Neglect or Instrumentalization of Social Impact Assessment in Pakistan? Reflections on the 2025 Madni Mosque Demolition Case

Introduction

Methodology

Table 1. Audit codebook – indicators and decision rules.

Case Analysis/Discussion

The Madni Mosque Demolition Case: Events and Analysis

The mosque was reportedly constructed in the early 2000s, though exact records are unavailable. Its location on a greenbelt suggests it may have lacked formal planning approval, a common occurrence in informal religious and residential structures in Pakistan’s urban peripheries. The demolition in Islamabad took place in early August 2025 as part of a municipal drive to clear encroachments on public land. The mosque, along with an adjacent madrassa (religious seminary), was located on a greenbelt area alongside a main road (Murree Road near Rawal Dam Chowk) (Ali 2025). Viewing it as an unauthorized structure violating city zoning laws, the Capital Development Authority (CDA) and Islamabad Capital Administration decided to remove the mosque. Late on a Saturday night, bulldozers and police moved in to demolish the building, reportedly after ensuring the site was empty of people. By morning, the structure was razed and saplings were planted in its place as part of the “beautification” of the greenbelt (Dawn 2025). Crucially, there is no public record of prior disclosure, a stakeholder engagement plan (SEP), or a grievance mechanism, all of which would ordinarily evidence due process. This sequencing — decision → demolition → ex post landscaping — reverses the standard order envisaged by S/EIA.

Table 2. Chronological timeline of the Madni Mosque demolition (Islamabad, August 2025).

Table 2. Chronological timeline of the Madni Mosque demolition (Islamabad, August 2025).

Date (2025)	Event (observed)	Government statement / claim (if any)	Notes relevant to SIA/Social risk	Source
Aug 8–9 (Fri–Sat night)	Mosque demolished overnight on greenbelt; saplings planted by morning	—	Action precedes any documented public engagement; high conflict sensitivity overlooked	Dawn report Aug 11 (news + ePaper)
Aug 10 (Sun)	Worshippers pray at site; saplings uprooted	—	Immediate community backlash → strong indicator of social license gap	Dawn ePaper Aug 12
Aug 11 (Mon)	Protests by multiple religious groups; negotiations announced	—	Escalation within 24–48h → an ex-ante SIA would have flagged this risk	Dawn Aug 12 (news + ePaper)
Aug 12–13 (Tue–Wed)	—	Minister says consent was obtained; months-long process; replacement built (≈PKRs 40m; students relocated)	Post-hoc narrative; does not substitute for early, inclusive consultation	Dawn Aug 13; APP Aug 13
Aug 15 (Fri)	Large Friday gathering; groups begin reconstruction at site	—	Demonstrates absence of social buy-in; law-and-order risk materializes	Dawn Aug 16

The timing and manner of the demolition prompted immediate public concern and mobilization by religious groups. Public demonstrations were organized by religious political parties in response to the demolition such as Jamiat Ulema-e-Islam (JUI-F) (Kamijo 2022). Protesters gathered at the demolition site for several days, denouncing the government’s action as an assault on Islam. They symbolically rebuilt portions of the mosque with collected debris during a mass prayer gathering (Dawn 2025). Religious leaders publicly expressed their intent to reconstruct the mosque independently, citing dissatisfaction with the government's approach. The controversy intensified, with some groups filing legal complaints alleging religious desecration; multiple police complaints were lodged seeking to charge the Interior Minister and CDA officials for “desecration” of a place of worship (Dawn 2025). This reflects the intense social impact of the demolition, touching a deep religious nerve in a conservative society. Analytically, the rapid escalation from localized gatherings to city-wide mobilization within 24–48 hours is a classic marker of high conflict sensitivity that a routine SIA would flag at scoping.

Figure 1. Protest tension escalation after the Madni Mosque demolition (Islamabad, August 9–16, 2025). Figure was generated by synthesizing event chronology from press reports (Dawn, Daily Times) between August 9–16, 2025, mapping escalation phases and stakeholder responses.

