Wednesday, 23 November 2016

Amend Anti-Corruption Act.


With steps being taken to put a check on black money it is high time that the next big thing be done i.e. to relieve the common man from the clutches of corruption is here.
"When the rich stop giving,
The corrupt will stop asking,
And when everybody will have to stand in the same line,
INDEED MY COUNTRY SHALL BE FREE FROM CORRUPTION." 
Prajval Albuquerque.

Hence with this object in mind through this post I have made a sincere effort to analyse the Amendment Bill to Prevention of Corruption Act 1988 and the way forward.
Proposed Amendment To Prevention of Corruption Act, 1988.

   Introduction:
    The entire Act of 1988 is not repealed entirely but the following sections of the Act are proposed to be amended which are as follows S.7, S.8, S.9 and 10, S.11, S.12 to S.15, S.17A (I),[S.18A(I) to18N],19 and 20, S.24 have been omitted. The bill focuses on amending the Act with regards to the definition, meaning and application of 1988. The Bill makes  giving of a bribe an offence against only taking of bribe as in Current Act. The Amendment also focuses on; Intermediaries and third party involvement, giving of a bribe by a commercial organization, abetment, criminal misconduct and habitual offender, attachment of property acquired as a bribe, protection to retired public servants from prosecution, Presumption   of wrongdoing.

  History:
The Prevention of Corruption (Amendment) Bill, 2013  was introduced in the Rajya Sabha in August 2013 to amend the PC Act. The Amendment Bill was referred to the Standing Committee of Personnel, Public Grievances, Law and Justice, which submitted its report in February, 2014. In pursuance to the report there had been certain modifications to the Amendment Bill. The revised draft was approved at a cabinet meeting and was subsequently sent to the Law Commission of India for its views. The Law Commission has in February, 2015[1]
   Analysis of Sections in the Act and the Amendments passed by the cabinet :

·        S.7(As to be  Amended by the Bill compared with Existing Section 7 and UK Bribery Act):
The ingredients of these Sections are compared along with the sections of the Act in existence, proposed Amendment and UK Bribery Act[2] 



S. 7, PC Act, 1988

S. 7(1), 2013 Amendment

S. 2(1) UK Bribery Act
Any public servant who
 accepts
 obtains
 agrees to accept
 attempts to obtain

“any gratification whatever, other than legal remuneration….”
in the context of “official acts” or “official functions”
Any public servant who
requests any person for
 obtains
 agrees to receive
 accepts
 attempts to obtain

“any undue financial or other advantage” ….
in the context of “improper performance” of “a relevant public function or activity”
Any person who
 requests,
 agrees to receive or
 accepts

“a financial or other advantage”…..
in the context of “improper performance” of a “relevant function or activity”

The Amendment by proposing to add the word requests in S.7 (1) acts as a very potent tool to snip corruption in the bud as now there shall be no need of actual physical delivery of the bribe, thus any such person who had demanded a bribe but due to intimation or pre-knowledge  of a trap by Anti- Corruption Authorities refuses such a bribe and files a suit of Defamation, or maligning the image of a public official  against the person from whom  such bribe was demanded and who took up the effort to set up the trap. By inserting the word request a safety cover for the activist is inserted, however it is up to  him how he would prove this request was made. Though the previous Act provided a protection against counter filing of suit by using the words attempts to obtain. Yet these words came into picture when a suit had begun against the person who had initially made a complaint against the public servant was before the court and the court decided whether the act of public servant was an attempt to obtain any gratification based on the motive of the act. The word request thus leaves no scope for identifying ‘was there an attempt or not’. Secondly by the use of the word request. It becomes easier for the complainant to identify what is an attempt to obtain gratification and thus he can be judicious while lodging a complaint. The words however attempt to receive gratification are not deleted. It is beneficial as the court where no request was made can still at is discretion based on facts determine whether there was an attempt to receive gratification. Hence there is clarity regarding when to complain and ample space for judiciary to decide on how to Act when no request was made yet there was an intention to receive gratification. Thus this Section is a perfect combination of rigidity and flexibility. When compared with UK bribery Act Amendment this section specifically uses the words, “requests any person”. But the word person is not defined in the Act so to increase the ambit of the Act S.9 was amended which incorporated the term commercial organization and in the same section,the word "business" is defined under (3)(a) of the above mentioned section which incorporates every other entity other than a person who may give bribe. The issue can be solved by the judicial interpretation of the words attempts to obtain. In spite of this to add more clarity to this Section a need is felt either to delete the word person as in UK Bribery Act or to define the word person in this amended Act, though the general clauses act takes care of it. S.7 is an excellently drafted section that caters to the various facets of receiving gratification which are described in detail so as to avid any loop hole in the law. The S.7 (2) (a) to (d) describes as what may be construed as public activity and (e) leaves the discretion to court so as to consider  of any other act as may be understood by a reasonable man. However a need is felt either to make the public servant responsible for his private acts which have an impact on the ultimate fulfilling of legal obligation. Basically the intention of framing this legislation was to stop the people from paying bribes hence focus should be not on the activity but on the consequence or the effect sought and the same which is to be achieved. Thus the provisions in this section should be made applicable regardless of the form of activity either public or private if the legal objective sought by the complainant is left unfulfilled due to non-performance or wrongful performance of the public servant due to non-payment of any gratification to which he is not entitled to or to achieve any such legal or illegal objective any public servant demands any gratification which he is not entitled to  then he shall be liable for prosecution.
The punishment has also been enhanced in this amendment  from  minimum punishment of 6 months to 3 years in this section and maximum from 5 years to 7 years.
   
