What really happens when the trust one places in another becomes leverage, intimacy becomes a dagger pressed against the chest, and love takes the form of an evidence? When, without consent, intimate images, perhaps once shared in a moment of euphoria, vulnerability, or misplaced trust, are disseminated, this is where a private moment gets transformed into a public weapon and leaves victims to confront not just the anguish of personal betrayal, but the mercy of a far more consequential question: can the law itself meaningfully protect victims when the person entrusted with their intimacy becomes the one who weaponizes it against them?
In 2017, a 22-year-old student, whose name was Naila Rind, got away with her life permanently at the University of Sindh, Jamshoro, after being blackmailed by her ex-partner with intimate photographs they had once exchanged in sheer confidence. In Okara, a mother of four gulped down the poison after her relatives forged explicit images from standard photographs and circulated these on WhatsApp. She did so months after she had already filed a complaint with the FIA’s cybercrime wing. As recently as December 2025, a Pakistani woman was targeted through a deepfake pornography campaign, and Dawn reported this. After she reported the matter to the authorities, the lead investigator was transferred while the investigation was still ongoing. The investigation eventually, and apparently, lost momentum because of that disruption. This forced the campaign to migrate abroad, where it continued unchecked and made it occult for Pakistani authorities to investigate.
These are not isolated tragedies. These are actually symptoms of a system that criminalizes non-consensual intimate image distribution (NCII) fairly seriously, but, in actuality, it repeatedly fails the people it exists to protect. This article is meant to examine what remedies for it exist under Pakistani law, where these fall short, and what would be the requirement of a functioning response.
The Statutory Framework
The NCII cases in Pakistan are being dealt with primarily by the Prevention of Electronic Crimes Act, 2016 (PECA). Section 19 of the said Act, titled “Offences against modesty of a natural person and Minor,” criminalizes intentional and public exhibition, display, or transmission of information that superimposes a person’s face into sexually explicit content, includes an actual photograph or video of a person in a sexually explicit conduct, intimidates someone with such material, or entices or induces someone to engage in a sexually explicit act to:
- harm a natural person or his reputation; or
- take revenge; or
- create hatred or to blackmail
Most importantly, section 21 (1)(a) of the said Act, covering superimposed images, already extends to deepfakes, meaning thereby that Pakistan’s law was, at least on this narrow point, ahead of the curve well before AI-generated intimate imagery arose as a global concern.
The penalties, including imprisonment of up to five, seven, or even ten years, and a fine of up to five million rupees, are meaningful on paper. Offences outlined under Section 21 are non-bailable, non-compoundable, and cognizable, meaning that police can arrest without a warrant, and the case cannot simply be settled between families and withdrawn, at least theoretically. Section 21 also enables a victim, or a minor’s guardian, to directly petition the Pakistan Telecommunication Authority for removal or blocking of the offending content, without even waiting for conclusion of a criminal trial.
In addition to section 21, there are other provisions which may be invoked at the same time:
- Section 24 of the said Act that criminalizes cyberstalking.
- Section 20 of the said Act that covers offenses against dignity where false information is used to intimidate or harm reputation.
Moreover, if money is also demanded by the perpetrator under the threat of disclosure, the most common pattern followed in Pakistani NCII cases is the concurrent application of the below-mentioned provisions of the Pakistan Penal Code, 1860:
- Section 386 that deals with extortion by putting a person in fear of death or grievous hurt.
- Section 506 that deals with criminal intimidation.
This gives prosecutors several overlapping charges to work with.
From Legal Promise to Practical Failure:
The recurring gap in Pakistan’s response to non-consensual intimate image distribution cases is not mainly statutory; rather, it is institutional. A legal right is meaningful only when institutional mechanisms can reliably enforce it. Three institutional weaknesses recur across a substantial number of documented cases.
The first weakness is a poor investigative continuity, where most cases lose their momentum either because investigators are transferred or because they are unresponsive.
In the Okara case, an investigator was assigned by the FIA after the victim got her complaint filed, but the accused kept blackmailing her. It was reported by Dawn that a woman inspector was assigned the case, but the victim’s family claimed that the investigation agency did not protect her. Eventually, she died by suicide months later. In the 2025 deepfake case of Mona Alam, the leading officer was transferred mid-case, with the complainant expressing concern that she was being personally rebuffed after raising the matter with the Interior Minister. When enforcement is based more on which officer happens to be assigned, and survives only for the period the officer stays in post, then guarantees of law become a matter of chance rather than right.
