Headnotes are not part of the judgment, therefore, it is neither safe nor desirable to cite headnotes in judgments.

The headnotes preceding the judgment of a court are not a part of that judgment but are the notes prepared by the editors of the law-reports, highlighting the key law points discussed in the judgment and are supplied just to facilitate the reader with a summarized version of the salient features of the case which helps in quickly scanning through the law reports. It is a matter of common knowledge that the headnotes are at times misleading and contrary to the text of the judgment. Headnotes by the editors of the law-reports cannot be taken as verbatim extracts of the judgment and relied upon as conclusive guide to the text of the judgment reported, hence they should not be cited as such. Therefore, it is neither safe nor desirable to cite a dictum by reference to the headnotes.1 We are sanguine that in future the High Courts and the District Courts while referring to a precedent or case law in their judgments and orders will cite the actual text of the judgment rather than place reliance on the headnotes thereof.

C.P.1274-L/2013
Province of Punjab, etc v. Hafiz Muhammad Ahmad
Mr. Justice Syed Mansoor Ali Shah
29-07-2021
26-07-2021