Figure 1. Protest tension escalation after the Madni Mosque demolition (Islamabad, August 9–16, 2025). Figure was generated by synthesizing event chronology from press reports (Dawn, Daily Times) between August 9–16, 2025, mapping escalation phases and stakeholder responses.

In response, Government officials subsequently issued statements to clarify the rationale and legality of the demolition. Officials asserted that the relocation was carried out lawfully and with sensitivity. According to the Minister of State for Interior, “the demolition of the mosque and its adjoining seminary was carried out strictly per law, Islamic principles and with the consent of the mosque administration” (DailyTimes 2025). The authorities claimed they had given the mosque administrators two months’ prior notice and even constructed a modern new mosque and seminary in a different locality (Margalla Town) for Rs 40 million, “ensuring no one was present at the old site during demolition.” (DailyTimes 2025). They cited Islamic precedents to legitimize mosque relocation; for instance, invoking the Prophet’s order to remove an improperly built mosque (Masjid Dirar) in early Islamic history, and Quranic verses against unjust occupation of land (DailyTimes 2025). The Interior Ministry stressed that Islam permits relocation of mosques when done for the public good and with proper alternatives provided (DailyTimes 2025). Officials also insisted that any future removals of mosques from unauthorized sites would be done in consultation with religious scholars and with the administration “on board.” (DailyTimes 2025). However, these assertions are not accompanied by documentary artifacts typically used to verify due process (e.g., a dated written consent, minutes of meetings, a publicly disclosed SEP/GRM, or a relocation MoU); in their absence, “consent” remains unverified and narrowly construed. As used here, consent appears transactional and limited to custodians, rather than “broad-based community support, as required under international standards such as ESS10 and IFC Performance Standards” in the ESS10/IFC sense that requires inclusion of broader affected stakeholders.

Despite these assurances, a critical examination reveals that the SIA process was largely neglected and partially “instrumentalized” in the Madni Mosque affair (Vanclay Frank 2003; Esteves et al. 2012). The government’s narrative of having secured “consent” and provided a ready alternative was used as an ex post facto rationalization to blunt criticism, rather than as part of a genuine participatory planning process. By all accounts, the decision to demolish had already been made by authorities well before any outreach. The mosque’s caretakers may have been pressured into agreement, facing an illegal status, they had limited bargaining power. Broader stakeholders (local worshippers, neighboring communities, and the wider Islamic fraternity in Islamabad) were not engaged in advance. The first many learned of the plan was after the fact, through the shocking news that a house of worship had been torn down overnight. This lack of transparent, inclusive engagement violated the spirit of international standards like WB ESS10 and the IFC guidelines, which call for open dialogue throughout project planning (World Bank 2018a). This omission also illustrates what Cashmore (2004) terms a failure of substantive effectiveness: although the formal rationale emphasized legality, the process did not achieve the deeper objective of securing social legitimacy. Instead, authorities treated the matter as a confidential enforcement operation, likely to avoid mobilizing opposition, a political expedience that backfired by causing outrage when the secretive action came to light. In short, selective engagement of custodians functioned as “elite brokerage,” not community consultation; the sequence indicates narrative management rather than risk management. The limited evidence of a replacement facility signals partial compliance on resettlement infrastructure, but not on social continuity or ritual transition.

