text:
HTC has released a version of HTC Touch2 without the camera. This will be good news for our National Service Man or Government related companies that forbid them to bring in camera phones. The HTC Touch2 (non camera) will be available from this weekend at authorized resellers in Urban Brown at a suggested retail price of SGD $398. (Inclusive of 7% GST)*
HTC Touch2™ (non-camera) – A Touch of Communication Perfection for National Servicemen & Government Personnel
Singapore – 3 August 2010 – Staying in touch with people and information that matter just got easier especially for all National Servicemen and government personnel with the introduction of the HTC Touch2™ (non camera)(non camera) – a full touch smartphone experience designed to empower all that are employed in high security environments.
The HTC Touch2 (non camera) utilizes the powerful Windows Mobile® 6.5 platform and integrates that with innovative HTC unique features like TouchFLO – an enhanced user interface that includes integrated weather updates and quick access to your favourite applications with just a touch.
A full touch screen experience that fits in the palm of your hand
Though compact and weighing in only at a mere 110g (battery included), the ergonomically-designed HTC Touch2 aptly showcases its ability to let you take charge of your work and social life on-the-go. Setup and access both work and personal emails with just a username and password. You can also backup and restore those emails, contacts & calendar appointments effortlessly with Microsoft® My Phone. Let loose the social butterfly within with the pre-loaded Live Messenger and FaceBook applications that are bound to keep you glued to your touch screen display on the go.
Pricing & Availability:
The HTC Touch2 (non camera) will be available from this weekend at authorized resellers in Urban Brown at a suggested retail price of SGD $398. (Inclusive of 7% GST)*.
*All prices are subject to pricing policies of individual operators


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subset: commoncrawl


text:
For 12 pieces
INGREDIENTS: tsp = teaspoon tbsp = tablespoon
cup = 200 ml
1 cup flour
3 tbsp Honey
1 tsp Sesame oil
1 tbsp Sesame seed
- Parch flour in a frying pan with wooden spatula over medium heat.
- When the flour turned yellow (about 5/7 min)put the flour in a bowl and add the honey. Mix all together until having a soft dough
- You can use any silicone tin (like the one you use for ice cube for exemple) to make nice shape
- Put some sesame oil in each shapes of the tin and fill with the dough, using your fingers to well tamp the dough down.
- Once you finish to fill in, you can start to turn all the pieces out.
- Put them on a dish and scatter each small cake with sesame seeds


text:
California schools have an average of 1,000 students for every guidance counselor. The American School Counselor Association recommends a ratio of 250 students to one. But as public school budgets shrink, counseling programs get cut, and that forces counselors across the country to take on bigger case loads.
Guest: Tim Conway, Director of Guidance, Lakeland Regional High School, Wanaque, N.J.


text:
DNA Evidence in Pakistani Courts: An Analysis
Dr. Shahbaz Ahmad Cheema*
This article examines the approach of Pakistani courts with respect to the admissibility and evaluation of DNA evidence. The case law analysis brings to the fore two distinct streams of cases in which parties attempt to rely on DNA evidence: paternity/legitimacy of children and sexual offences. In the first category of cases, courts are reluctant to question paternity/legitimacy on the basis of DNA evidence due to a legislatively enforced conclusive presumption under the Qanun-e-Shahadat Order 1984 in favor of paternity/legitimacy. DNA evidence is admissible in the second category of cases and its value is determined on a case-by-case basis. Under the prevalent legal framework, DNA evidence is regarded as equivalent to an expert opinion, and is thus treated as corroboratory or secondary evidence. This laxity on the part of the judiciary is further compounded by the ill-trained investigating agencies and the lack of scientific resources needed for careful collection and preservation of DNA evidence. Against this background, this article underscores the re-examination and re-formulation of the present legal framework around the assessment of DNA evidence by the courts so as to maximize its benefits for the investigation of crimes.
1. Introduction
While there is a growing body of reported judgments dealing with questions concerning the admissibility and weight of DNA evidence in Pakistan, there is little scholarship available on the subject. This article hopes to bridge this gap by presenting an analysis of the case law on DNA evidence. It looks at the established jurisprudence on the matter in order to map and explain the state of law in this jurisdiction, along with urging the re-examination and re-formulation of the present legal framework in order to maximize the benefits that can be derived from the use of DNA evidence.
This article is divided into three sections. The introductory section discusses some of the contemporary issues relating to DNA evidence in developed countries and reproduces the provisions of law dealing with its admissibility in the legal system in Pakistan. The second section comprises of an extensive analysis of the reported judgments of the superior judiciary on the admissibility and evaluation of DNA evidence. This section is further divided into two sub-sections keeping in view the nature of cases in which DNA evidence is produced before Pakistani courts. The first sub-section traces its relevance in paternity/legitimacy cases and explains why it is discouraged in these cases. The second sub-section takes up the task of explaining the admissibility and assessment of DNA evidence in sexual offences. This analysis highlights the main argument of this article, which is that treating DNA evidence as corroboratory evidence ultimately reduces its utility and stems its potential as an effective forensics tool. The article concludes by summarizing the main findings of the research and making policy suggestions for the best use of DNA evidence.
1.1 Contemporary Issues Relating to DNA Evidence in Developed Countries
DNA evidence has revolutionized the world of forensic sciences in technologically advanced countries. Many of them maintain DNA databases for the investigation of crimes. Many crimes that were once difficult to investigate due to lack of evidence are now being revisited, and offenders are being put behind bars. It is the prevalence of DNA databases in various European countries that has made some scholars and policy-makers contemplate a pan-European DNA database.[2] DNA databases enhance the probability of arrest of profiled offenders as compared to similarly situated un-profiled offenders, and consequently, huge databases are more likely to reduce the commission of offences.[3]
There are many ethical and legal issues involved in maintaining a DNA database, but in the public interest, it is gaining currency. Considering a plethora of ethical issues associated with maintaining such a database, it has been termed an 'ethical minefield'. [4] Maintaining a DNA database of only some categories of offenders violates the rights of those who have been sampled. Alternatively, if a country opts to maintain a database of all offenders, or even of the entire population, it would increase costs exponentially.[5]
The Supreme Court of the United States of America weighed in on the legal issues surrounding the maintenance of DNA databases in Maryland v King.[6] The Court upheld a statute enacted by the State of Maryland for the preservation of DNA samples of some categories of offenders (eg sexual offenders) on the basis of public interest. The Court found some force in the argument advanced by the accused that the impugned law related to the involuntary extraction of cheek swabs of an offender for DNA analysis was contrary to the constitutional protection against unreasonable searches and seizures, and violated personal privacy, but it further observed that such an involuntary extraction was like fingerprinting and photographing which had already been held constitutional. The Court also noted that the law was meant to foster public interest by establishing a DNA database and that in such cases, personal interest could not defeat the interest of an entire community.
Tania Simoncelli has pointed out that in addition to undermining the goal of individual liberty and justice for all, maintaining a DNA database would impose an unjustifiably heavy cost on society.[7] Establishing such a database is not financially viable for countries like Pakistan because it requires huge resources for building and maintaining infrastructure. Moreover, samples of DNA are susceptible to extensive misuse if proper checks are not put in place. DNA is the repository of our genetic makeup; if a country maintains a database but does not introduce measures for curbing its misuse by punitive sanctions, the right of privacy of those sampled would be jeopardized.[8] Nevertheless, the potential benefits of DNA evidence are innumerable and each country may benefit from it according to its legal and scientific infrastructure.
It must be borne in mind that many experts agree on the fact that DNA evidence is not always flawless and conclusively reliable. Like all other forms of evidence, its results are subject to interpretation. The possibility of the collection of incomplete samples for extraction, contamination, intentional planting of biological samples, and the possibility of faulty conclusions by experts all diminish the claims of the infallibility of DNA evidence.[9]
1.2 Statutory Framework in Pakistan
In Pakistan, there is no particular legal framework that specifically deals with DNA evidence, and hence the courts have to maneuver while remaining within the legal framework hitherto available. DNA evidence is evaluated in the context of Articles 59 [10] and 164 [11] of the Qanun-e-Shahadat Order 1984 ('QSO'). The former provision states that expert opinion on matters such as science and art falls within the ambit of 'relevant evidence', whereas the latter provision provides grounds for admissibility of various modes of proof made available due to advancements in science and technology. Under the present legal framework, the technician who conducts experiment to scrutinize DNA evidence is regarded as an expert whose evidence/opinion is admissible in court. This legal framework is no different from the one governing the admissibility of a medical opinion, which gives the impression that DNA is another kind of medical evidence, and that a DNA expert is like a doctor. If DNA is evaluated from this perspective exclusively, we might not fully benefit from its usage. The main distinction between medical opinion and DNA evidence is that the former does not identify offenders[12] whereas the latter does so with a high degree of accuracy. Hence, it would be more appropriate to evaluate it from a different legal perspective. But as we shall see, the courts have not interpreted the law progressively enough, and there is much ground to be covered.