The second is associated with informal settlements: formal prosecution is being routinely replaced by the informal resolutions undertaken by families. In several reported cases, family elders stepped in to negotiate private settlements through compensation and apologies in lieu of the criminal complaint. What happens afterwards is that the accused violates these informal agreements once the case goes cold with the FIA. Section 21 offences are legally non-compoundable, and the aforementioned settlements have no formal standing to close a case. On the contrary, in practice, the very protection the non-compoundable category was meant to provide has been undermined because victims are frequently pressured to ask the FIA to close the matter. The same happened in the Okara case.
Thirdly, much of the practical burden of obtaining redressal lies with survivors. They may be required to preserve links, messages, screenshots, account details, and other available evidence. They are also expected to report abuse, navigate a system that is not trusted by many women, and seek removal from platforms where the content may reappear through new accounts. The Digital Rights Foundation documents how reporting gets deterred by fear of family and social repercussions, victim blaming, and even the idea of prolonged, traumatic proceedings. It also notes that PECA empowers the FIA to seize devices and access data, which is an intrusive prospect itself to discourage survivors from approaching the authorities. They are not always staffed and trained in handling intimate imagery cases with sensitivity. In June 2020, during the pandemic, the Digital Rights Foundation reported an increase of 189% in complaints to its cyber-harassment helpline. Mostly, these were based on blackmailing through non-consensual sharing of intimate images, videos, or information, and women made 74% of these complaints. The FIA’s capacity is not measured merely through these figures, but these express an acute need for survivor-centered investigation, take-down support, evidence handling, and legal aid.
The UK’s Consent-First Model
A useful comparison is provided by the UK because of its consent-first approach to non-consensual intimate image sharing. It places emphasis on whether the victim consented, rather than majorly on the perpetrator’s motive. A tiered offence structure was created through the Online Safety Act 2023, and this imposed platform-level duties to address intimate-image abuse proactively. However, Pakistan’s section 21 of the PECA requires additional proof of intention, such as harming reputation, creating hatred, blackmailing the victim, or taking revenge. This is how prosecution becomes potentially more difficult because the perpetrator’s motive establishment is required. Additionally, Pakistan lacks comparable proactive platform-removal obligations. Consequently, the victims largely become responsible for reporting and pursuing removal of the content themselves.
From Paper Rights to Real Protection
To prosecute non-consensual intimate image distribution (NCII), Pakistan does not lack legal tools, and section 21 of PECA has already provided a serious offense with serious penalties. The real problem is the gap that exists between the law’s promise and its practical delivery. Reform should focus on three main areas rather than another round of statutory amendments: (i) Institutional continuity in investigations and responsiveness where the cases would be assigned to units rather than individual officers. (ii) A consent-based evidentiary standard that makes non-consensual sharing the pivotal question rather than making the perpetrator’s specific motive more significant. (iii) Formal platform obligations requiring verified NCII to be removed within a specified timeframe.
References
The Prevention of Electronic Crimes Act, 2016.
Chaudhry, A. (2022, October 3). Woman commits suicide in Okara after ‘relatives’ share doctored images. Dawn. https://www.dawn.com/news/1713205
Punjab Commission on the Status of Women. Prevention of Electronic Crimes Act, 2016. https://pcsw.punjab.gov.pk/prevention-of-electronic-crimes-act-2016
Haider, S. B. (2025, December 10). From fake profiles to deepfake porn: The war Pakistani women cannot win alone. Dawn. https://www.dawn.com/news/1959376
Gondal, S. R. (2020, August 28). Stolen images and violations of privacy: How women in Pakistan navigate digital spaces. Digital Rights Monitor. https://digitalrightsmonitor.pk/stolen-images-and-violations-of-privacy/
Digital Rights Foundation. (2025, September 25). Probing attacks on journalists: Investigative analysis of PECA’s post-amendment 2025 cases. Digital Rights Foundation
Wiggin LLP. (2024, September 23). Online Safety Act: Sharing intimate images without consent to be made a priority offence. Wiggin LLP
Domestic Abuse Education. (2025). Sharing images without consent UK: Your legal rights explained (2025 guide). Domestic Abuse Education