S.8 ( As to be  Amended by the Bill compared with Existing Section 8):
In S.8 of the 1988 Act it stated the liability and the punishment to be imposed on any such person who received any such gratification for himself on behalf of any public servant  to which he was not entitled to.....(It further states the penalty for the same). S.8 has been modified in the Amendment as with regards to changing  context  and it  has been observed from the acts of the Corporates in the 2G Scam case that corruption is not only limited to situations where bribe would be demanded by the public servant to fulfill his legal obligation but where persons would give gratifications to direct a public servant to perform his public function in an unlawful or erroneous manner. Thus the amendment to S. 8 focuses on making the person offering or giving the bribe too liable for his act and a punishment of minimum 3 years and a maximum punishment of 7 years  will be awarded. At present however the bribe giver or offerer walks out scot free as per the provisions of the Section 24 of this Act. The intention of the framers of the 1988 Act was to prevent corruption in its totality and to punish any person who committed an act of offering bribe. Hence they drafted S.12 but however word used was abetment which means, “To contribute as an assistant or instigator to the commission of an offence”[3]. Based on this meaning the bribe offeror is in no way contributing to the act of public servant rather he is just making a proposal
When one person signifies to another his willingness to do or to abstain from doing anything, with a view to obtaining the assent of that other to such act or abstinence, he is said to make a proposal”[4].
Thus if such person offered a bribe but did not give any such bribe would be  exempted under S24 and even if he actually paid such a  bribe he would not come under  S.12, as he would not fit in the definition of S.12. Hence the Amendment to S. 8 of this Act was the need of the hour. 

·        S.9 (As to be  Amended by the Bill compared with Existing Section 9):
Section 9 talks about the liability of the various commercial organization towards the acts of the employees committed for the benefit of the commercial organization. This concept is based on the tortuous concept of Vicarious liability of Master towards the acts of its servants. There are provisions in various Acts regarding the laws regulating them individually but to bring them under the ambit of one single Act so as to increase their liability towards public they have been combined and classified as commercial organizations which is defined in S.9 (3)(a) of the Amendment.
Note: The punishment has also been enhanced in this amendment  from  minimum punishment of 6 months to 3years   in this section and maximum from 5years to 7 years 

·        S.10 (As to be  Amended by the Bill compared with Existing Section 10):
S.10 is the punitive or the application section for the acts committed by the employees of the commercial organizations as in S.9 of the Amendment. S.9 and S.10. Where in (1) it  makes the persons in charge and responsible for running these commercial organizations responsible for the acts of its employees as in S.9 and awards punishment  for a period of minimum 3 years and maximum 7 years and fine . It however nullifies the liability of such persons mentioned above if they prove that the offence was committed without their knowledge or that they had exercised all due diligence to prevent the commission of such offence
This is further clarified in the (2) of this Section where it states the persons responsible for the acts of their employees and as and when such liability comes into effect. It is worded as follows:
“where an offence under section 9 has been committed by a commercial organization and it is proved that the offence has been committed with the consent or connivance of, or is attributable to, any neglect on the part of any director, manager, secretary or other officer of the commercial organization,such director, manager, secretary or other officer shall also be deemed to be guilty of the offence and shall be liable to be proceeded against and punished accordingly under this section.”
Here it must be clarified that the original 1988 Act S.10 does not contain Sub section 2 and will be incorporated in this Act if this bill is passed.
S.9 and S.10 when read together eliminates the ambiguity which has been created in S.7 by not defining the term person though this ambiguity is cleared by looking  at the definition of person in General Clauses Act, but however abiding by the Rules of interpretation it is always a safer bet to deal with such an essential term in the Act itself.