2. DNA Evidence in Pakistani Courts
This section of the article is dedicated to the analysis of the cases decided by Pakistani courts involving DNA evidence. The purpose of this analysis is to explore how the present legal framework has influenced and shaped the judicial approach. During the analysis, two streams of cases have surfaced: one deals with paternity/legitimacy and the other with sexual offences. There are different legal provisions for both these streams of cases. In one set of cases, DNA evidence is discouraged and excluded, while in the other, it is admitted but its reception is not unswerving or optimal. I have divided this section into two sub-sections in order to consider the two streams separately.
2.1 Paternity/Legitimacy Cases
Paternity is an important and sensitive matter since it has many legal and social consequences. The issue of paternity is likely to attain added significance in a society with religious inclinations. That is why the modes in which paternity is ascertained are elaborated in sufficient detail in almost all legal systems. In Pakistan, the determination of paternity is a matter of personal law. Since Pakistan is a Muslim majority country, it seems appropriate to briefly state some important points of Muslim Personal Law on the subject which would make the tricky relationship between DNA and paternity disputes more understandable.
On the basis of a well-known saying of the Holy Prophet (PBUH), a child is attributed to a person in whose wedlock he/she is born.[13] In a situation where dispute arises as to the paternity of a child, and no direct evidence is available to ascertain paternity, the mode of presumption is resorted to in order to fill the void of factual evidence. There is a difference of opinion among the Muslim scholars as to what should be the maximum period of time for extending paternity to a child born after the dissolution of marriage. The Pakistani legislature has enacted Article 128 of the QSO in line with the Hanafi point of view.[14] According to this provision, a child born after six lunar months of marriage and within two years after dissolution of marriage will be considered legitimate and attributed to his/her putative father. According to the said provision, this fact is regarded as a 'conclusive proof' and no evidence can be admitted to refute it.[15] There are two exceptions to this: (a) if the child is disowned by the father, and (b) if the child is born after six lunar months once the mother declares expiry of her iddat period.[16]
In view of the aforementioned principles, the legal framework of paternity does not leave much space for the admissibility of DNA evidence. One of the earlier reported cases on the subject is Muhammad Arshad v Sughran Bibi.[17] In this case, a suit for recovery of maintenance was filed by the mother and her minor son. The petitioner (father) disowned the minor while responding to the claim. For substantiating his contention, an application was filed by the petitioner in a Family Court praying for a DNA test of the child which was dismissed. Thereafter, the petitioner filed a petition in the Lahore High Court to challenge the order of the Family Court dismissing his application. While considering his petition, the Court observed that the determination of a child's legitimacy entailed far-reaching consequences, and therefore, the determination of such crucial and vital issue should not be done in a cavalier manner. The Court felt that the accusations leveled by the petitioner and his act of disowning the child born in the wedlock needed to be substantiated through tangible proof and credible evidence, which were found to be missing in the petitioner's case. Following the traditional stance supported by Pakistani law, the Court highlighted that the paternity of a child born in a lawful wedlock invariably carries the presumption of truth and thus the mere denial could never take away the status of legitimacy as 'child follows the bed'. The metaphor of bed in the hadith implies the owner of the marital bed, i.e. the woman's husband. The Court further observed that if the petitioner was right in his stance, he should have resorted to the process of liyan[18] instead of challenging the paternity for the first time in a suit for maintenance. Consequently, the petition was dismissed in limine and the Family Court's order of refusing the request for DNA test was held to be lawful. It appears that the Court was reluctant to go beyond the conclusive presumption of paternity enshrined in Article 128 of the QSO, and for this purpose, it foreclosed the process of discovery of a piece of evidence (i.e. DNA) which might have jeopardized the concept of presumptive paternity/legitimacy without there being any other credible evidence.
In Sharafat Ali Ashraf v Additional District Judge, Bahawalpur, [19] the petitioner denied his marriage with the respondent and filed a suit for jactitation of marriage after the respondent had filed a suit for maintenance. During the pendency of the suit, a daughter was born, and was impleaded as a party. The Family Court held the respondent and the daughter entitled to maintenance, and the appellate courts also upheld its decision. Thereafter, the petitioner contended before the Supreme Court that the courts below were guilty of gross injustice by not conducting a DNA test. The Court analyzed the record of the case and found that there was convincing and substantial evidence of marriage between the parties, and the lower courts had rightly concluded that the parties were lawfully married. The petitioner had denied the fact of marriage and the legitimacy of his daughter without substantiating his claim by reliable evidence. He was unable to prove that the daughter was born either after the dissolution of marriage, or that the respondent had committed adultery. Since the daughter was born after six lunar months of the marriage and before the conclusion of two years since dissolution, her legitimacy and the consequent paternity could not be called into question through unsubstantiated claims. While dismissing the petition, the Court further underscored that the case of the petitioner was motivated to avoid his responsibility of maintaining the daughter.
In Khizar Hayat v Additional District Judge, Kabirwala, [20] the subordinate courts passed a decree for the maintenance of a son. In this case, the petitioner denied the paternity of the son, eleven years after his birth and requested a DNA test. The High Court observed that a DNA test could not be ordered when it was proven that the son was born during the marriage, and the petitioner was unable to bring any reliable evidence for disputing his legitimacy. The Court deplored the undesirable practice of denying legitimacy to one's own children in order to avoid paying maintenance, or excluding them from inheritance. The Court also raised certain questions about skilled personnel and requisite scientific infrastructure for conducting DNA tests in Pakistan and expressed its apprehension that, in such circumstances, any mistake or malpractice during the test might end up stigmatizing a child for the rest of his/her life.
As is evident from the above reported cases, the judicial approach of discouraging DNA tests in cases of paternity brought by fathers seems settled at present. The courts frustrate all efforts meant to dispute the legitimate status of children, as Article 128 of the QSO precludes the admissibility of any evidence in such matters and declares birth during marriage and within a specified period after dissolution as conclusive proof of legitimacy.
In the recently decided case Malik Muhammad Rafique v Tanveer Jahan,[21] the issue of paternity was not agitated by the father but by the paternal uncle. The father was not alive when the matter came up before the courts. The uncle's stake in the deceased's property motivated him to challenge the paternity of the deceased's son. The High Court declined to conduct a DNA test unequivocally. It concluded that the entire proceeding was frivolous and baseless, and dismissed it with costs. The Court founded its decision on the following three grounds: firstly, that DNA tests cannot be routinely conducted on the basis of an unsubstantiated allegation; secondly, that the petitioner had failed to produce cogent and reliable evidence that would necessitate resorting to a DNA test; and thirdly, that the requisite consent of the parties for conducting the test was not available. The Court observed that 'passing an order in routine and compelling a person to undergo a DNA test can have serious consequences, besides interference with personal liberty… Allowing an opportunity to fish for a cause to create doubts regarding the paternity of a person can neither be encouraged nor taken lightly.'
In Sarwar Mai v Judge Family Court, Muzaffargarh,[22] a petition was filed in the Lahore High Court by a woman and her son praying for a DNA test to establish their relationship with a person, who had died long ago, as his wife and son respectively. They also produced a nikahnama (marriage registration certificate) and contended that they should be declared his heirs. The relatives of the deceased initiated a suit for jactitation of marriage in a Civil Court in which it was claimed that the deceased was a lunatic, and that he did not marry the petitioner. The suit for jactitation was decreed on the basis of cogency of evidence and the decree was affirmed in appeal. Thereafter, the petitioner brought the matter before the Lahore High Court requesting a DNA test of the deceased. The Court rejected the application on the ground that the controversy had been settled by the subordinate courts on the basis of evidence other than DNA, and that there appeared to be no justification to start proceedings afresh by allowing a DNA test of the deceased.
This case is distinguishable from the cases of disputed paternity previously mentioned above. In most of those cases, the issue of paternity was raised to jeopardize legitimacy/paternity, but in this case, the request for a DNA test was made in order to establish paternity. Despite such a difference, the outcome was similar: the test was not allowed for settling paternity disputes in either way. This judicial approach has primarily been shaped by Article 128 of the QSO, which does not allow for the introduction of any piece of evidence meant to destabilize the presumptive legitimacy. In addition to the aforementioned provision, there is another hindrance in allowing a DNA test; under the adversarial system of justice prevalent in Pakistan, a party asserting a fact has to establish it by producing cogent evidence in favor of his/her claim, and the courts are reluctant to facilitate the claimant in discharging the onus of proof by ordering the test.
