Initial presumption in Pakistan is that a Muslim is a Sunni until the contrary is proved; and, that the burden to prove that the deceased was Shia is on the person alleging him to be not Sunni but Shia

The full Bench of Hon’ble Supreme Court of Pakistan in the case of “Ghulam Shabbir and others v. Mst. Bakhat Khatoon and others” (2009 SCMR 644) has held that the initial presumption in Pakistan is that a Muslim is a Sunni until the contrary is proved; and, that the burden to prove that the deceased was Shia is on the person alleging him to be not Sunni but Shia.  

Part of Judgment
 THE LAHORE HIGH COURT LAHORE 
Civil Revision
1777836.955-15
2018 LHC 701

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