·        S.11( As to be  Amended by the Bill compared with Existing Section 11):
The Amendment bill omits the S.11 of the previous Act. The Section is in context of a Public servant obtaining valuable thing, without consideration from person concerned in proceeding or business transacted by such public servant. Going by the contents in the current Section it contains three main ingredients
Obtains or agrees to obtain any gratification for himself or any other person:
1.     Without consideration.
2.     Or for a consideration which is inadequate.
3.     Punishment for receiving such gratification.
Though a classification is made in this section with regards to public servants who demand a bribe yet the punishment is the same. This specific section does not serve any purpose. Secondly in case of corruption there is no need to make any reasonable classification as permitted in Article 14 as any such classification must be made with regards to objectives of the Act and no objective of this Act is fulfilled by making such classification. Hence the Amendment omits it.

·        S.12 (As to be  Amended by the Bill compared with Existing Section 12):
The current section in the Act punishes offence for abetting any of the acts committed in S.7 and S.11. But since the Amendment changes the wordings of S.7 and omits S.11. So a need is felt to amend the S.12 as well. Secondly the wordings of the Amendment to this section are so worded so as to generalize the offence of abetting any acts committed in violation of this Act. It also contains the punishment  there to.

·        S.13 (As to be  Amended by the Bill compared with Existing Section 13):
Only clause(a) and (b ) of the current Act have been substituted   .
These sub clauses in  the current Act relate only to habitual offenders but to make the law more stringent there should be no classification made with habitual and non- habitual offenders as this differentia is not necessary to serve the objectives of this Act so these have  been substituted  in the Amendments which rather focus on the words fraudulently and intention of the public servant.
·        S.14 (As to be  Amended by the Bill compared with Existing Section 14):
The current section punishes specific habitual offences as in S.8, 9 and 12.
The Amendment generalizes punishment for all the offences which are committed habitually rather than making it specific to certain offences besides this it also helps to concise the legislation.
The minimum and the maximum punishment under the current Act have been enhanced in the current amendment from 2 to 3 years and from 7 to 10 years.




·        S.15 (As to be  Amended by the Bill compared with Existing Section 15):  
 The current S.15 of the Act deals with punishment for attempting to commit professional misconduct as in S.13. The current amendment has amended S.13. Hence S.15 too has been amended in accordance with it. However the punishment has not been enhanced in the Amendment  to S.15.

·        S.17 (As to be introduced by the Bill):
S. 17 of the Act designates certain authorities to investigate charges of corruption bu t no authority can be appointed under this Act or investigation  by any authority appointed  be conducted violating any provision of CrPC.
S.17 A is added  in the Amendment so as to keep a check on the powers of the authorities who are designated to Act on a complaint of any person but to avoid  any arbitrary act or  misuse of power by such designated authorities. The legislators through this provision have given powers in the hands of Lokpal in case of central government employees and Lokayuktas in case of state government employees and without their  approval an investigation cannot be initiated but at the same time it can be said that the powers of the Lokpal and the Lokayuktas are being diluted because as per S.11 and 12 of the  THE LOKPAL AND THE LOKAYUKTAS ACT 2013 has empowered the Lokpal and the Lokayuktas to constitute a inquiry wing of which he himself must be a member of and prosecution wing but at the beginning of S.11 the words,“Notwithstanding anything contained in any law for the time being in force” hence once this legislation is passed the Lokpal will not be able to conduct or initiate inquiry on his own. But at the same time this section of the amendment plays a crucial role in the decentralization of Authority as the power to sanction an inquiry will be with him and the designated police officer. Hence there can be no scope for collusion between the accused public servant and the person investigating the matter. Despite all this some questions   still remains unanswered i, Why are special bodies like Lokpal and the various tribunals created ? They are created with a view to hasten the legal proceedings but if despite creating these bodies  if we are depending on police for investigation  then why  are we exerting pressure on our consolidated  funds by creating such bodies? Lastly doesn’t the Government trust the credibility of the Lokpal? If the Government does not trust the Lokpal then THE LOKPAL AND THE LOKAYUKTAS ACT 2013 Act must be severed or in the current Act Lokpal and the Lokayuktas should be given authority to conduct to investigate and prosecute the public servants as per S.11, 12 , CHAPTER IV and CHAPTER V of  THE LOKPAL AND THE LOKAYUKTAS ACT 2013.
The proviso to this Amendment allows for investigation of any public servant without the consent of  Lokpal or Lokayukta where the public servant has been arrested on the spot while receiving any gratification. The law commission of India in its report 254 has summarised this section as follows:
The proposed section 17A(1), introduced in 2014, thus extends such a limited requirement of “previous approval” to public servants who are or were in service at the time of the alleged offence. This is in line with the provisions of section 197 Cr.P.C. and the scheme of section 14 of the Lokpal Act.
The proviso to the proposed section 17A (1) is similar to Clause (2) of the repealed section 6A of the Delhi Special Police Establishment Act, 1946 (hereinafter “DSPE Act”) which provided that in certain factual scenarios/gross cases, no sanction/previous approval would be necessary. However, the proviso to the proposed section 17A (1) is narrower than Section 6A(2) of the DSPE Act – now requiring that even if a person is caught on the spot while accepting illegal gratification (“undue financial or other advantage”), it would have to be shown by the prosecution that it was intended that such acceptance consequential to a relevant public function or activity being performed improperly.

