visiting Faculty at Lahore University of Management Sciences (LUMS), is author of numerous books and articles on Pakistani tax laws. She is editor of Taxation and partner of Huzaima & Ikram, a leading law firm of Pakistan. From 1984 to 2003, she was associated with Civil Services of Pakistan. Since 1989, she has been teaching tax laws at various institutions including government-run training institutes in Lahore. She specialises in the areas of international tax laws, corporate and commercial laws. She is review editor for many publications of Amsterdam-based International Bureau of Fiscal Documentation (IBFD) and contributes regularly to their journals. She has to her credit over 1500 articles on issues of public importance, printed in various journals, magazines and newspapers at home and abroad.She has also coauthored with Dr. Ikramul Haq many books that include Pakistan: Enigma of Taxation, Towards Flat, Low-rate, Broad and Predictable Taxes, Law & Practice of Income Tax, Law , Practice of Sales Tax, Law and Practice of Corporate Law, Law & Practice of Federal Excise, Law & Practice of Sales Tax on Services, Federal Tax Laws of Pakistan, Provincial Tax Laws, Practical Handbook of Income Tax, Tax Laws of Pakistan, Principles of Income Tax with Glossary andMaster Tax Guide, Income Tax Digest 1886-2011 (with judicial analysis). She regularly writes columns for Pakistani newspapers and has contributed over 1500 articles on issues of public finance, taxation, economy and on various social issues in various journals, magazines and newspapers at home and abroad.
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Dr. Ikramul Haq, Advocate Supreme Court, specialises in constitutional, corporate and tax laws. He established Huzaima & Ikram in 1996 and is presently its chief partner as well as partner in Huzaima Ikram & Ijaz. He studied journalism, English literature and law. He is Chief Editor of Taxation andVisiting Faculty at Lahore University of Management Sciences (LUMS). He has also coauthored with Huzaima Bukhari many books that include Pakistan: Enigma of Taxation, Towards Flat, Low-rate, Broad and Predictable Taxes, Law & Practice of Income Tax, Law , Practice of Sales Tax, Law and Practice of Corporate Law, Law & Practice of Federal Excise, Law & Practice of Sales Tax on Services, Federal Tax Laws of Pakistan, Provincial Tax Laws, Practical Handbook of Income Tax, Tax Laws of Pakistan, Principles of Income Tax with Glossary andMaster Tax Guide, Income Tax Digest 1886-2011 (with judicial analysis). He is author of Commentary on Avoidance of Double Taxation Agreements signed by Pakistan, Pakistan: From Hash to Heroin, its sequelPakistan: Drug-trap to Debt-trap and Practical Handbook of Income Tax. He regularly writes columns for many Pakistani newspapers and international journals and has contributed over 2500 articles on a variety of issues of public interest, printed in various journals, magazines and newspapers at home and abroad.