Gray Zone Constitutionalism and the Dilemma of Judicial Independence in Pakistan

Many countries exist in a gray zone between authoritarianism and democracy. For countries in this conceptual space--which is particularly relevant today given the halting path of change in the Arab world--scholars, judges, and rule of law activists conventionally urge an abstract notion of\u27 judicial independence as a prerequisite for successful democratic transition. Only recently, for example, Pakistan\u27s judiciary was widely lauded for its independence in challenging the military regime. However, judicial independence is neither an all-or-nothing concept nor an end in itself. With the return of civilian rule in Pakistan, a series of clashes between Parliament and the Supreme Court has raised concern that the same judiciary celebrated for challenging the military regime--while invoking exactly the same abstract notion of judicial independence--might now be asserting autonomy from weak civilian institutions in a manner that undermines Pakistan\u27s fragile efforts to consolidate democracy and constitutionalism. In this Article, I challenge the conventional view by examining these recent developments in Pakistan, which are instructive for other countries in this gray zone. Over many decades, as Pakistan has cycled between military and weak civilian rule, the military and its affiliated interests have entrenched their power, and the judiciary has played a central role in facilitating that process. The result has been an enduring institutional imbalance that has undermined Pakistan\u27s weak representative institutions. This process of entrenchment has never gone entirely unchallenged, and Pakistan\u27s current shift to civilian rule offers genuine potential for the long-term consolidation of democracy and constitutionalism. But this persistent institutional imbalance and continued military dominance remains a significant obstacle to fully realizing that potential. Accordingly, I urge an understanding of judicial independence that goes beyond abstract, unqualified notions of judicial autonomy and instead contemplates an appropriate balance between autonomy and constraint--one that not only enables representative institutions to strengthen their governance capacities and power to rein in the military, but also enhances mechanisms of judicial accountability to reinforce the democratic legitimacy of the judiciary\u27s role. Pakistan\u27s experience also has broader significance, suggesting lessons--or at least notes of caution--about the relationship between entrenched status quo interests and an independent judiciary in other countries, such as Egypt, that risk languishing in the gray zone between authoritarianism and democracy but seek a more complete shift to democracy

Primary Ovarian Pregnancy - A Rare Case Report

We report the rare case of a 27-year-old female who presented to the emergency department with severe pain in the lower abdomen. She gave a history of a spontaneus pregnancy of 5 weeks gestation with a history of irregular spotting on and off. The total leukocyte count was 25,000/cmm and β-human chorionic gonadotropin level was 984.7 IU/mL. Ultrasound showed an adnexal mass with hemoperitoneum. An ovarian wedge resection was done. She made good postoperative recovery and was discharged on the third postoperative day. Histology confirmed a ruptured ovarian ectopic pregnancy. Ovarian ectopic pregnancy is a rare condition and is associated with the use of assisted reproductive techniques. This case is unusual as it was a spontaneous pregnancy with no history of use of any assisted reproductive techniques

Relating tissue/organ energy expenditure to metabolic fluxes in mouse and human: experimental data integrated with mathematical modeling

Mouse models of human diseases are used to study the metabolic and physiological processes leading to altered whole‐body energy expenditure (EE), which is the sum of EE of all body organs and tissues. Isotopic techniques, arterio‐venous difference of substrates, oxygen, and blood flow measurements can provide essential information to quantify tissue/organ EE and substrate oxidation. To complement and integrate experimental data, quantitative mathematical model analyses have been applied in the design of experiments and evaluation of metabolic fluxes. In this study, a method is presented to quantify the energy expenditure of the main mouse organs using metabolic flux measurements. The metabolic fluxes and substrate utilization of the main metabolic pathways of energy metabolism in the mouse tissue/organ systems and the whole body are quantified using a mathematical model based on mass and energy balances. The model is composed of six organ/tissue compartments: brain, heart, liver, gastrointestinal tract, muscle, and adipose tissue. Each tissue/organ is described with a distinct system of metabolic reactions. This model quantifies metabolic and energetic characteristics of mice under overnight fasting conditions. The steady‐state mass balances of metabolites and energy balances of carbohydrate and fat are integrated with available experimental data to calculate metabolic fluxes, substrate utilization, and oxygen consumption in each tissue/organ. The model serves as a paradigm for designing experiments with the minimal reliable measurements necessary to quantify tissue/organs fluxes and to quantify the contributions of tissue/organ EE to whole‐body EE that cannot be easily determined currently