It would be pertinent to mention that the Supreme Court of India has taken a different stance on DNA evidence in paternity disputes. In Nandlal Wasudeo Badwaik v Lata Nandlal Badwaik & Anr, [23]the petitioner challenged the paternity of the child and argued that he could not be made responsible for the child's maintenance. The petitioner applied for a DNA test, his application was declined, and eventually the matter went to the Supreme Court. It was asserted by the respondent (mother of the child) that the petitioner had access to her during the period in which the child was conceived, and so his request for DNA test should not be allowed. The respondent argued that the notion of conclusive proof enshrined in Section 112 [24] of the Indian Evidence Act 1872 mandated the dismissal of the petition. The Court, in its landmark judgment, explained the significance of conclusive proof when it was pitched against a valuable piece of DNA evidence. The court observed:
We may remember that Section 112 of the Evidence Act was enacted at a time when the modern scientific advancement and DNA test were not even in contemplation of the Legislature. The result of DNA test is said to be scientifically accurate. Although Section 112 raises a presumption of conclusive proof on satisfaction of the conditions enumerated therein but the same is rebuttable. The presumption may afford legitimate means of arriving at an affirmative legal conclusion. While the truth or fact is known, in our opinion, there is no need or room for any presumption. Where there is evidence to the contrary, the presumption is rebuttable and must yield to proof. Interest of justice is best served by ascertaining the truth and the court should be furnished with the best available science and may not be left to base upon presumptions, unless science has no answer to the facts in issue. In our opinion, when there is a conflict between a conclusive proof envisaged under law and a proof based on scientific advancement accepted by the world community to be correct, the latter must prevail over the former.
The Supreme Court of India put its weight behind conducting DNA tests despite the fact that the legal provision dealing with paternity states that birth during a specified time would be regarded as conclusive proof. Whatever legal sanctity is enjoyed by the term 'conclusive proof', it is nevertheless a kind of presumption, and presumptions by their very nature cannot substitute facts. Thus when someone asserts before a court that proof of a particular fact lies in some scientifically valuable evidence, that evidence should be brought on record. It was this line of argument which guided the Supreme Court of India in this case.
On the one hand, this decision has raised some questions about employing the terminology of 'conclusive proof' in a legal provision when there is a possibility of piercing the sanctity of such proof. On the other hand, encouraging DNA tests in paternity disputes might open the floodgates, which would not be in consonance with protection and preservation of the basic unit of society: the family. These considerations have recently guided the Supreme Court of Pakistan in refusing DNA test in paternity disputes. In Ghazala Tehsin Zohra v Mehr Ghulam Dastagir Khan, [25] the Court pondered over DNA fingerprinting and its implications for establishing paternity in the context of Article 128 of the QSO. The paternity of two children born during a marriage was denied by their father and a request for conducting DNA test was made. Referring to Nandlal, it was argued that Indian courts have started allowing DNA tests when the legitimacy of children is contested on the ground of unchastity of one's wife. The Court observed:
The Article [128] is couched in language which is protective of societal cohesion and values of the community. This appears to be the rationale for stipulating affirmatively that a child who is born within two years after the dissolution of the marriage between his parents (the mother remaining un-married) shall constitute conclusive proof of his legitimacy.
The Court further pointed out that Muslim scholars as well as legislators of the QSO were not oblivious to the gestation period of a fetus, and even then, they extended the presumption of legitimacy up to two years, which shows 'the legislative intent as well as the societal imperative of avoiding controversy in matters of paternity.'
The Supreme Court of Pakistan has largely been guided by Article 128 of the QSO and a preference for the collective interest of society over an individual's interest in excluding DNA evidence in paternity cases. The Court also buttressed its conclusion by observing that Article 128 is founded on the traditionally recognized religious perspective. Hence, unless that religious perspective is revisited, DNA evidence will remain inadmissible in paternity disputes.
As far as the argument of preferring collective interest over an individual's interest is concerned, it may lead to another conclusion in a different set of circumstances which would become evident during our analysis in the latter half of this section. The latter half of this section analyzes the admissibility of DNA evidence in sexual offences. The judiciary's approach in dealing with sexual offences is markedly different from that in paternity disputes, but the overarching impact of the present legal framework in laying down its parameters cannot be overlooked.
2.2 Sexual Offences
Sexual offences are another stream of cases in which Pakistani courts deal with DNA evidence. The judicial approach in this respect is opposite to the one which we have noted in paternity disputes. A question that inevitably comes to mind is: why is there such a divergence? The answer to this question lies in the difference in legal frameworks governing the two streams of cases, as enshrined in the QSO. DNA evidence has become prominent because of the advancements in science and technology. Any piece of evidence which has become available by advances in science and technology is declared admissible by Article 164 of the QSO. The technician who conducts a DNA test is an expert witness, and his opinion is made admissible under Article 59 of the QSO. Moreover, there is no express provision like Article 128 of the QSO foreclosing admissibility of evidence by articulating a conclusive presumption as we have noted in paternity disputes in the previous sub-section.
The availability of an encouraging legal framework for admissibility of DNA evidence in sexual offences does not mean that it is sufficient for awarding DNA evidence its due role in investigation of crimes. This legal framework has adversely impacted DNA evidence in different ways. Treating DNA evidence as a form of expert evidence has eclipsed its significance and potential to be used as primary evidence. Expert evidence/opinion in Pakistan is regarded as corroboratory evidence, and thus cannot be treated as primary evidence. It implies that no case can be decided on the basis of expert evidence exclusively in the absence of any other primary piece of evidence, such as oral evidence. Properly collected, preserved and analyzed DNA evidence merits treatment as primary evidence in itself. During our analysis of the case law later in this sub-section, this aspect will be highlighted.
Moreover, the approach of judicial officers and investigating officials has already been settled vis-à-vis expert evidence, and that settled approach is likely to diminish the important role of DNA evidence in numerous ways. For instance, the non-availability of any expert evidence in a case due to carelessness of investigating agencies does not prompt the courts to direct them to procure it, as the courts in such a situation do not feel legally obliged to take any punitive action or play an active role to ensure the availability of expert evidence. This approach is shaped by the fact that if any particular piece of evidence is not brought before them, its unfavorable implications will have to be borne by the concerned party, and the courts in an adversarial system are not bound to go an extra mile to procure a missing piece of evidence. During our analysis of the case law, we will observe this undesirable aspect of the present legal framework.
Another by-product of this sitting-on-the-sidelines approach of the Pakistani judiciary is that we do not find other cases, such as property offences and homicide, where DNA evidence has been brought before the courts or a direction is issued by them to produce DNA evidence before them. In technologically advanced countries, DNA evidence is commonly used in the investigation of offences relating to property[26] and homicide.[27] This passive approach is partially attributable to the lack of requisite scientific resources and infrastructure.
In Muhammad Shahid Sahil v The State, [28] the petitioner was alleged to have committed rape, and as a result, the victim conceived and gave birth to a baby girl. The victim made an application for conducting a DNA test of the petitioner/accused, which was accepted by the trial court. The Court directed the petitioner/accused to appear for a DNA test in order to ascertain whether the victim's daughter was related to him or not. The petitioner/accused challenged the above order before the High Court. The latter did not find any legal infirmity in the order and confirmed it. The Court observed that once a DNA test is conducted, its report would be produced as evidence by summoning the expert who conducted the test. The accused would have an opportunity to cross-examine the expert, and that would be sufficient to grant him a fair opportunity to question the validity of the evidence. The Court said that DNA evidence was the best available evidence in this case for unearthing the truth without loss of time. The Court noted:
The prosecution agencies should take heed and use latest available technology to trace and locate the actual criminal. Under Article 164 of QSO, a court might allow to be produced any evidence available because of modern devices or techniques. Furthermore, the Holy Qur'an and Sunnah did not forbid employing scientific or analytical methods in discovering the truth. On the contrary, the discovery and investigation had been strongly recommended by both. The courts in matters relating to Offence of Zina (Enforcement of Hudood) Ordinance 1979 had all the powers to permit reception of evidence including resort to DNA test, if demanded by the occasion. It is fundamental duty of the courts to arrive at the truth without depriving an affected party to establish its point of view.
Consequently, the accused's petition was dismissed and the Court directed him and the victim along with her daughter to appear for a DNA test.