Had a proper Social Impact Assessment or stakeholder consultation been undertaken, it would have identified the mosque’s significance to the community and the high risk of backlash. An SIA might have recommended alternative approaches: for example, negotiating a relocation plan with the community’s buy-in, publicly announcing and explaining the move well in advance, perhaps even performing religious rites to officially transfer the mosque’s status to the new site before demolition. These steps could have preserved public trust and a sense of respect. Instead, the sequence of events—demolition followed by post hoc justification—contributed to perceptions of procedural opacity and disregard for community sentiment. The token elements of SIA that were present were instrumentalized mainly for narrative control: the new replacement building was highlighted to show “no harm” was done, and the claim of clerics’ consent was repeatedly emphasized as proof of consultation (DailyTimes 2025). Yet, this narrowly defined consent (limited to the seminary’s head) does not equate to broad community acceptance or participatory decision-making. In essence, the government used the veneer of SIA (replacement facility, selective consultation) to legitimize an action that otherwise followed the typical pattern of a forced eviction or clearance. Counterfactually, a sequenced plan — public notice → clerical council mediation → ritual translocation → activation of the new site prior to closure — would likely have reduced conflict probability and reputational risk. This pattern aligns with critiques in Vanclay (2020) and Ijabadeniyi & Vanclay (2020), who highlight how procedural references and technical language in ESIA can obscure substantive harm and marginalize affected communities (Cashmore 2004; Bond et al. 2018). According to the IAIA Principles of SIA, effectiveness requires early integration, inclusivity, and influence on decision-making. None of these were evidenced here, highlighting a gap between formal compliance claims and substantive practice.

From a legal standpoint, the Madni Mosque case also exposes ambiguities and gaps in Pakistan’s environmental and social protection framework. Formally, the Pakistan Environmental Protection Act (PEPA) 1997 and the accompanying IEE/EIA Review Regulations (2000) require that any project likely to have an “adverse environmental effect” must undergo an Initial Environmental Examination or full EIA, including at least one public hearing for the latter (Government of Pakistan 1997; Alam 2018). However, what constitutes a “project” and an “adverse environmental effect” is key. One could argue that an operation to demolish a longstanding public mosque and alter land use has significant social and environmental ramifications, community unrest, loss of cultural heritage, changes in land cover (greenbelt restoration), thus should have triggered an assessment. In practice, though, authorities treated it not as a development project but as an enforcement action, thereby sidestepping environmental review processes entirely. However, international best practice recognizes that actions with significant social consequences, such as demolitions of religious or residential structures, warrant proportionate SIA, even if not legally classified as ‘projects.’ The World Bank’s ESS10 and IFC Performance Standards require stakeholder engagement and grievance mechanisms in any activity with foreseeable social risks, regardless of formal EIA triggers (World Bank 2018b; Imperiale & Vanclay 2023). Pakistan’s EIA regulations list types of projects that require EIA (large infrastructure, industrial plants, etc.), but a one-off demolition for land clearance is not explicitly covered (Nadeem and Fischer 2011). This loophole meant the CDA could lawfully proceed without any EIA or SIA, despite the profound social impact. The law’s focus on physical environmental impact and its project-based definitions left social considerations in such enforcement scenarios unregulated. As noted in one analysis, Pakistani EIA laws “do not specifically cater to Social Impact Assessments,” being primarily geared toward biophysical factors (Alam 2018). Public consultation is only mandated during the EIA review stage and not at all for smaller undertakings (Alam 2018). Thus, if an action is not formally categorized as a project requiring EIA, the law imposes no duty to consult or compensate affected communities. This regulatory gap was evident in the Madni Mosque saga; the authorities were not legally compelled to hold a public hearing or prepare an impact report, and they did not. The outcome demonstrates how even a legally “compliant” operation (in terms of domestic law) can fail the test of social legitimacy and sustainability when broader stakeholder engagement is neglected. This constitutes a form of regulatory arbitrage: by classifying the act as “enforcement,” the state avoided triggers that would otherwise have mandated disclosure, hearing, and conditions of approval (Bond et al. 2018). Doctrinally, the social consequences meet “significance” thresholds even where biophysical impacts are modest, underscoring a design flaw in PEPA and its rules. Conceptually, this illustrates the classic distinction between “procedural effectiveness” (whether legal steps exist) and “substantive effectiveness” (whether impacts are actually mitigated) often applied in IA literature (Cashmore 2004). While Pakistan’s EIA framework provided procedural cover, substantive outcomes — community trust, conflict avoidance, cultural continuity — were absent, underscoring the weakness of formalistic compliance in fragile governance contexts.

