Executive Orders and their Disobedience

This paper appeared in daily The Frontier Post on 19th, 20th, and 21st July 1995

I was thoroughly disappointed, somewhat shocked and confused, to find that I was allocated to the Civil Service of Pakistan, on being successful in the Central Superior Service Competitive Examination of the year 1951.  Civil Service of Pakistan was my last preference, the thirteenth in the order if I remember correctly.  I then realized that the Public Service Commission, and not necessarily the order of merit, finally determined the suitability of a candidate for a particular service.

I was the only one to take up the appointment late, by one day, on October 2, 1951.  In the very first week of our Probation, we were handed over a number of documents, like the Service Rules and Instructions, Government Servants Conduct Rules, etc.  Of these, two documents had an abiding value, as relevant today as they were then.  They remained with me throughout, for guidance always, for solace at times, and as a charter for an executive office.

One of these documents has the title “Quaid-e-Azam’s informal talk to Civil Officers at Government House, Peshawar at 12.15 p.m. on the 14th April 1948”.  It appears, from what is recorded, to be a talk of short duration.  I am reproducing the whole of it as I received it.

“The reason why I wanted to meet you is that I wanted to say a few words to you who are occupying very important position in the administration of Pakistan in this province.

The first thing that I want to tell you is that, that you should not be influenced by any political pressure, by a political party or individual politician.  If you want to raise the prestige and greatness of Pakistan, you must not fall a victim to any pressure, but do your duty as servants to the people and the State.  Governments are formed, Governments are defeated, Prime Ministers come and go, Ministers come and go, but you stay on, and therefore, there is a very great responsibility placed on your shoulders.  You should have no hand in supporting this political party or that political party, this political leader or that political leader – this is not your business.  Whichever Government is formed according to the Constitution, and whoever happens to be the Prime Minister or Minster, coming into power in the ordinary constitutional course, your duty is not only to serve that government loyally and faithfully, but at the same time fearlessly maintaining your high reputation, your prestige, your honor and integrity of your service.  If you start with that determination, you will make a great contribution to the building up of Pakistan, of our conception and our dream of a glorious State and one of the greatest nation in the world.

While impressing this upon you on your side, I wish to take the opportunity of impressing upon you leaders and politicians in the same way that if they ever try to interface with you and bring political pressure to bear upon you, which is a horrible disease for which not only your province but others too, are suffering – if they try and interfere with you in this way, they are doing anything but a disservice to Pakistan.

I hope that each one of you will understand his own sphere of duty and responsibility and act with others harmoniously and in complete cooperation, keeping in mind that each has to do his duty within the sphere to which he belongs.  If you on your side start with the determination and enthusiasm and I hope the other side will also realize what a terrible evil they are raising up and how it demoralizes the services to try and influence this department of that department, this officer or that officer – and if you will stick to your determination you will have done a great service to your nation.  Putting pressure and influence on service people, I know, is very common fault of politicians and those with influence in political parties, but I hope that you will now, from today, resolve and determine to act according to my humble advice that I am giving you.

Everybody should realize that there is a fundamental and vital change of the entire Government and the Constitution under which we are working.  You should try to create an atmosphere and work in such a spirit that everybody gets a fair deal, and justice is done to everybody, and not merely justice has been done to them.  There may be some selfish people – and I know your class is no exception – who think of immediate advantages and work or act for better prospects and so on for themselves, and therefore they describe themselves lover of their province and sometimes they start slogans about outsiders such as Punjabis, Sindhis, or Pathans.  All such things are hindrance and an obstruction in the way of galvanizing the people and welding them together as one great nation.”

The other document described “Precepts based on ‘A HANDBOOK FOR THE NEW CIVIL SERVANTS”’, published by H. M. G. Treasury for the guidance of Civil Servants was a more elaborate document.  I am reproducing portions of it relevant to our present context.