It is pertinent to point out that the above case tends to border on validating the establishment of paternity of a child conceived as a result of sexual assault through DNA evidence, though as we have seen already, this evidence is discouraged in paternity disputes. While this may seem to be the case at the outset, it would be incorrect to conflate the two situations primarily because a biological father is not treated the same way as a legal father. Under the present legal system of Pakistan, a legal father is the person who has been validly married to a child's mother to whom the child is born during a specified time after the marriage or its dissolution. [29] Moreover, the case at hand is different from the cases reproduced in the previous sub-section owing to distinguishable facts. In the earlier cases, the purpose of the litigants is to question paternity in civil litigation, particularly when the legal framework has raised a conclusive presumption in favor of legitimacy, whereas in the present case, the objective is to establish an alleged rape, a criminal offence, by linking the daughter with an alleged offender through DNA. It would appear that the present legal framework does not at least debar any kind of evidence likely to unearth the truth in such cases.
In Salman Akram Raja v Government of Punjab, [30] the Supreme Court of Pakistan made an attempt to remedy the lack of a specialized legal framework for utilization of DNA evidence. The Court directed that DNA tests be conducted in all sexual offences, and that DNA samples be preserved as well. This case was public interest litigation initiated by the Court suo moto in response to an attempted suicide by a minor victim of rape on her failure to get her complaint registered against influential offenders. Concerning DNA, the Court observed that it provided
a mean[s] of identifying perpetrators with [a] high degree of confidence… [and] by using DNA technology the courts would be in a better position to reach at a conclusion whereby the real culprit would be convicted, potential suspects would be excluded and wrongfully involved accused would be exonerated.
The Court cautioned that DNA evidence is not infallible and should not be taken as a conclusive proof. It should always be acted upon after corroboration from other pieces of evidence. This caution is appropriate and timely as sometimes people indulge in exaggerating DNA's accuracy. DNA evidence is 'largely rooted in probabilities, even a confirmed "match" does not supply concrete proof of guilt'.[31]
The Supreme Court also engaged with the issue of consent of a victim and an accused to DNA testing. It was held that the victims could not be coerced to provide a sample for DNA testing or any other medical test because it infringes upon their personal liberty. On the other hand, the consent of the accused persons is not a pre-requisite for conducting DNA tests, and their sample can be extracted without their consent because it would facilitate in ascertaining the truthfulness of allegations.
Despite the significance of this decision in highlighting the role of DNA evidence, it has not so far brought a large-scale shift among the investigating agencies in their attitudes towards the collection of DNA evidence in all sexual offences. Moreover, the decision has not specifically encouraged the use of DNA evidence in other kinds of offences such as those related to property and homicide. At any rate, DNA evidence is being received in sexual offences by courts in Pakistan, but the analysis of the cases below would demonstrate its divergent and minimalistic use, reinforcing the case for the re-evaluation of the present legal framework.
A positive DNA report has implications for an accused and it substantially reduces his chances of acquittal. In Zulfiqar Ali v The State, [32] an unmarried girl was sexually assaulted twice by her own father before marriage, but she was reluctant to report it due to family pressure and the adverse effects it would have on her marriage prospects. However, after being assaulted for the third time, she decided to report it to police by registering a First Information Report ('FIR'). The version of the victim's story was fully supported by her mother, who was aware of the abuse. Their statements were found to be convincing and were corroborated by the reports of the chemical examiner and a DNA test. The only adverse factor in the narrative presented by the prosecution was of the delay in the registration of the FIR, which was plausibly explained. In these circumstances, the Court convicted the accused of rape. In Imran alias Manoo v The State,[33] a woman was kidnapped and raped. An FIR was lodged after an unexplained delay of eight days. The medical examiner found the hymen of the victim to have been torn earlier than the alleged incident. The statement of the victim did not inspire confidence, and was insufficient in establishing the accused's guilt. In these circumstances, the Lahore High Court maintained the conviction after reducing the imprisonment awarded by the trial court on the basis of the evidence of a doctor who examined the victim and a positive DNA report. In both these cases, DNA evidence was utilized as corroboratory evidence.
Since DNA evidence can have dire consequences for the involved parties, all precautions should be taken to ensure its sanctity – procedural as well as substantive. In Shakeel Nawaz v The State,[34] the Court refused to rely on a DNA report and acquitted the accused because the test was not conducted by a laboratory notified by the government.
A positive DNA report may reduce the chances of acquittal, but a negative DNA report or non-matching of the profile does not guarantee acquittal, provided the other available evidence is convincing and reliable. This approach is reflective of treating DNA evidence as corroboratory or secondary evidence. In Khadim Hussain v The State, [35] the Federal Shariat Court maintained the conviction of an accused by a trial court, though a DNA report on the swab samples taken from the victim did not match the profile of the accused. The victim was allegedly raped by the accused and her father lodged the report of this incident. The prosecution produced, as witnesses, the father, the victim, and the doctor who examined the victim and found her to have been subjected to rape. The evidence of the doctor was found to be insufficient in identifying the accused, but the Court regarded it as corroborating the statement of the victim, which was found to be truthful and confidence inspiring. Moreover, the accused had absconded for a reasonable period of time, lending credence to the prosecution's version of the events. In view of these circumstances, the Court concluded that the mere non-matching of the DNA profile of the accused was not sufficient for acquitting him.
In another case Muhammad Ameen v The State,[36] the Lahore High Court refused to grant bail to a petitioner despite a negative DNA report, relying on the view that DNA evidence was only a secondary evidence and not primary evidence. The petitioner/accused was an imam[37] of a mosque, who was alleged to have committed zina with his student. The victim's father filed the complaint against the accused. While hearing the bail petition, the Court observed that no father would risk stigmatizing his daughter by falsely implicating someone.
When a DNA test could have been conducted but was not carried out due to negligence on the part of an investigating agency, or any other reason, the lapse has the potential to go against the prosecution and lead to the acquittal of an accused on the principle of the benefit of the doubt. In The State v Abdul Khaliq,[38] an appeal was filed against the acquittal of the accused. The victim was alleged to have been raped by four young offenders, though she did not have any marks or injury on her body. The prosecution collected semen from the victim's vagina but did not proceed to conduct DNA and group semen tests. The Court displayed its astonishment as to why the prosecution was prevented from conducting such tests and, at the same time, declined to accept the appeal against the acquittal. In Muhammad Ashfaq v The State,[39] a person accused of rape and murder was extended the benefit of the doubt and acquitted on the ground of non-procurement of DNA evidence by the relevant investigating agency for the purpose of determining whether the alleged intercourse with the deceased victim was committed only by the accused before causing her death. In both these cases, the lapse in conducting DNA tests was committed by investigating agencies, but the burden of the consequential injustice had to be borne by the victims. This is because the courts in the prevalent adversarial system of proof and evidence do not feel obliged to extend their jurisdiction for the procurement of missing pieces of evidence such as DNA evidence.
In another case, Zohra Bibi v The State,[40] a victim was allegedly detained for more than two months, and during this period, she was allegedly raped by three persons. The swabs taken from the victim's vagina were found to be stained with semen by the chemical examiner. Thereafter, the chemical examiner sent one swab for semen grouping, which the serologist found to be insufficient for the said purpose. No DNA test was carried out for establishing the involvement of the accused persons. In these circumstances, the trial court acquitted the accused persons, and in appeal before the Federal Shariat Court, the decision was maintained. The Federal Shariat Court observed that no accused should be convicted in the case of zina without semen grouping and a positive DNA report. This case appears to contradict Khadim Hussain v The State[41] discussed above. Both these cases were decided by the Federal Shariat Court, but entirely divergent positions were taken on the value of DNA evidence. This divergence is an outcome of Pakistani courts' perspective on DNA as corroboratory or secondary evidence.
As has been observed above, non-conducting of DNA test may become a ground for acquittal and such lapses of investigating agencies may also benefit an accused at the stage of bail. An accused may be granted bail in sexual offences if his DNA test has not been carried out by an investigating agency. In this situation, bail is extended to an accused under the legislatively coined ground of 'further inquiry' provided in Section 497 of the Code of Criminal Procedure 1898. [42] For instance, in Parvaiz v The State,[43] semen found on the vaginal swabs of a victim was not examined or tested for DNA. Instead of reprimanding the investigating agency, the case was treated as one of 'further inquiry' and bail was granted to the accused.
The courts' approach towards DNA as corroboratory or secondary evidence unfolds in another manner. The courts do not insist on collecting all sorts of evidence in one particular case. They receive evidence for proving a contentious issue, and if the issue is concluded as per the requisite standard without procuring DNA evidence, they may dispense with it. In other words, if the evidence available on the record of a case file establishes the guilt of an accused beyond a reasonable doubt, a court can decide such matter even without DNA evidence.