The Capacitated Matroid Median Problem

In this thesis, we study the capacitated generalization of the Matroid Median Problem which is a generalization of the classical clustering problem called the k-Median problem. In the capacitated matroid median problem, we are given a set F of facilities, a set D of clients and a common metric defined on F ∪ D, where the cost of connecting client j to facility i is denoted as c_{ij}. Each client j ∈ D has a demand of d_j, and each facility i ∈ F has an opening cost of f_i and a capacity u_i which limits the amount of demand that can be assigned to facility i. Moreover, there is a matroid M = (F,I) defined on the set of facilities. A solution to the capacitated matroid median problem involves opening a set of facilities F' ⊆ F such that F' ∈ I, and figuring out an assignment i(j) ∈ F' for every j ∈ D such that each facility i ∈ F' is assigned at most u_i demand. The cost associated with such a solution is : Σ_{i∈F} f_i + Σ_{j∈D} d_j c_{i(j)j}. Our goal is to find a solution of minimum cost. As the Matroid Median Problem generalizes the classical NP-Hard problem called k- median, it also is NP-Hard. We provide a bi-criteria approximation algorithm for the capacitated Matroid Median Problem with uniform capacities based on rounding the natural LP for the problem. Our algorithm achieves an approximation guarantee of 76 and violates the capacities by a factor of at most 6. We complement this result by providing two integrality gap results for the natural LP for capacitated matroid median

Immigration Surveillance

In recent years, immigration enforcement levels have soared, yielding a widely noted increase in the number of noncitizens removed from the United States. Less visible, however, has been an attendant sea change in the underlying nature of immigration governance itself, hastened by new surveillance and dataveillance technologies. Like many other areas of contemporary governance, immigration control has rapidly become an information-centered and technology-driven enterprise. At virtually every stage of the process of migrating or traveling to, from, and within the United States, both noncitizens and U.S. citizens are now subject to collection and analysis of extensive quantities of personal information for immigration control and other purposes. This information is aggregated and stored by government agencies for long retention periods in networks of interoperable databases and shared among a variety of public and private actors, both inside and outside the United States, with little transparency, oversight, or accountability. In this Article, I theorize and assess this underappreciated transformation of the techniques and technologies of immigration enforcement—their swift proliferation, enormous scale, likely entrenchment, and broader meanings. Situating this reconfiguration within a larger set of developments concerning surveillance and technology, I explain how these technologies have transformed a regime of immigration control, operating primarily upon noncitizens at the territorial border, into part of a more expansive regime of migration and mobility surveillance, operating without geographic bounds upon citizens and noncitizens alike. The technologies that enable this immigration surveillance regime can, and do, bring great benefits. However, their unimpeded expansion erodes the practical mechanisms and legal principles that have traditionally constrained aggregations of power and protected individual autonomy, as similarly illustrated in current debates over surveillance in other settings. In the immigration context, those constraints have always been less robust in the first place. Accordingly, I urge more constrained implementation of these technologies to preserve zones where immigration surveillance activities do not take place and to ensure greater due process and accountability when they do. A complete understanding of immigration enforcement today must account for how the evolution of enforcement institutions, practices, and meanings has not simply increased the number of noncitizens being deported but has effected a more basic transformation in immigration governance. The institutions of immigration surveillance are becoming integrated into the broader national surveillance state very rapidly. As that reconfiguration proceeds, scholars, policymakers, advocates, and community members need to grapple more directly with its implications