Enforcement Framing and SIA Avoidance: Comparative Patterns in Urban Governance

While the Madni Mosque case is central, similar enforcement-driven actions in Pakistan reveal a broader pattern of SIA avoidance. These comparisons help situate the case within systemic governance dynamics. The incident therefore is not an isolated case; it reflects a broader pattern of compromised social due process in Pakistan during enforcement, displacement, or land-clearance operations. In numerous instances, development projects or anti-encroachment drives have proceeded with little-to-no attention to SIA, leading to human rights violations, social tensions, and protracted conflicts (Table 1). The term ‘encroachment’ is often used by authorities to justify clearance of informal or unauthorized structures. However, this framing obscures the socio-legal complexity of land tenure, religious use, and community claims. Scholars argue that encroachment is not merely a legal violation but a contested concept shaped by governance failures, urban inequality, and planning exclusion (Andreasen et al., 2022). Two instructive comparisons are the mass eviction of the I-11 Katchi Abadi (informal settlement) in Islamabad in 2015 and the clearance of thousands of homes along Karachi’s stormwater drains (nullahs) in 2020-21. These cases, like Madni Mosque, highlight how formal legal justifications (illegality of structures, public interest objectives) are often pursued through summary actions that override community participation and social safeguards. Across cases, the mechanism is consistent: weak or absent duty → compressed timelines → force-first implementation → ex post justification → rights-claiming and unrest. Where partial remedies existed (e.g., limited cash in Karachi), they were non-restorative and lacked livelihood linkage.

In July 2015, Islamabad’s I-11 informal urban settlement (locally known as “Afghan Basti”) was bulldozed in a large-scale operation. Approximately 15,000 people, mostly low-income Pashtun families, were evicted from land they had lived on for decades (Ahmad 2002). The authorities (CDA, police, and paramilitary Rangers) served only a one-week eviction notice before mobilizing force. When residents refused to leave, citing lack of alternative shelter, the state deployed hundreds of personnel to cordon off the area and systematically demolish homes with excavators (Ahmad 2002). Many inhabitants escaped with just their basic possessions; some who resisted were beaten or arrested (Ahmad 2002). No resettlement plan was offered; the residents were simply deemed encroachers on state land and thus undeserving of compensation. This approach blatantly disregarded any notion of SIA or stakeholder engagement. The eviction destroyed not just physical structures but livelihoods and community networks, leaving evictees in a humanitarian crisis (Cernea 2000; Fernandes 2008). From a conceptual IA lens, this case highlights procedural effectiveness was absent (Bond et al. 2018), as no scoping or consultation mechanisms were applied, leading to predictable substantive failures in social outcomes. Subsequent investigations by human rights organizations concluded that the eviction violated multiple rights (housing, due process, etc.) and failed to meet international standards for evictions (HRW 2024). For instance, advance consultation was absent; people were not meaningfully informed or consulted about less harmful alternatives. International law (e.g. UN guidelines on evictions) requires exploring all feasible alternatives and genuine consultation before displacement, but Pakistani law’s silence on such requirements enabled the blunt use of force (HRW 2024). The I-11 case led to court petitions and public criticism, yet it set a precedent for similar anti-encroachment actions in the years to follow, with the underlying social issues unresolved. Analytically, I-11 represents “zero-option” decision-making: no alternatives, no entitlements, no GRM—an archetype of SIA avoidance under an enforcement framing.