  1. Legally you serve the State, that means, in practice you serve the responsible Minister in charge of your Department, who exercise his powers as a member of the Cabinet, and as the Minister is responsible to the Legislature, you serve the Legislature and hence the whole community.
  2. As a Civil Servant you must never forget that, however well qualified and expert you may become in your job, you have not been elected to it by any vote, and in a democratic country it is the elected representative – the Legislature and the cabinet responsible to the Legislature, and therefore your minister who is a member of the Cabinet – who must settle the lines on which the administration of the community should be carried out in a particular sphere —— Your Minister holds his office because he belongs to the majority in the Legislature which has formed the Government, and therefore what you do must be in accordance with what he wants you to do. After all, he has the job of explaining to the Legislature what you are doing and justifying it.  You must, therefore, serve him loyally to the best of your ability and carry out his decisions and the decisions of senior officers acting on his behalf.
  3. When Changes in Government occur, you might be carrying out measures opposite to those you carried out under an earlier Government. You might think that a civil servant who can do this must be a pretty spineless creature – but this is a wrong attitude.  If you accept that parliamentary democracy is the best form of government you must also accept that public service should be performed in accordance with the wishes of the majority from time to time.
  4. This is the most fundamental thing of all you have to remember – that as a civil servant, YOU ARE THE SERVANT OF THE PUBLIC AS A WHOLE, AND NOT OF ANY SECTIONAL INTEREST. “You must be scrupulously fair, you must be quick, accurate and efficient, you must be courteous to the members of the public with whom you have to deal, and within the limits of your Departments powers, you must be as sympathetic and helpful as possible.
  5. As fresh entrants to the civil service, you may find that the civil service attaches great importance to papers, files, memoranda, and written record of all kinds. A good deal of the work may be done by telephone, where available, or by personal discussion, but you will find that everything important or new has to be recorded on paper.  You may think this as slow and cumbrous way of doing things, but there are several reasons for it.  The first is that under a parliamentary system of government, the legislature has the right to inquire into any action taken by a government department, and a short notice question can be put any time after the event, or perhaps the civil servant who actually took that particular action has retired or has been transferred.  A written record of the action taken and of the reasons underlying the decision is therefore necessary.  Secondly, the written record is necessary to preserve the impartiality of the service.  A Civil Servant cannot, as a private businessman sometimes may, sell at a low price to one customer and makeup by charging a higher price to another; it has to deal with all on the same terms.  There must, therefore, be a written record so that it may be done again in the future when the same problem arises.  This incidentally reduces a number of administrative problems to a set of principles to be followed and avoids chances of whimsical or arbitrary action on the part of the civil servant.
  6. You may find that before a decision is taken, the papers pass through several hands. This may, at first sight, seems cumbrous, but it is bound up with the tradition of impartiality and fairness.  Written records must be carefully examined to see what principles have been followed in similar cases in the past, and a junior civil servant must do this.  Departure from precedence is often necessary, but a decision in such cases has to be taken by the senior and more experienced civil servant.  It is for this purpose that work must pass through a junior civil servant to save the time of the senior civil servant.
  7. You must be precise and honest. You must appreciate the problem before you fully, collect and check up all the relevant facts and set them out clearly and fairly, do not take anything for granted.  There may be more than one point of view and it is dangerous to accept somebody else’s statement without verifying it yourself.  If you see a snag or a difficulty or point which you do not understand, do not ignore it in the hope that nobody else would spot it.  It is your job to straighten it out, or if you cannot, at least to point it out to your Chief and let him deal with it.  Whatever shortcomings a civil servant may have, he need never be found wanting in this kind of honesty.
  8. In dealing with a member of the public or with another civil servant, try to put yourself in the place of the other person and think whether your answer (whether by letter, minute, telephone, or interview) is going to satisfy. Be polite always, don’t be deliberately obscure, if you have to turn down a request, make it clear why you are turning it down.  Do try to explain and give the reason for your decision.  Nothing is more irritating than to be refused and not to know why one is being refused.
  9. Don’t be shy of suggesting ways and means of improving the organization of your job, or doing it more rapidly, or with less effort. You come to it with a fresh mind, and you may have some useful suggestions to make.  But think them over very carefully first and make quite sure that they are improvements and that you have not, through inexperience, overlooked some obvious snag.  Don’t begin to criticize until you have learned the reasons behind the existing method of doing things and don’t assume that every existing method is just red tape.
  10. Many employers ask no more of their employees than that they should do their jobs conscientiously and intelligently, and may feel at first the State as your employer, cannot reasonably ask any more of you. But the State can and must; nobody wants to control your private life for control’s sake or to place unnecessary restrictions on what you do outside office hours. But in order that the public may have confidence in the loyalty, efficiency, and devotion to duty of the public servants, there are some limitations and rules of behavior, which the civil servants must accept not only during the working day but outside it.

This document ends with an extract from Board of Inquiry led by the British Prime Minister in 1928, laying down briefly what the Civil Service traditions should be.  It contains the observation that “The service exacts from itself a higher standard because it recognizes that the state is entitled to demand that its servants shall not only be honest in fact but beyond the reach of suspicions of dishonesty.”

When those of us who had a questioning disposition made inquiries, as to how the conflicting norms contained in these two equally important documents were to be reconciled in practical life, they were invariably advised by those who knew better and had greater service experience, to use tact.  What was meant by ‘tact’ in executive service, none could define, explain or describe.  Any further questions on the subject always made the mood lighter and the subject more elusive.  The impression gained, at least by me, was that ‘tact’ was something, which had to be experienced individually, and even the understanding of it, could not be shared collectively.