 CHAPTER  IV A (As to be introduced by the Bill):
·        CHAPTER  IV A has been proposed to be added in this Act through this Amendment so as to make a provision for attachment of property of any public servant who commits corruption or is accused of the same. The entire chapter constitutes of  Sections 18A to 18N which describes in detail when  such property can be attached along with the procedure. The Indian law commission in its 254 report has summarized this section, reported the drawbacks and has made recommendations which are as follows:
 Provisions regarding attachment and forfeiture have been introduced vide sections 18A-N of the 2013 Bill. However, they are bound to create confusion given that separate procedures for attachment and forfeiture in cases of corruption of public servants are covered under the following three laws:
a. The Criminal Law (Amendment) Ordinance 1944;
b. Prevention of Money Laundering Act, 2002 (“hereinafter PMLA”);
c. The Lokpal and Lokayukta Act, 2013.

 Hence, it might be better suited to replace the proposed sections 18A-18N with a single provision referring to the forfeiture and attachment procedures in the PMLA Act or the Criminal Law Ordinance of 1944. This will ensure our compliance with the UNCAC.
 There may be some  difficulties in the adoption of the PMLA procedure in cases which are investigated and prosecuted by State Government agencies, Ex. State Police, State Anti-Corruption Bureaus etc. It may not be desirable to load the Enforcement Directorate, the Adjudicating Authority and the Appellate Tribunal with thousands of cases under the PC Act all over the country as an exclusive forum for handling matters relating to attachment and forfeiture of property.
 Further, the reach of the 1944 Ordinance is slightly different than that of the PMLA in as much as the Ordinance enables the filing of application for attachment by the appropriate government merely on the belief that any person has committed a scheduled offence and the said person has procured money or other property by means ofthe offence, whether or not any court has taken cognizance of the offence.
 PMLA on the contrary enables provisional attachment where the Director or authorised Deputy Director believes that any person is in possession of any proceeds of crime (not necessarily the person who committed the crime) and such proceeds are likely to be concealed, transferred, etc. which may result in frustrating any proceedings for confiscation of such proceeds. PMLA requires that an order for provisional attachment cannot be passed by the Director or authorised Deputy Director unless, in relation to the scheduled offence, a report has been forwarded to a Magistrate under Section 173 of the CrPC or a complaint has been filed by a person authorised to investigate the offence before a Magistrate or court for taking cognizance of the scheduled offence.
Having regard to these factors, a better option would be to provide for recourse for both the PMLA and the Criminal Law Amendment Ordinance of 1944, whichever may be found most convenient, depending upon the nature of the case. It may, therefore, be desirable to delete the proposed new Chapter IVA and in its place, incorporate a new Section 18A along the lines of the provision made in the earlier Prevention of Bribery of Foreign Public Officials and Official of Public International Organisations Bill, 2011, which was introduced in the Lok Sabha in 2011 but lapsed with the dissolution of the 15th Lok Sabha.
Recommendation: The proposed Chapter IVA should be deleted and be re-cast as follows:
“18A. Save as otherwise provided under the Prevention of Money Laundering Act, 2002, the provisions of the Criminal Law Amendment Ordinance, 1944 shall, as far as may be, apply to the attachment, administration of attached property and execution of order of attachment or confiscation of money or property procured by means of an offence under this Act.”
Consequential amendments will also need to be made to the PMLA, 2002 so as to include all the offences under the PC Act, as now redefined, as predicate offences under the Act by appropriate substitution of Paragraph 8 of Part A of the Schedule to the PMLA.