Fast forward to Karachi in 2020-2021, where authorities undertook mass demolitions of houses built along the Gujjar and Orangi Nullahs (stormwater channels) after catastrophic urban floods. Framing the informal riverside settlements as the cause of drainage blockage, the city, on court orders, cleared a wide swath of working-class neighbourhoods. Over 20,000 homes were estimated to be demolished, displacing around 100,000 people. Again, the pattern repeated: minimal consultation, perfunctory notices, and inadequate rehabilitation. Many affected families had nowhere to go; some received meagre monetary compensation that did not cover the cost of new housing. Activists argue that “preventing flooding was used as an excuse to gentrify the area”; the land cleared is prime urban real estate [46]. Regardless of intent, the social outcome was thousands of homeless people, whose plight was largely ignored in the pursuit of an infrastructure objective (Patel and Baptist 2012; Satterthwaite and Mitlin 2013). A Human Rights Watch report on these evictions noted that they “worsen social and economic inequalities, disproportionately burdening low-income and minority households” (HRW 2024). In other words, the absence of SIA in planning perpetuates environmental injustices: vulnerable groups bear the brunt of both environmental hazards and the impacts of mitigation projects. Notably, even after these harsh measures, Karachi continues to experience flooding highlighting that evicting the poor is not a cure-all, and a more holistic, consultative approach to urban resilience was needed (HWR 2024). The persistence of flooding despite mass displacement underscores Vanclay’s (2020) critique of SIA “instrumentalization”: impact assessment language is invoked to justify interventions, but the processes are detached from their purpose of risk reduction. The courts in Pakistan, which ordered or green-lit many such anti-encroachment drives, have been criticized for ignoring the social dimensions and treating the issue purely as one of legality of tenure. There is a nascent recognition (as seen in some Pakistani court judgments on housing rights) that due process and rehabilitation are part of the right to life, but this principle is yet to be consistently applied in practice (Alam 2018; HRW 2024). Karachi thus demonstrates the limits of “infrastructure-first” approaches: biophysical risk reduction cannot be sustained if it manufactures social vulnerability downstream.

Across these cases – the mosque demolition, the slum clearance, the flood evictions – a common thread is the instrumental use of law and process to expedite objectives at the expense of public participation (Sánchez and Mitchell 2017; Bond et al. 2018). Environmental and planning laws are invoked to justify action (be it restoring a greenbelt or removing encroachments for public safety), but social impact processes are either bypassed or reduced to a checkbox. Public hearings, where they occur, often happen after key decisions are made, and affected communities’ input seldom influences outcomes (Nadeem 2010; O'Faircheallaigh 2010). This tokenism erodes trust in authorities and can lead to conflict, as seen in the Madni Mosque case where excluded stakeholders resorted to protest and even violence. Seen through IA theory, this represents a collapse across all four quality dimensions: procedural (steps omitted), substantive (outcomes worsened), transactive (inefficient use of resources), and normative (erosion of justice and equity) (Bond et al. 2018). The failure to integrate SIA also means missed opportunities for better solutions. With genuine engagement, creative compromises could emerge; for example, in Islamabad’s Mosque case, stakeholders might have agreed on relocating the structure in a ceremonious, acceptable manner; in Karachi’s flood areas, upgrading settlements in-place with community cooperation might have been preferable to wholesale demolition. Empirically, what fails is not merely procedure but problem-solving capacity: exclusion forecloses lower-cost, lower-conflict options that SIA typically surfaces.

Table 3. Graded procedural compliance matrix for the Madni Mosque demolition.

Table 3. Graded procedural compliance matrix for the Madni Mosque demolition.

