The first Provisional Constitutional Order (PCO) was declared on March 24, 1981, by then-President and Chief of Army Staff General Muhammad Zia-ul-Haq.
[3] Under this new order, the senior justices of the Supreme Court of Pakistan were asked to take an oath of office under the provisions set by the PCO.
[4] Senior Justices Hussain and Haq had previously approved Zulfikar Ali Bhutto's hanging and were reportedly restrained from taking the oath under the secretive directives issued by President Zia.
[4] In the wake of political tensions arising after the border incidents with India that nearly pushed the two countries to the brink of war, Chairman Joint Chiefs of Staff Committee and Chief of Army Staff General Pervez Musharraf imposed martial law against the government of Prime Minister Nawaz Sharif on October 12, 1999.
Nearly all senior justices were required to take an oath of office under this new order, and concerns were raised that this would "erode the independence of the judiciary".