Appealing a Virtual Assets Tribunal Order to the Supreme Court

The Virtual Assets Act 2026 builds a two-tier appeal structure around decisions of the Pakistan Virtual Asset Regulatory Authority (“PVARA” or “the Authority”). The first tier is the Virtual Assets Appellate Tribunal, which hears appeals against PVARA’s own orders. The second and final tier, set out in a single provision — section 65 — is a further appeal to the Supreme Court of Pakistan.

This article covers that final route: who can use it, the deadline that applies, and how it fits with the rest of the Act’s enforcement and appeals framework. Two related analyses cover the earlier stages — who sits on the Tribunal, and how the first-tier appeal against a PVARA order actually works.

What does section 65 of the Virtual Assets Act say?

Section 65 gives any person aggrieved by an order of the Virtual Assets Appellate Tribunal a right to appeal to the Supreme Court of Pakistan, within thirty days of the date of that order. The Act states:

“Any Person aggrieved by an order of the Virtual Assets Appellate Tribunal may file an appeal to the Supreme Court of Pakistan within thirty days from the date of such order and in such manner as may be prescribed.”

That is the entire operative text of the section. It sits alone in Chapter 11 of the Act, immediately after section 64, which sets out how the first-tier appeal to the Tribunal is conducted.

Who can bring this appeal?

The wording — “any Person aggrieved” — mirrors the equally broad language used in section 63 for the first-tier appeal to the Tribunal. It is not restricted to the party that originally brought the Tribunal appeal, nor to virtual asset service providers or licence holders specifically. Read plainly, any person with a genuine grievance arising from the Tribunal’s order — whether the original appellant or, in principle, another party directly affected by that order — falls within scope. The Act does not narrow this further, and it does not, for example, exclude the Authority itself from being an aggrieved party capable of appealing a Tribunal decision that went against it.

How long does a party have to file this appeal?

Thirty days from the date of the Tribunal’s order. This is the same length of window the Act gives for the first-tier appeal against a PVARA order under section 63, so the structure is symmetrical: thirty days to challenge PVARA’s order before the Tribunal, and a further thirty days to challenge the Tribunal’s order before the Supreme Court.

Stage	Appeal from	Appeal to	Window	Statutory basis
First tier	Order of PVARA	Virtual Assets Appellate Tribunal	30 days from communication of the order	Section 63
Second tier	Order of the Tribunal	Supreme Court of Pakistan	30 days from the date of the order	Section 65

Because the two windows use slightly different anchor language — section 63 runs from the date the PVARA order “was communicated”, while section 65 runs from “the date of such order” — a careful reader should not assume the two clocks are triggered identically. Our reading is that the difference in wording may matter in a case where there is a gap between a Tribunal order being made and being communicated to the parties, though the Act does not resolve that question directly for the section 65 window the way it does for section 63.

In what manner must the appeal be filed?

Section 65 says the appeal must be filed “in such manner as may be prescribed” — deferring the procedural detail to Rules made under the Act, in the same way section 64(1) defers the form, particulars, documents and fee for a Tribunal appeal. The Act itself does not set out the form of the Supreme Court appeal, the documents that must accompany it, or any fee. Readers preparing such an appeal should confirm the current procedural requirements directly with the Supreme Court’s own rules of procedure and any Rules PVARA or the Federal Government issue under the Act, rather than relying on an assumption drawn from the Act’s text alone.

Does this appeal go through the ordinary High Court structure first?

No. The Act’s structure moves directly from the Tribunal to the Supreme Court of Pakistan — there is no intermediate High Court appeal built into Chapter 11 of the Act. This is consistent with section 62(1), which excludes the ordinary courts’ jurisdiction over disputes falling within the Tribunal’s jurisdiction, and with the Tribunal itself being staffed, under section 62(2), by people qualified to a standard equivalent to a retired High Court judge or a senior advocate. In effect, the Act substitutes the specialist Tribunal for what might otherwise have been a first-instance court, and then allows a final appeal straight to the apex court.

What can a party actually challenge at the Supreme Court stage?

Section 65 does not itself limit the grounds of appeal — it does not, for example, say the appeal is confined to a question of law, as some other statutory appeal provisions in Pakistan do for appeals to the Supreme Court. The Act simply gives “any Person aggrieved by an order of the Virtual Assets Appellate Tribunal” a right of appeal, without stating a narrower test. Where a statute is silent on the scope of appeal in this way, the applicable Supreme Court rules of procedure, and the Supreme Court’s own practice, will generally govern what can and cannot be argued at that stage — this is a matter for the Court’s own procedural framework rather than something the Virtual Assets Act 2026 itself resolves, and it should be verified against the Supreme Court’s current rules before relying on any particular scope of appeal.

Why does this matter for a VASP or applicant weighing whether to appeal?

A licensee or applicant contesting a PVARA order under the Virtual Assets Act 2026 is not gambling on a single hearing. The structure gives two further chances to have an adverse decision reviewed — first by a Tribunal with statutory civil-court powers under section 64(3), and then, if still aggrieved, by the Supreme Court of Pakistan itself. That is a meaningful safeguard against a single regulatory decision being final and unreviewable. At the same time, both stages carry a strict thirty-day filing window, and missing either deadline is likely to close off that stage of review entirely, since the Act does not provide for an extension of either thirty-day period. In practice, this means the clock starts running the moment an order is made or communicated, not from whenever a party gets around to instructing advisers — a point worth building into any internal escalation process for a licensed virtual asset service provider.

How does this compare with the rest of the enforcement chapter?

Chapter 10 of the Act gives PVARA a wide enforcement toolkit — criminal offences under section 54, administrative sanctions under section 59, emergency intervention powers under section 60, and website-blocking powers under section 61. Chapter 11’s two-tier appeal structure is the counterweight to that toolkit: whatever action PVARA takes under those provisions, an affected party generally has the section 63 route to the Tribunal and, ultimately, the section 65 route to the Supreme Court available to test it. Prosecutions under section 54, by contrast, run through the ordinary criminal courts and any Special Court the Federal Government designates under section 54(8), rather than through the Tribunal — the Chapter 11 appeal route applies to PVARA’s own regulatory orders, not to a separate criminal prosecution.

Related reading

• PVARA Exchange License: Capital, Rules & Obligations 2026
• PVARA Transfer & Settlement License: Crypto Payments 2026

About this analysis

This analysis was prepared by the CoinConnect research desk from the Virtual Assets Act 2026, read as published, focusing on section 65 and its relationship to sections 62 to 64 and Chapter 10. Where the Act defers procedural detail to Rules not reproduced in its text, or is silent on a point such as the grounds of appeal available at the Supreme Court stage, that is stated in the text above.

Regulatory positions change and specific requirements should be verified against the current position published by the relevant authority before you act on them. This is information and analysis, not legal advice, and it does not create an advisory relationship. Take professional advice on your own circumstances.