In Rashid Minhas v Muhammad Fayyaz,[44] a boy aged 13/14 years was subjected to sodomy by the accused. The victim reported the incident on the same day, disclosing all details. The report of the chemical examiner on the swab samples was positive and pointing towards the commission of the alleged offence. The medico-legal report also confirmed an act of penetration. The victim, who nominated the accused as sole culprit of the incident, was noticeably innocent and trustworthy throughout his examination-in-chief and cross-examination. The defense could not point out any flaw in his statement. On the other hand, the accused raised the pleas of alibi and enmity, but was unable to establish them. In this situation, the Court noted that the absence of semen grouping and a DNA test was not of any assistance to the accused. Consequently, the acquittal order of the trial court was converted into a conviction by the appellate court. In Mazhar v The State, [45] the non-conducting of a DNA test was held by the Federal Shariat Court not to benefit the person accused of rape because the case against him was proved beyond a reasonable doubt on the basis of convincing evidence, which comprised of statements of the victim, her father, and a doctor along with the report of a chemical examiner.
The cases analyzed in this sub-section show that DNA evidence is admissible in sexual offences as a relevant piece of evidence, but the evidentiary value it enjoys varies case-by-case. In most of the cases, it is treated as corroboratory or secondary evidence which alone cannot determine the fate of a case. The present legal framework vindicates this perspective. Despite some doubts about the absolute and unqualified credibility of DNA evidence, it can be regarded as primary evidence provided some standards, as to sample collection, its handling and testing, are set either through legislative measures or progressive legal interpretations. The questions that need to be addressed are: in what circumstances should DNA evidence be collected? How should it be preserved? In what manner can it be used in offences, and what should be its evidentiary value? If the criteria are laid down to answer these questions after a thorough debate and deliberation, there would be no difficulty in elevating DNA evidence to the status of primary evidence. The judiciary has not yet addressed these issues in a progressive manner, leaving them to be resolved by the legislature. Another major obstacle for proper reception of DNA evidence in the present judicial approach is the prevalent adversarial system. Although the complete shifting to an inquisitorial system just for the optimal utilization of DNA evidence is not advisable, calculated legislative measures can be implemented so that the lapses in utilization of DNA evidence can be penalized to bring a positive attitudinal shift in the approaches of the judiciary and the investigating agencies.
3. Conclusion
DNA has opened new vistas in forensic sciences. But whatever worth DNA evidence may promise, its use is dependent on the existing legal framework and scientific infrastructure of a country. The analysis above has exposed the fact that various legal hurdles undercut the unanimous reception of DNA evidence in all sorts of proceedings in Pakistan. On the one hand, DNA's admissibility is hindered in paternity disputes owing to a statutory conclusive presumption in the favor of legitimacy. In these cases, the courts prefer the collective interest of the community by favoring the legitimacy of an offspring over an individual's interest in unearthing the truth. According to prevalent judicial opinion, this approach is also in consonance with the Islamic dictates. This is why there is little prospect of making DNA evidence admissible in these cases. On the other hand, DNA evidence is admitted by the courts in sexual offences and is treated as a kind of expert evidence.
The utilization of DNA evidence in other offences is almost negligible in Pakistan. This approach of the judiciary is constructed partly by the present legal framework and partly by the lack of technical expertise and the requisite capacity in the crime scene analysis. If crime scenes of offences such as murder and other violent offences are examined properly, we may collect DNA evidence from those scenes, but due to a scarcity of personnel and scientific infrastructure, such valuable evidence is often lost.
DNA evidence is equated with expert evidence in the present legal framework in Pakistan which diminishes its value significantly. Due to their pre-settled notions informed and shaped from the perspective of expert evidence, the judicial officers are not willing to give more credence to DNA evidence than what they normally extend to other medical or expert evidence. As a consequence, DNA evidence has been marginalized as corroboratory or secondary evidence, and has been deprived of its potential as primary evidence. As long as DNA evidence is not freed from this reductionist perspective, it is difficult to benefit from its true potential. Thus a thorough re-evaluation of the present legal system is required in order to maximize the utilization of DNA evidence and its elevation to the status of primary evidence.
DNA evidence merits becoming primary evidence provided the possibilities of errors are eliminated by developing proper procedures at all levels including detection, collection, preservation and the manner in which DNA samples may be employed. Through well thought-out legislative measures, even within the present legal framework, an inquisitorial flavor could be added to the current judicial approach. The present approach of the courts of sitting aloof from the investigation process and dispensing justice by remaining unmoved irrespective of the non-collection of important pieces of evidence needs to be rectified. This rectification can be introduced by sensitizing the judicial officers to the significance of DNA evidence. The inculcation of a minimalist inquisitorial approach would help the courts in Pakistan to encourage the collection and the use of DNA evidence wherever circumstances allow, and any lapse committed in this regard by the investigating agencies would not go unnoticed and unpunished. This shift would prompt the investigating agencies to realize the significance of DNA evidence, which in turn would reduce the possibility of loss of a valuable source of evidence. Additionally, it is high time that Pakistan should begin to develop the requisite scientific infrastructure for the extraction and preservation of DNA evidence, failing which would result in miscarriage of justice and a lack of fair play.
* Assistant Professor, Punjab University Law College, University of the Punjab, Lahore. The author expresses his gratitude to the anonymous reviewers of the LUMS Law Journal for their valuable comments and suggestions.
[2]Peter D. Martin, Hermann Schmitter, and Peter M. Schneider, 'A Brief History of the Formation of DNA Databases in Forensic Science within Europe' (2001) 119 (2) Forensic Science International 225.
[3]Jennifer L. Doleac, 'The Effects of DNA Databases on Crime' Working Paper (01, 2012) <http://www.batten.virginia.edu/content/2013-001-effects-dna-databases-cr... accessed 10 December 2015.
[4]Hugh Whithall, 'The Forensic Use of DNA: Scientific Success Story or Ethical Minefield' (2008) 3 Biotechnology Journal 303.
[5]Margarita Guillén, María Victoria Lareu, Carmela Pestoni, Antonio Salas, and Angel Carracedo, 'Ethical-legal Problems of DNA Databases in Criminal Investigation' (2000) 26 (4) Journal of Medical Ethics 266 <http://jme.bmj.com/content/26/4/266.full> accessed 10 December 2015.
[6](2013) 133 S. Ct. 1958.
[7]Tania Simoncelli, 'Dangerous Excursions: The Case Against Expanding Forensic DNA Databases to Innocent Persons' (2006) 34 (2) The Journal of Law, Medicine & Ethics 390.
[8]Khaleda Parven, 'Forensic Use of DNA Information v Human Rights and Privacy Challenges' (2013) 17 University of Western Sydney Law Review 41.
[9]Encyclopedia Britannica 'DNA fingerprinting' <http://www.britannica.com/science/DNA-fingerprinting> accessed 10 December 2015.
[10]Article 59 of QSO: 'Opinions of experts: When the Court has to form an opinion upon a point of foreign law, or of science/or art, or as to identity of hand-writing or finger impressions, or as to authenticity and integrity of electronic documents made by or through an information system the opinions upon that point of persons specially skilled in such foreign law, science or art, or in questions as to identity of hand-writing or finger impressions or as to the functioning, specifications, programming and operations of information system, are relevant facts. Such persons are called experts....'
[11]Article 164 of QSO: 'Production of evidence that has become available because of modern devices, etc.: In such cases as the Court may consider appropriate, the Court may allow to be produced any evidence that may have become available because of modern devices or techniques.'
[12]Sikandar v The State 2006 SCMR 1786.
[13]Hamida Begum v Murad Begum PLD 1975 SC 624.
[14]Article 128 of QSO: 'Birth during marriage conclusive proof of legitimacy: (1) The fact that any person was born during the continuance of a valid marriage between his mother and any man and not earlier than the expiration of six lunar months from the date of the marriage, or within two years after its dissolution, the mother remaining unmarried, shall be conclusive proof that he is the legitimate child of that man, unless—
(a) the husband had refused, or refuses, to own the child; or
(b) the child was born after the expiration of six lunar months from the date on which the woman had accepted that the period of iddat had come to an end.
(2) Nothing contained in clause (1) shall apply to a non-Muslim if it is inconsistent with his faith.'
[15]Article 2 (9) of QSO: 'When one fact is declared by the Order [QSO] to be conclusive proof of another, the Court shall, on proof of the one fact, regard the other as proved, and shall not allow evidence to be given for the purpose of disproving it.'