·        S 19:
S.19 answers the question as and when sanctions are needed to prosecute a public servant. Changes have been made in this section to correspond with changes in other section along with which it is supposed to be read i.e. with S.7, S.13 and S.15 of the Amendment. As per the words in the current section (1) (a) and (b) it states that in case of allegation of  corruption occurring during the course of   public servants either of state cannot be removed on allegation of corruption without he sanction of the respective government but these clauses were unfavorable for the public servants as no sanction was required (As maybe construed from (a) and (b)to remove them when the allegation  was pertaining to a previous employment and that where the nature of their employment had been changed. To safeguard the interest of public servants and that they may merely not be removed from his office based on past allegations the necessary provisions have been made in the amendment by adding the words “or as the case may be, was at the time of commission of the alleged offence employed" in (a) and (b).(1)(c)States that only a competent Authority can pass any such sanctions. But a proviso to this has been added in the Amendment. Which states that only following authorities have permission to request such sanctions:
Police officer, officer of an investigation agency or any other law enforcement authority. Such request must be made to the appropriate Government or competent authority and the conditions in compliance with the sub clauses in the proviso.
However before abiding by any such  request a provision has been made so as to give any such public servant an opportunity to be heard. The proviso also consists of duration and hierarchy of authority for passing any such sanction.
The Subsection (2) which makes provisions with regards to previous sanctions, subsection (3) which deals with the provisions in CrPc which are applicable to this section of the Act and the courts power regarding prosecution without sanctions and (4) talks about erroneous exercising power as in (3). The Amendment has not made any changes in them and they  shall continue to be a part of this legislation.

·        S.20:
S.20 of this Act is about presumption of gratification received the section in the current Act has made differential provisions with regards to such gratification as in section 7 and 11. The current section while making such presumptions relies on S.12 and S.14 of the current Act . But with the Amendment omitting S.11 it become applicable only to S.7 . Besides with the amending of S.12 and 14 they can no longer be read along with section 20 so as to presume receiving of gratification.
The amended S.20 in the amendment  is concise and states that unless the contrary is proved it shall be presumed that the public servant has
violated S.7

·        S.24 (The Bill intends to omit this Section which currently exists in PC Act):
Section 24 has been omitted by the amendment as it is solely required in a scenario where there are no provisions regarding bribe giver but with the amended  S.8, 9 and 10 it is no longer required as it  serves no purpose. Besides the provision in this section provide a loop hole for the bribe giver to escape conviction. The section relies on other sections  but when such other have been amended in the Act  then this section will not comply with those sections so this Section has been deleted in the Amenddment.

§  Besides this the Amendment to PC Act has made provisions to amend  theCriminal Law Amendment Ordinance, 1944, in the Schedule and the DelhiSpecial Police Establishment Act, 1946


.
Summary



The whole amendment can be summarized as follows :
The cabinet  by passing this bill  has acknowledged the fact that it  is no longer true that the bribe giver  is always the victim but with changing times and rapid growth of corporate sector the bribe giver is no longer specifically a victim.
The times when bribery only existed due to the ignorance  of the common man,   are soon coming to an bribe was given to achieve a legal objective that includes basic necessities as the public servants would not do their rightful duty. The PC Act of 1988 was almost sufficient to keep a check and control over such officials but in modern scenario bribes are no longer given as a necessity but to gain undue privileges in this scenario where a public servant does not ask the bribe per se but is offered the same then holding such public servant alone guilty would not be right as per the principle of equality before law as in A.14. The bribe giver or the one who offers bribe is also equally guilty  and he must too be punished . The Amendment in S. 8,9 and 10 of PC Act are amended and S.24 of the Act is omitted with the sole purpose of making the person and commercial organizations liable for their acts of either giving or offering bribes.    The Amendment if passed will remove the drawbacks in the earlier Act one of them being the classification with regards to habitual offenders which will no longer be there once this Amendment is passed. The Act at present relies on imprisonment and fines as a mode of punishment but with the insertion of Chapter IV (A). The court will be able to attach properties of persons in relation of any offences under PC Act once this Amendment is passed. At the Same time provision is also made in the Amendment for protecting the public servants from prosecution when any false allegations are made by amending S.19. Under which provisions are made with regards to procedure which must be followed before any sanction is obtained for prosecution of public.
Like any other legislation this Amendment has some drawbacks but as compared to the current PC Act. This Amendment is the need of the hour and must be passed by the Parliament.





[1][1] http://lawcommissionofindia.nic.in/reports/Report_No.254_Prevention_of_Corruption.pdf
[2]http://www.legislation.gov.uk/ukpga/2010/23/data.pdf
[3]Deans Law Dictionary
[4]S.2(a) of Indian Contract Act,1872









No comments:

Post a Comment