Land ownership in Pakistan remains a complex subject dating back to the era of the People’s Party government (1971-7) under Prime Minister Zulfiqar Ali Bhutto (Kennedy, 1993). During this time, large landlords that held tracks of agricultural lands in excess of 150 acres 2 were to lose such lands without compensation from the government. The Land Reform Regulation of 1972 proposed that the government was to give such lands to the landless as a way of reducing poverty levels among the rural population (Kennedy, 1993). This land reform came to be known as the Martial Law Regulation – MLR 115. A significant provision of the MLR – 115 was section 25 that gave tenants the first right to purchase such tracks of land from their landlords. With high number of large tracks of lands on the hands of a few wealthy individuals, Bhutto went on to sponsor a bill, the Land Reform Act, 1977, which reduced the maximum allowable land size from 150 to 100 acres 2 . Markedly, the 1977 Act provided for compensation to landlords whose lands had to be taken for distribution to the landless. The land question remained contentious that the move was intended to reduce power and dominance of the Pakistan’s wealthy class, transform the Pakistan’s agricultural production to modern efficient agricultural entrepreneurship, and enhance equality in the rural regions (Kennedy, 1993). With high political interests and opposition during the same period, implementation of the Land Reform Regulation, 1972 (Martial Law Regulation – MLR 115) took a political direction. Bhutto’s government fully implemented the reforms more in opposition strongholds of NWFP and Balochistan than in their strongholds of Punjab and Sindh (Kennedy, 1993). With numerous political opposition from different quarters on the introduced land reforms, a military coup deposed Bhutto’s government in July 1977. So controversial was the land issue that landlords viewed the idea as meant to ‘snatch’ them their long-standing control in politics the rural areas of Pakistan. Bhutto held that such reforms on land would create a democratic Islamic state that practices socialism (Kennedy, 1993). However, critics argued that the Prime Minister used the land reforms to punish his political enemies since he concentrated the implementation in their strongholds of NWFP and Balochistan. In addition to the unjust policy administration, critics argued that such reforms of denying people their rights to own land were un-Islamic; therefore, it ought to be discarded. So conflicting was the land issue that most landlords went to court to challenge the provisions of the acts, such as tenants’ right to pre-emption. Haji Niamatullah held that not even the Holy Quran gives tenants’ right to pre-emption; therefore, the reforms were going against the Islamic culture (Kennedy, 1993). Additionally, such rights are not mentioned in reports of the prophet’s actions and sayings. The Shariat benches of the high court found that the provisions were repugnant to Islam, thus should not be applied in their situations. In a twist of events, the benches formed the Federal Shariat Court (FSC) in 1980 to continue handling land cases, but with limited constitutional guidelines (Kennedy, 1993). Landlords claimed that the provision gave tenants exces