[16]Article 128 of QSO.
[17]PLD 2008 Lah 302.
[18]If a husband accuses his wife of adultery, but cannot bring four witnesses to prove it, then the spouses have to go through the process prescribed in the Quran and termed as Liyan. According to this process, the spouses individually swear four times as to the truthfulness of their assertions and then during the fifth time invite curse upon them if any of them has told a lie. Thereafter, the marriage stands dissolved and if the divorced wife gives birth to a child, he/she will not be attributed to the husband.
[20]PLD 2010 Lah 422.
[21]PLD 2015 Isl 30.
[22]2010 YLR 1234 (Lah).
[23]2014 (5) CTC 680 <http://indiankanoon.org/doc/139951018/> accessed 15 November 2015.
[24]Section 112: 'Birth during marriage, conclusive proof of legitimacy.–The fact that any person was born during the continuance of a valid marriage between his mother and any man, or within two hundred and eighty days after its dissolution, the mother remaining unmarried, shall be conclusive proof that he is the legitimate son of that man, unless it can be shown that the parties to the marriage had no access to each other at any time when he could have been begotten.'
[26]Michael Briody, 'The Effects of DNA Evidence on Property Offences in Court' (2005-2006) 17 (3) Current Issues Criminal Justice 380.
[27]Michael Briody, 'The Effects of DNA Evidence on Homicide Cases in Court' (2004) 37 (2) Australian & New Zealand Journal of Criminology 231.
[29]See Article 128 of QSO.
[31]Karen Norrgard 'Forensics, DNA fingerprinting, and CODIS' (2008) 1 (1) Nature Education 35 <http://www.nature.com/scitable/topicpage/forensics-dna-fingerprinting-an... accessed 10 December 2015.
[33]2013 MLD 1790 (Lah).
[34]PLD 2013 Pesh 78.
[35]2011 PCrLJ 1443 (FSC).
[36]2013 PCrLJ 733 (Lah).
[37]A person who leads prayers in a Muslim mosque.
[39]2014 PCrLJ 1531 (Lah).
[40]2013 PCrLJ 772 (FSC).
[41]2011 PCrLJ 1443 (FSC).
[42]The phrase 'further inquiry' is not defined anywhere conclusively and it allows the courts an ample space for using discretionary powers in bail petitions. It is interesting to observe that no draftsman of the Criminal Procedure Code would have contemplated that the terminology of 'further inquiry' would be used in this manner.
[43]2014 PCrLJ 599 (Lah).
[44]2012 PCrLJ 816 (FSC).


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If you imagined spending your retirement like Smaug the dragon, sitting atop a pile of gold (by which we mean retirement savings), think again. The IRS wants you to start taking money out of your retirement accounts beginning around age 70.5. This money goes by the name required minimum distributions (RMDs). Want to learn more? You're in the right place.
Check out our retirement calculator.
The following kinds of retirement accounts all come with required minimum distributions:
- SEP-IRAs
- SIMPLE IRAs
- Traditional IRAs
- 401(k)s
- 403(b)s
- 457(b)s
- Profit-sharing plans
- Other defined contribution plans
For IRAs, SEP-IRAs and SIMPLE IRAs, the date for beginning required minimum distributions is April 1 of the year following the calendar year in which you turn 70.5. For 401(k)s, profit-sharing agreements, 403(b)s and other defined contribution plans, the beginning date for RMDs is usually April 1 after the later of either a) the year you turn 70.5 or b) the year you retire.
Why Are There Required Minimum Distributions?
You may be wondering why the IRS doesn't let you wait as long as you want to take distributions. Here's why: The above account types all offer tax-deferment. With these accounts you can make tax-deductible contributions and enjoy tax-deferred growth. From the time you first open, say, a traditional IRA, to the time you turn 70.5, the IRS is getting nothing out of your IRA savings.
You didn't expect the Tax Man to defer your taxes indefinitely, did you? That's why the IRS imposes required minimum distributions. Without RMDs, people could use tax-deferred retirement accounts to stash their money indefinitely and never pay taxes on the funds. In exchange for letting you deduct your contributions to tax-deferred accounts, the IRS wants to make sure that it gets its share when you're in your golden years.
Why Don't Roth IRAs Have RMDs?
Because Roth IRAs (and Roth 401(k)s) are funded with after-tax dollars, the IRS has already gotten a cut. Roth accounts are great because you don't pay taxes on the money you take out of them in retirement, and you're not required to dip into them if you don't need to. Some strategic folks choose to diversify their tax burden in retirement by having a mix of Roth and non-Roth accounts.
How Are Required Minimum Distributions Calculated?
Great question. To calculate this year's RMD, take the account balance at the end of the previous calendar year and divide it by the distribution period you find on the IRS's Uniform Life Table. The "distribution period" is pretty much a nice way of saying, "the number of years you have left."
Of course, because it's the IRS, there are exceptions that complicate things. If someone is the sole beneficiary of a deceased's retirement account, and that someone is the spouse of the deceased, and that spouse is 10+ years younger than the deceased, a separate life expectancy table is used to calculate RMDs. This is called the Joint Life and Last Survivor Expectancy Table. Other beneficiaries who need to calculate RMDs use the Single Life Table.
Do Inherited Accounts Have RMDs?
Yup. If you inherit one of the retirement accounts listed above (or even a Roth IRA), you will have to take RMDs. The rules on these distributions depend on whether you're the spouse of the deceased or another, non-spouse beneficiary.
If you're the spouse and sole beneficiary of the retirement account, you have several options. You can treat the inherited retirement account as yours and roll it over into a retirement account of your own, base RMDs on your age, base RMDs on your late spouse's age at death and reduce the distribution period by 1 year annually or withdraw the entire amount by the end of the fifth year after retirement, provided your spouse died before the age at which he/she should have taken RMDs. If your spouse died before reaching the age for RMDs, you can wait until he or she would have reached age 70.5 to start taking distributions.
The rules for beneficiaries who aren't spouses are different. If the account owner died before the beginning date for RMDs, you can pocket the entire account balance by the end of the fifth year after the account owner's death. Alternatively, you can calculate required minimum distributions based on the Single Life Expectancy Table.
Bottom Line
Do required minimum distributions sound too complicated? Are you considering taking your chances, skipping the RMDs and hoping the IRS doesn't notice? Not a good idea. If you skip taking distributions, or if you take distributions that are too small, you'll pay for it. To be specific, you will owe the IRS a 50% excise tax on the sum you should have taken in distributions. This applies to beneficiaries as well, so add "start taking RMDs" to the list of things you have to do when you inherit.
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Photo credit: flickr


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This Week's Top Promotional Products Trends –
June 3, 2020
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In working with our customers, our sales team noticed a quantifiable shift in the types of sanitizers we are selling. We unquestionably saw an increase in the sale of pocket-size sanitizers, UV sanitizers, and sanitizer stations.
Convenience is king in our society. We, as a country, are continually looking for the next product that can save us time. In the business world, saving time often also means saving money. That's why it is not a surprise that we have had such a large demand for our imprinted pocket-size sanitizers. Last week our Sani-Spray Pen was our best-selling item. These sanitizers are designed to fit into pockets or can easily be clipped to clothing, with the provided lanyard hook, for easy access. Customers consistently rate this product with 5-stars, noting how easy they are to use. Another excellent option for on-the-go sanitizing is our Clear Sanitizer with Carabiner. This new item allows users to keep their sanitizer close-at-hand. We had two customers last week, one in the restaurant industry and the other in finance, tell us that they were buying these as a way to simplify their sanitization practices. Both planned on providing personal sanitizers to their workforce as a way to save time, as they will no longer need to be running back and forth to a communal sanitizer bottle. For companies looking for slightly more sanitizer per product, we are recommending the 4oz Gel Sanitizer Bottle. Several delivery centric businesses have purchased these for drivers to keep in their trucks and sanitize after each delivery. As an extra benefit, most of the sanitizer bottles are refillable. The 1 Gallon Gel Hand Sanitizer is a smart add on to any sanitizer order as a way to refill bottles.
Cell phones are crawling with bacteria, 25,127 bacteria per square inch, to be precise, according to State Food Safety, a leader in restaurant and hospitality food safety. The next three most bacteria-infected objects are doorknobs, checkout screens, and counters. These levels of bacteria are why we're seeing more customers add UV Sanitizers to their sanitation arsenal. This method of using light as a means of cleansing is an efficient way to sanitize the most often touched surfaces and possessions that works in minutes. UV Light Sterilizing Wands kill germs in seconds on high traffic surface areas like doorknobs, keyboards, checkout screens, and desk phones. For smaller, yet still exposed items, we recommend the Phonesoap® UV Cleaner and Charger. These cases sanitize cell phones in minutes and can also cleanse watches, rings, keys, credit cards, and ID badges. For companies looking for a product to disinfect larger items such as tablets and small computers, we recommend the UV Tech Sanitizer & Charger. Bonus both the Phonesoap and Tech sanitizers double as phone chargers.
