(Sample Material) Gist of Important National Administrative Committees Report Study Kit: "Ethics, Integrity and Aptitude"

CHAPTER - ETHICS, INTEGRITY AND APTITUDE
Paul Appleby Committee Report on Public Administration in India(1953)

IRREGULARITY AND CORRUPTION

“The extent to which there is graft or corruption is wholly within the responsibility of ministers”, one eminent and intelligent official said to me here. Perhaps I define graft and corruption more broadly
than he used the words in that conversation, but I find it impossible to agree with him. It is true, of course, that each minister sets a tone, good or bad, that has a penetrating effect on his subordinates. A decision by a minister, overruling subordinate recommendations and seeming simply to favour some particular citizen at the expense of the general public, does demoralize staff and invite other acts of favouritism. An exacting minister who investigates insistently anything that has, the appearance of wrong-doing guides administration in ways of rectitude far beyond the scope of his particular efforts. Yet it would be a serious evasion of official responsibility and a gross understatement of the importance and scope of administration to dismiss the subject there.

A minister can determine any particular action, but no minister can or does come close to determining all actions; and what the minister does not determine, the administrative personnel do. The administrative personnel have, in addition to their personal integrity, at least two relevant technical responsibilities. One is for creating organizational structures that minimize opportunities for dishonesty and favouritism and maximize probabilities of propriety. The other is for procedures that serve the same ends. In time, if not under a particular minister or at a particular moment, such structures can be set up, such procedure installed.

The simplest kind of structural protection is a division of functions and responsibilities so that favouritism requires not merely one employee willing to do the wrong thing, but conspiracy of a number of such persons, preferably in a minimum of three different organizational units with differentiated responsibilities and lines of review. Conspiracy is more difficult to achieve and to keep secret than wrong-doing by a single individual. Where those involved are in different hierarchal units, if one line of review does not sense that something is wrong, another is likely to do so. A very concrete example would be in the matter of disbursing public funds. No one person, and no one organizational unit, should have simultaneous responsibilities for certifying a payroll and receiving and distributing pay-checks. This should apply equally to other disbursements. Here I am told that the ministry making a purchase sometimes receives and mails out the check in payment.

A more complicated and complementary structural device is to have programmatic operating agency hierarchies paralleled by another hierarchy charged with checking that operation-thoroughly and at all levels. I found such structures on some of the big construction projects, where engineer-administrators had made the arrangements, and I found an excellent example in Bombay state, where the tax collecting organization was paralleled by an administrative investigational staff constantly scrutinizing the whole operation, going in teams of six from office to sub-office. Here I find an extraordinary degree of reliance placed on auditing and account ing , which are quite pedestrian, although necessary, functions.

Auditors and accountants cannot discover much of importance about the administrative process-especially when their work is done on a government-wide basis. The same functions need to be performed
by the administrators themselves for elementarily good management, and will reveal more to them than to a general auditing organization- but not nearly as much as the administrators need to know.

A petty example of fraud observed at a railway station illustrates in the very simplest terms the shortcomings of mere auditing. A purchaser of a platform ticket was given an undated ticket. He was passed through the gate without his ticket being torn in two as is required, and when he left the platform his whole ticket was taken up, ready to be returned to the ticket booth and resold. Here is a simple case of collusion between a ticket-seller and a gateman. Such things can be reduced in frequency by the systematic use of “spotters”, but perhaps the simplest and most effective prevention would be through installation of automatic coin-turnstiles. Not to use adequate preventive methods is to subject employees to unnecessary moral overstrain and to demean government and the public service.

Contrasting with the quotation with which this section was introduced is a statement from another eminent and experienced civil servant. He said:

“Leakages in the collection of taxes may occur as amount under collection due through collusion with the persons liable to tax, through under-checking or inadequate checking of the returns on which demands are built up, and through negligence in the checking of the accounts rendered by the tax collection agencies, thereby facilitating embezzlements. The evil exists on a fairly considerable scale and due to all three of these causes in varying degree. I should think on a very rough guess that the total amount of leakage in all sources may be 15 per cent. of the amount due.”

If this man’s estimate were to be halved it would still represent too substantial a sum. Worse, it would reflect a squandering of the nation’s “moral capital”. The laying down of detailed instructions will not meet the need. To have through structural arrangements units of adequate size and quality whose only excuse for being is in systematic review of the actions of other units, and to divide operating functions in ways making collusion difficult are two basic preventives. Hospitality to reports of irregularities, real or apparent, prompt and sufficient penalties for wrong-doing, and constant attention are also essential. Measures also should be taken to protect employees who inform on associates from subsequent vinditictiveness of superiors who had been embarrassed by the disclosures. Both in the provision of a strong unit to check on tax collection and in the vigorous activities of a special anti-corruption unit, the state of Bombay has given an outstanding example of good performance. There a principal source of corruption remains in prohibition enforcement. The anti-corruption activity in Mysore and Bengal also should be mentioned favourably, although the latter seems to have displayed less initiative and perhaps has followed through less vigorously.

The areas of administration most needing attention as most susceptible to perversion are those where money or documents of monetary implications are handled. The latter include requisitions for supplies, material or other purchases, payrolls, licenses, permits, contracts, and procedures with respect to violations or evasions of law, permits, contracts and the like. As a general rule, no two persons and no two units should have complete control of actions or all of the papers involved in such matters. Even ministers, with their inevitably final powers, should have the frank and critical guidance of units competitively responsible in different functional respects.

In view of structural and procedural defects and the very low rates of pay for most subordinate employees, the general situation appears to be surprisingly good. This would indicate that the shortcomings are not attributable to any low state of personal integrity. On the contrary, my impression is that the people here are rather more than ordinarily honest. The shortcomings are, of one sort, attributable to political inexperience, and, of another sort, to inadequate institutional arrangements. Too often there is little basis for evaluation of performance aside from simple level-to-level assurances that “there is little wrong-doing in my organization”. I should think that the government’s widest single area of vulnerability, in both the states and the Centre, is in the imperfect and belated levying and collection of taxes. This is not in the first instance corruption, but it is a condition that encourages tax evasion by citizens and invites corruption within the government. The faults are in part with existing statutes, in part with legislative reluctance to provide funds, and in part strictly administrative.

The bureaucracy has an obligation to insist more strongly on provision of adequate facilities in law and personnel resources. It has an obligation to perfect and energize existing facilities. It should be understood by citizens that a considerable part of the slowness they attribute to governmental action is caused by concern within the government for acting properly. Some quite urgent business has been much slowed up because of past instances of wrong-doing in matters of the same sort. This should all be taken as indicative of a responsible concern for honesty and fair-dealing. At the same time, the government has an obligation to use ingenuity in devising simpler ways of insuring against venality. All in all, I believe that the general judgment I have expressed about the quality of the government of India applies in respect of honesty. This is to say that India is one of the dozen or so governments in which honesty has been carried to its highest levels.

Moral concerns of democracies are much more numerous, more subtle and more refined than may be found elsewhere, whether historically or in currently alternative forms; practice among democracies has been greatly elevated during the last century as attention and learning have shown the way. Yet in all nations it is an enduring problem, with performances varying by agencies, jurisdictions and levels of government, by the nature of governmental functions and according to variations in social values. In other words, there are places within any government where improvement is badly needed. Here the general line of improvement points to need for administrative ingenuity in developing more intra-ministerial checks, more checks during and after performance by separate units, and less inter-ministerial check antecedent to action, and toward more adequate intermediate personnel capable of assuming responsibility for action and for checking upon action.

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