vii) In Shahid Ali v. The State (2025 SCP 250), the Supreme Court reiterated that

Lahore High Court

a confession made to a police officer is inadmissible under Article 38 of the QSO, even if made in t he presence of a Magistrate. A statement made while in police custody, even to a third party, is inadmissible under Article 39 unless recorded in the immediate presence of a Magistrate. The eviden

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