Placing sanitizer stations in high-traffic areas is an effective way to combat the spread of germs. They work great in entryways, hallways, near bathrooms, common areas, and breakrooms as a touch-free means to hand cleansing. One customer last week bought a few of the Bannitizer® Sanitizer Stations for the walkways in the lobby of the building where his office is. He noted it was a great way to promote his business and further associate his brand with a commitment to health and wellness. He also stated that he plans to use them at tradeshows when those types of events start to happen again. We also sold a few of our smaller Sanitizer Stations to car dealerships, daycare centers, and real estate agencies. Unlike most products in the promotional products industry, all the Bank Express sanitizer station options have low quantity minimums, 1 to 6.
There are so many sanitizer options to choose from; it can get confusing knowing what the right choice is. If you're looking to understand all the differences and make the best decision for your business, check out our Custom Hand Sanitizers Guide. If you need additional help or want to talk to one of our sales representatives, give us a call, 866-488-4975, we are here and happy to help steer you in the right direction.
Employee Review of the Week:
"I would say I use the Sani-Spray Pen more than any other product. I practically have one on me at all times. I keep at least one in my purse, one clipped to my gym bag, one in my glove compartment, and several in my desk drawer. It just makes me feel better knowing I can clean my hands whenever I want. And I love the smell of the citrus breeze pens." – Tabatha White, Account Manager


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6 Design Ideas for a Festive, Sun-Drenched White Christmas
With these design tips, bring the white Christmas inside this year.
Do you dream of having a white Christmas but live in a climate that's too warm for snow? There's no reason you can't embrace your own style. The traditional red and green combination can look out of place when it's hot outside. But by using fresh white pieces, keeping decorations to a minimum and sticking with a limited color palette, you can cool things down for a fresh and chic white Christmas.
Use Lots of White
There is nothing like an abundance of cool, crisp whites to help bring the temperature down, and this principle can apply to your Christmas decorating, too. It is best to include as much white as possible for a warm-weather white-Christmas theme. Use white objects with varying textures to maintain interest and avoid monotony. White wood, fabric, marble, clay ornaments and candles all have surfaces that help break up the repetition of white. A crisp white tablecloth is the perfect base for this Christmas table setting. White napkins, vases, flowers and dishware all work beautifully together here, and the varying textures provide points of difference between the many white pieces. The rustic burlap table runner adds some softness to the table and just a touch of warmth, saving the scene from feeling sterile.
Restrict Your Color Palette
Limit your color palette to white and natural tones, with accents of silver and glass. Focusing on neutral tones doesn't have to be boring — as long as you include a variety of shapes and textures, the look will always be interesting. A good mix of textures will add depth and fullness to your Christmas decor.
For this simple, minimalist style, a variety of textures can mean the difference between a stylish, cool interior and one that is boring and without feeling.
Photo Credit: The Happy Home Blog, original photo on Houzz
These glasses and jars have been adorned with silver glitter and suit the white tablecloth elegantly, setting the scene for a crisp, white holiday celebration. Accents of silver work well because they add an icy look, which makes us feel cooler even when the weather is warm. Crystal glasses and goblets would create a similar effect. Despite the lack of color in this scene, the table is cheery and obviously set for a celebration.
Photo Credit: The Happy Home Blog, original photo on Houzz
Keep Things Minimalist
The less-is-more approach is definitely fitting for this style of Christmas decorating. This room proves that Christmas styling can be muted and restricted while maintaining that festive feel. The wreath on the wall is made from vintage book pages and looks gorgeous against this clean, white wall.
Try to limit the amount of ornaments on your tree, and if you want to include red in your minimalist style, make sure it is a muted tone, so as not to clash with any neutral shades.
Be selective when choosing your decorations and only include pieces that are simple and fit the brief. Achieving a minimalist style is often perceived as the easy option, but because you are including fewer objects, it will be more obvious if something doesn't suit the theme. If a single item is out of place, it is likely that the whole room will look and feel disrupted, so choose carefully and if you're not sure, pack it away.
Photo Credit: Louise de Miranda, original photo on Houzz
Focus on Christmas Shapes
There is minimal color in this style of Christmas decorating, so bring in the holiday cheer with shapes that represent Christmas. Stars, trees, reindeer and angel shapes all give an impression of Christmas, even in neutral tones.
We get a sense that the natural-colored reindeer and handmade stick star are Christmas themed, even without the traditional red and green combination. The white lights add a coolness to the scene and make us think of a celebration, despite the lack of color.
Photo Credit: RedAgape Blog, original photo on Houzz
Match Your Wrapping
Those who like things neat will probably prefer Christmas wrapping that ties in with their theme. For this cool, white Christmas theme, use plain white paper and embellish gifts with objects in colors that match the palette. You can include items like sticks and rosemary from the garden, which will not only save you money but will help save the earth. These gifts have been tied up with natural jute string and embellished with white clay tags.
Include Objects From Nature
Use sticks, wood, rocks and other found objects in your Christmas decorating, and you will create a down-to-earth atmosphere that helps guests feel relaxed and calm. Finding objects from your own backyard will add a distinctly homey feel to your celebration.
Photo Credit: RedAgape Blog, original photo on Houzz
A Christmas tree made from sticks is the perfect alternative to a store-bought fake green tree. It is not only a more environmentally ethical way of decorating, but the handmade imperfections simply add to its charm. A natural pine would have worked beautifully in this setting as well. Most objects we find in nature will blend with this white-Christmas theme, because their colors and textures bring a sense of peace that we often find in natural settings.
This article originally published on Houzz.
Related articles:
How to Decorate With Nature This Season
Find Fabric for a DIY Table Runner
Dress Up a Bar Table Natural Decor


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|About GearUGalore
GearUGalore is a virtual fashion
styling center that offers our clients
the 'hands-on' experience of a
fashion stylist right at their
GearUGalore's mission is to readily
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e.Logical Restore
May 27th, 2011No Comments
Restore – Calcium and Lime Remover
Concentrated multi-purpose acidic descaler. Safely and effectively removes calcium, lime and other hard water deposits. Use in food service, housekeeping and industrial applications. Strips hard water deposits from a variety of surfaces. No harsh fumes. Recognized for Safer Chemistry through registration in the EPA Design for the Environment (DfE) Program.
APPLICATIONS INCLUDE: Dishmachine Descaling, Steam Tables, Urns, Pots/Pans, Restoration of Glassware, Bathroom Fixtures, Sinks, Tubs and Showers.
FOR USE IN: Restaurants, Schools, Institutions, Hotels, Motels, C-Stores, Supermarkets and Commercial Cleaning.


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Google does keep cookie- and IP-correlated logs
I asked John Battelle the question about whether Google keeps personally identifiable search log information, particularly search logs correlated with IP address. He asked Google PR, who confirmed that they do.
From my comment there, ultimately, this is bad for users. If the information is kept, it's available for request, abuse, or theft.
Tags: Google, privacy, logs, retention, tracking, personal data, search


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Wriston: Walter Wriston, Citibank, and the Rise and Fall of American Financial Supremacy
By Phillip L. Zweig
Crown Publishers, 1996, 952 pp.
Banking is regarded by many as a dull activity run by dull people, but both come alive in this biography of Walter Wriston, CEO of Citicorp for 17 years from 1967 to 1984. His tenure covered major world economic events -- the cessation of the dollar's gold convertibility, the move to floating exchange rates, two large oil price increases and the accompanying inflation and recession that were dubbed stagflation, and the most serious international debt crisis since the 1930s. Wriston was involved in all of them, both as chief of the country's most internationally engaged bank and as counselor to sundry presidents, secretaries of state and treasury, and Federal Reserve chairmen. In a highly regulated industry, Wriston was a vigorous advocate of free markets. He was not always popular with the regulators, nor with other bankers, but during his tenure Citibank pioneered several financial market innovations, such as negotiable certificates of deposit and floating-rate notes in the U.S. market. This hefty, well-written volume also covers the post-Wriston legacy of Citicorp, including the real estate problems of the early 1990s, and offers a general commentary on world financial history since the 1950s from the perspective of one of the world's leading and most outspoken bankers.


