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Sa‘adat Hasan Manto: The Fifth Trial — The Story Behind the Case

Sa’adat Hasan Manto’s “The Fifth Trial” recounts the case over “Above, Below, and Middle,” the fifth proceeding in his account of prosecutions over his stories.
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In “The Fifth Trial,” Sa’adat Hasan Manto describes being summoned to court over his short story Ūpar, Nīčē Aur Darmiyān (“Above, Below, and Middle”), published in Karachi. The essay is a first-person account of the proceeding and of the four earlier cases against his writing—not a fictional courtroom drama.

What happened in Manto’s fifth trial?

Manto recounts that, after Ūpar, Nīčē Aur Darmiyān appeared in Karachi, he was summoned under Section 292. He travelled from Lahore to Karachi, appeared before an additional magistrate, and received a fine. These particulars come from Manto’s retrospective narrative; the essay is not, by itself, an independent court record.

The story’s title means “Above, Below, and Middle.” Manto’s account presents the case through personal recollection and irony, making the courtroom episode part of a broader reflection on his writing and the prosecutions it attracted.

Why is it called the fifth trial?

Manto sets this proceeding within a sequence of five cases over stories. In his account, the first three ended in acquittals. The named stories and their order are:

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  1. Kālī Shalvār (“Black Shalwar”)
  2. Dẖuvāñ (“Smoke”)
  3. Bū (“Smell”)
  4. Tẖanḍā Gōsht (“Cold Meat”)
  5. Ūpar, Nīčē Aur Darmiyān (“Above, Below, and Middle”)

The sequence is described by Manto himself. Later contextual scholarship likewise discusses five cases involving his stories, but the details of the fifth proceeding here should remain attributed to his account.

How does the essay connect the case to censorship?

The fifth case took place in independent Pakistan, shortly before Manto’s death in 1955. A 2023 contextual study of literary censorship in Pakistan places cases involving Manto’s stories in a longer history of obscenity and sedition prosecutions, including the inheritance of colonial penal codes. That context helps explain the legal framework around the episode; it does not replace Manto’s first-person telling or establish every detail of the proceeding.

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What is the essay’s publication history?

Manto writes that he began an article titled “The Fifth Trial” for Nuqūsh, issues 29–30, dated February–March 1953, but could not finish it because of illness. The English translation by Muhammad Umar Memon was published in The Journal of Urdu Studies in 2013, according to the translator’s note accompanying the essay. The available publication information does not establish the complete edition history or the full terms of the translation’s licence.

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Where can you read the essay and its historical context?

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