- Accused — Substitution of — It is a very rare phenomenon — One who alleges substitution must lay foundation for the same — If at all the complainant party was inimical or some of the eye-witnesses were having some enmity even then it was the basic duty of defence to lay foundation for proving substitution of the accused. Liaqat Hussain & another v. Ulfat Khan & another 2007 SCR 39 (C)