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Ghazni gŭz´nē [key], city (1981 est. pop. 31,200), capital of Ghazni prov., E central Afghanistan, on the Ghazni River. Located on the Kabul-Kandahar trade route, Ghazni is a market for sheep, wool, camel hair cloth, corn, and fruit. The famed Afghan sheepskin coats are made in the city. Most of the inhabitants are Tajiks. The city, named Ghazna in ancient times, was flourishing by the 7th cent. but reached its peak (962–c.1155) under the Turkish Ghaznavid dynasty. Mahmud of Ghazna built a magnificent mosque, the Celestial Bride, there. The kings of Ghor sacked Ghazni in 1149 but later (1173) made it their secondary capital. Ogotai, a son of Jenghiz Khan, completed its downfall in 1221; Mahmud's tomb and two high columns outside the city escaped destruction. In 1747 the city became part of the new kingdom of Afghanistan. Ghazni's strong fortress was taken by the British in 1839 and 1842 during the Afghan Wars. The main city on the Kabul-Kandahar highway, it became a strategic military target during the Afghanistan War. The walled, old city of Ghazni, with its numerous bazaars, contains the ruins of ancient Ghazna.
The Columbia Electronic Encyclopedia, 6th ed. Copyright © 2022, Columbia University Press. All rights reserved.
See more Encyclopedia articles on: Afghanistan Political Geography


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Why Busy Moms Should Not Forego Regular Exercise
Full-time moms find themselves on their feet most of the time, whilst burning calories at levels higher than what they burn when taking an early morning run. Yet engaging in regular exercise is more than just about burning calories, it's also about feeling good and maintaining a positive outlook. House chores and being in the […]Read More »


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Turn Your Spring Cleaning into Cash
This post may contain affiliate links for your convenience. Read my full disclosure policy here.
My sister is back sharing her favorite ways to turn a spring decluttering spree into cash. There's a thrill in getting rid of your old, unwanted items and using that money toward something you'll love. Or putting it towards a goal such as a vacation, special activity, or a hot new pair of jeans. Or the bills. Whatever your needs, here's how you can sell your old stuff to earn money for goals of your own!
{original image via freedigitalphotos.net}
I don't really do a spring cleaning, but I do get an urge to purge each spring and fall. So, although I'm not scrubbing from ceiling to floor, I am scouring for clutter and sweeping it into a box. Having moved 7 times in a decade, paring down our stuff translates into savings when it comes time to move. But over the years, I have found ways to earn a few bucks while unstuffing my home. Here are some of my favorites:
Yard Sale: A yard sale is the most obvious answer for stuff you don't want, and you can sell virtually anything at a yard sale. At my last yard sale, I sold kitchen items, an air conditioner, baby gear, and even items that I picked up while strategically saving with coupons because the store basically paid me to buy them. A yard sale is one of the easiest ways to get rid of stuff that is cluttering your house. Just the act of setting up your yard sale gets unwanted stuff physically out of your house. If you don't sell the item it's much closer to the car that will drive it to the donation dropoff. There are also organizations that will pick up your items for you — set up a pickup for noon, and your yard sale will be cleaned up by naptime! The downside to a yard sale is that you won't get top dollar for your stuff. But if you keep your de-cluttering goal in mind, you come out ahead no matter how much you earn that day.
If you don't have enough for a full yard sale, pair up with friends or have a neighborhood yard sale. That's what I did last year and the cluster of yard sales increased foot traffic and the amount we sold.
Online Yard Sale: Generally, you will be able to get a better price for your item online than you will at a sale in your actual yard, but it will be more work and it will take longer for the item to leave the building. You should provide a high quality photo and a thorough description of the item, and you should answer emails from potential buyers promptly. How do you decide whether to list your item on Craigslist or eBay? It depends on the item and your goals. There are pros and cons to each:
- Craigslist has free postings, you can accept cash in person, and is good for bulky items that are expensive to ship. But the cons are you'll need to make time to meet with potential buyers, and some might stand you up. It can take time to weed through emails and requests, too.
- eBay has a national audience and payments are done online. The cons are that eBay charges for posting over 3 items each month; PayPal charges a percentage of the sales price; if you auction the item, you will have to wait until the auction is over; and you should be prepared to mail the item promptly (plus, all the hassle involved with packing and shipping items can be a headache).
In addition to these two heavy hitters, the newest way to get rid of items online is to post them to a Facebook page dedicated to local yard sales. When you advertise your sale or post individual items on the Facebook page, it will go into the newsfeed for everyone who has "liked" the page. Find one near you by searching Facebook with "Yard sale _____" provide your neighborhood, town, city, region, or state.
Books, DVDs, Videogames: Local used book stores and even stores like Best Buy and GameStop offer buyback programs for books, DVDs and videogames. But if you want to be sure to get the best price for your used book, I highly recommend using the app Bookscouter. You scan the book's ISBN and Bookscouter will list the amount the popular book buyback sites will pay you for the book. It took me about 30 seconds per book to determine whether the book could be sold online or whether I should toss it in the donation box. There were three companies who consistently gave me the biggest quotes, so I made one pile for each of them. I sold books to Powels (www.powells.com), Sell Back Your Book (www.sellbackyourbook.com), and CKY Books (www.ckybooks.com). Each bookbuyer provided a pre-paid shipping label, so shipping was free. Although I did have to follow up with one buyer who mysteriously lost my package until I spoke with a supervisor, the process was worth the cash in the end. I also sold a video game to Amazon, and the process was similarly easy and worthwhile.
Another resource for books is Paperback Swap. You enter the ISBNs of all the books you are willing to part with, and they are posted for any member to request. Once a book is requested, Paperback Swap provides you with a mailing label and you mail the book at your expense. Once the book is received, you earn a credit that you can then use to request a book. Your address is only displayed when you print a label to send someone a book, or when someone prints a label to send you a book. Even then, it does not reveal your full name. When choosing which books to post, I recommend that you avoid posting heavy books because they will cost more to ship.
Broken Items: Broken items are extremely unlikely to make you any money anywhere, but there are manufacturers out there who stand by their product and will replace items that have broken long before their life expectancy. If you have one of those items and dread replacing it, try contacting the manufacturer to see what can be done. You never know until you try!
When my $70 humidifier broke after only one year of use, I was really bummed about shelling out the cash to replace it, and wondering how long the next humidifier would last. When I contacted the manufacturer, they asked for a copy of my receipt and the exact product numbers on the humidifier. I didn't have a receipt, but they mailed me a replacement anyway. With this success in mind, I then contacted two more manufacturers — one product had arrived broken and one product was damaged after 5 years of normal use — and each one replaced the damaged part. A friend of mine spilled coffee on her Kindle, and Amazon gave her a discount on a new one even though the malfunction was clearly not their fault.
Appliances: Last year, our deep freezer broke. Disposing of it was not only a hassle, but was going to cost us money. Then we discovered an appliance rebate program that disposed of the freezer properly and paid us $50. It is a state-sponsored program that operates through our utility company. If you have an appliance that's lost its utility in your home, Google "appliance rebate in _____" your state and see what pops up — you might have one too. Getting some cash for your old, unwanted appliances takes the sting out of buying a new one.
Adult Clothing: If you are interested in consigning your clothes, check out these national chains to see if there is one near you: Clothes Mentor, Plato's Closet, and Buffalo Exchange. There may be local ones as well. It takes time to get them ready for consigning, but it's worth a shot for good clothing that no longer fits you or your style.
Baby Gear and Clothing: The traditional consignment shops still exist for these items, but the big trend now are the semi-annual consignment sales. They attract a bigger audience in a shorter amount of time, so you get immediate gratification after all of your hard work cleaning, tagging, and dropping them off. Check out Consignment Mommies to find local sales in your area. Before you decide to consign, you may want to go to the sale to see the quality of the merchandise, the pricing, and the volume of shoppers. The other information you should compare before choosing a sale is: (1) the administration fee, (2) the percentage of the sale price that is given to the consignor, (3) whether volunteering at the sale will increase your percentage, and, although not related to how much you will make, it is a benefit (4) whether consigning will get you admission to the pre-sale. If you get in to the pre-sale, you will have first dibs on the highest quality items for the best price. Here's a post Carrie wrote last year with inside tips on how to make BIG BUCKS consigning at kids consignment sales.
Household items: Carrie also recently posted about a new trend, home goods consignment sales. This is a brilliant concept to me. Google to see if there is one in your area. If there isn't, start one yourself (and be sure to invite us all!)
Did any of these suggestions inspire you to get out that box in the basement that has been nagging at you? Do you have any favorite methods of turning clutter into cash?