S/EIA step (aligned to WB ESS10 / IFC / ADB)	Madni Mosque (Islamabad, 2025)	I-11 Eviction (Islamabad, 2015)	Karachi Nullahs (2020–21)	Adopted Strategy
Screening & scoping	✖	✖	✖	No public scoping artifacts in press/official record for all three.
Baseline social data / stakeholder mapping	✖	✖	✖	No SEP/baseline disclosed (Madni); I-11 demolitions proceeded as enforcement; Karachi evictions criticized for lack of enumeration & inclusion.
Ex-ante social risk analysis	✖	✖	✖	No evidence of risk analysis prior to action in press/NGO documentation.
Alternatives analysis (avoid/minimize)	✖	✖	✖	No public record of alternatives (e.g., ritual relocation/in-situ solutions; upgrading/phasing for Karachi).
Consultation & disclosure	◐ (limited to administrators)	✖	✖	Madni: minister’s claim of “consent” contrasted with broad protests I-11: enforcement operations with clashes; Karachi: UN OHCHR cites lack of consultation.
Resettlement / compensation	◐ (replacement facility)	✖	◐ (rent/cash stipends, uneven)	Madni: replacement reported; I-11: none reported in contemporaneous press; Karachi: rent support ordered by SC but uneven/delayed
Grievance redress mechanism (GRM)	✖	✖	✖	No formal GRM disclosed; grievances expressed via protests/courts/CSOs. Madni: Friday rebuild; I-11: clashes; Karachi: UN/HRW criticism.
Monitoring & follow-up (social)	✖	✖	✖	No publicly available monitoring of social outcomes found.
Legal framing / trigger	— (enforcement)	— (enforcement)	— (judicial clearance)	Framed to avoid EIA triggers (press/judicial framing). Madni & I-11: enforcement; Karachi: SC-driven clearance; rent support ordered later.

Theoretically, these cases resonate with critics that IA in the Global South is trapped in a “thin” model, where reports and notices substitute for genuine social engagement. Integrating global best practice requires shifting toward “thick” IA; embedding deliberation, grievance mechanisms, and adaptive monitoring into core decision processes. It is instructive to compare Pakistan’s situation with experiences elsewhere. Many developing countries face similar struggles in operationalizing SIA. Studies have found that political will is a decisive factor; in places where governments see public participation as a threat or delay, they tend to keep it superficial (Chen 2013). Moreover, weak institutional capacity and lack of enforceable guidelines result in EIA/SIA reports of poor quality that decision-makers largely ignore (Nadeem and Fischer 2011). Pakistan typifies these challenges: while it has the legal trappings of environmental assessment, the practice often devolves into a pro-forma exercise, or is sidestepped entirely for politically sensitive undertakings. The Madni Mosque case also underlines an important point: even where an EIA is not legally required, there may be significant social impacts. Modern policy thinking advocates the use of “strategic” or ad-hoc SIA for policies or actions that affect communities, even if not full projects; for instance, urban renewal programs, slum clearance operations, or heritage site decisions. In Pakistan, such mechanisms are missing. Social impact considerations remain largely reactive (dealt with through crisis management once public backlash occurs) rather than proactive (planned for in advance). This article’s contribution is to identify “enforcement framing” as a predictable pathway to SIA avoidance and to specify the institutional fixes (trigger rules, SEP/GRM requirements, resettlement policy) that would close it.

Encouragingly, there are signs of change. Pakistani civil society and academia have been calling for stronger social safeguards. Some have proposed updating laws to explicitly require SIA and resettlement planning in a range of scenarios (Alam 2018). A draft National Resettlement and Rehabilitation Policy has existed since 2002 but awaits formal adoption (Alam 2018). If implemented, it could fill some gaps by mandating rehabilitation for people displaced by government projects, even when land acquisition is not via formal purchase. Additionally, Pakistan’s higher courts in a few cases have recognized housing and livelihood as rights; for example, the Supreme Court in 2015 (Dr. Imrana Tiwana case) emphasized that environmental regulators must uphold “social justice” and that unchecked development violates citizens’ rights (Alam 2018). In principle, these judgments support the argument that authorities have to weigh social impacts and involve the public, even if statutes are silent on the matter. The challenge is translating these judicial dicta and policy proposals into everyday administrative practice. Taken together, the evidence supports a graded conclusion: partial compliance (physical replacement facility) alongside systemic non-fulfilment of core SIA functions (baseline, alternatives, GRM, monitoring). For practitioners, the operational lesson is straightforward: the absence of a legal trigger does not erase social risk; it merely shifts it into the realm of public order and legitimacy.

Conclusions and Recommendations

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