Supreme Court had the conservative leanings in regards to the constitutionalism and their judgements in the cases of important issues. Chief Justice Shahabuddin plays a crucial role in drafting the second set of the Constitution of Pakistan which incorporated the liberal ideas with the important Islamic provisions. In 1960, President Ayub Khan appointed Justice Alvin Robert Cornelius who took much liberal approach in his jurisprudence when deciding cases on fundamental rights against the executive overreach. Justice Cornelius led Supreme Court's verdicts on many constitutional cases were carefully sided with the Islamic ideas but provided much broader role of liberal ideas to safeguard the fundamental rights ordinary citizens while being critical of the state emergency. In 1968, the Supreme Court greatly divided when Chief Justice Hamoodur Rahman presided the case hearings after President Yahya Khan declared martial law and suspended the writ of the constitution. In the views of Chief Justice Rahman, the martial law was invalid and notably ruled that Yahya Khan's assumption of power was "illegal usurpation". The Supreme Court also overruled and overturned its convictions that called for validation of martial law in 1958. Despite rulings, there was a split decision between the moderation justices, including Chief Justice Rahman, and conservative leaning justices of the Supreme Court who "condoned" the actions in the light of "doctrine of necessity". The de jure powers of the Supreme Court has increased since presiding the War Enquiry Commission in 1974, intervening in events that Supreme Court justices viewed as violation of human rights by the executive's authorities. In 1977, the Supreme Court had again legalized the martial law in 1977 in the light of "doctrine of necessity" and denied took petitions to review its decision. During this time, Supreme Court justices were described as notoriously conservatives and only few moderates, appointed by Prime Minister Zulfikar Ali Bhutto as his role as President in 1971–73. The Supreme Court, however, did take the petitions to review the case of Zulfikar Ali Bhutto, after his counsels filed an appeal against the verdict of Lahore High Court. The Constitution Bench formed under Chief Justice Sh. Anwarul Haq, had contained Justice Muhammad Akram, Justice Dorab Patel, Justice Mohammad Haleem, Justice Nasim Hasan Shah, Justice Ghulam safdar Shah, Justice Kareem Illahi, Justice Waheedudin Ahmad, and Justice Kaisar Khan. By 1979, the Supreme Court greatly divided with Justice Dorab Patel, Justice G.S. Shah, and Justice Moh'd Haleem, who had