The lessons learned during the probation and training were put to the real test as from 17.02.1954 when I received orders of my transfer from the post of Assistant Commissioner, Lahore to that of Sub-Divisional Officer, Rajanpur, then a Sub-Division in District Dera Ghazi Khan.  All those known to me, and others coming in contact with me, sympathized with me on this transfer.  Some thought Rajanpur was in East Pakistan.  All considered it a penal action.  Nobody asked me directly the evil deed for which I was being sent there.  I felt everybody had the question in mind when talking to me on this subject.  Soon I started pitying myself.  On further inquiry, my more senior and knowledgeable colleagues informed me that it was a good training station and very illustrious members of the service had served there.  Surprisingly, and to my great relief, my posting order was canceled on 2.3.1954.  I learned that the reason for it was that I was not acceptable to those who mattered locally.  Another officer was posted there and then another but none of them took charge.  In early May 1954, I once again received orders posting of Rajanpur.  This time, however, I was instructed to see the Chief Minister of the province before leaving for Rajanpur.  I presented myself before Chief Minster.  He informed me that under my charge would be a Sardar (chieftain) whom the Chief Minister considered his elder, respected him, valued his experience and advice.  I should show him consideration and regard.

The journey to Rajanpur was arduous and time-consuming.  The steamer crossing of Indus was reminiscent of steamer journeys too frequently undertaken in East Pakistan.  Once in Rajanpur, I liked the charge.  The place being inaccessible to Supervisory Officers, I had greater independence in discharging day-by-day duties.  The variety of work was remarkable.  The terrain offered much.

Only two Sardars in my Sub-Division called on me as part of the ritual.  To one the Chief Minister had already introduced me.  The other was so old and infirm that he had to be lifted by two persons and deposited on a chair, to be taken away in the same manner, hardly able to hear and understand.  When I was going through the Handing-Over notes recorded by my predecessors I came across one recorded in 1945, nine years before my taking over charge, which read, “Sardar —– is dead.  He refuses to lie down in the grave”.  To my great surprise, the two Sardars with whom I had to deal with on a continuing basis were both keen to get their relatives facing trial in criminal cases convicted by me.  They were not the only ones.  The Sub-Divisional Police Officer, an experienced elderly officer, missed no opportunity of emphasizing the Executive side of my duties.  I told him that in discharging my judicial duties, I considered myself accountable only to High Court and none else.  As soon as I sensed his inability to understand how an officer in the Executive, committed to the executive, having prospects only on the Executive side could subordinate executive consideration in handling Police cases, I stopped explaining to him the rationale of my approach.  I did not enter into any discussion about it.  My difficulty in recording convictions in Police cases was that mostly F. I. R’s were recorded after the recovery of stolen property.  Besides, with only stock witnesses to support the recovery, I always remained in doubt about the involvement of the person put up for trial.  One of my senior colleagues having an unusual interest in the affairs of the district considered me, a hopeless officer of the Civil Service of Pakistan and lost no opportunity of telling so to others whom he met.

I received recognition and support in a very unexpected manner.  By the time I completed one year in the Sub-Division, I was conferred power under Section 30 of the Criminal Procedure Code for the whole of District.  This happened at the behest of the High Court.  It silenced, for the time being at least, my executive-minded critics.  I gained greater confidence.

When the month of November 1954 approached, there was a great pressure on me initially from my office in the form of notes and suggestions, that I should control the prices of charcoal, which was rising sharply.  The suggestion always was that I should pass an order under Section 144 Cr. P. C.  The Order should prohibit the export of charcoal from the Sub-Division.  My inquiries into that matter showed that then Rajanpur produced the best charcoal of ‘kikar’ wood.  It was mostly exported to other parts of Punjab.  To stop its export would have directly hit people locally engaged in that business.  Besides, the order of this nature could be passed only for two months.  It had to be repeated if it was to serve the purpose for any length of time.  The other requirement of such as order is that it should prevent, among others, likely “disturbance of public tranquility, or a riot or an affray”.  None of these factors were at all present to justify an order.  I delayed passing the order.  The Deputy Commissioner’s Office then started reminding me of my duties of controlling the prices and making available the essential commodities at a fair price.  When I further looked up the files I found that every year such an order was, in fact, being passed.  On this occasion, I behaved more like an executive Office and ultimately passed the order.  The same week a bag of charcoal was left at my residence in my absence.  On my inquiry, I was told that the Contractor had, as usual, left it there, without my asking for it, without my requiring it and without asking for payment for it.  I found the entire staff in the offices thereafter satisfied, lavishly warming themselves in ‘kikar’ charcoal fire.  Everyone in the line knows the pittance that was then allowed to subordinate offices in the name of heating and cooling charges.  All those concerned with the passing of the order, its enforcement and supervision, benefited at the cost of the producer and consumer at large.  Not only the entire requirement for the passing of such an order was totally absent, it defeated the very purpose, which it was ostensibly required to serve.

An important lesson of executive service that I learned was that there is an inarticulate, disorganized section of our population whose interests and welfare none but those in power and authority alone can, for the present, best watch and protect.  The articulate section, far smaller, is well positioned, is able to advance its petty interests in the name of, and ostensibly for the benefit of masses.

The other lesson of legal significance that I then learned was that executive power is, in practice, enriched beyond proportion when powers reserved in two separate statutes are so combined as to avoid the limitations and restrictions of both and import the rigor and efficacy of each.  This is impermissible, legally as well as morally.  This is how Section 144 Cr. P. C. is being used for dealing with Essential Commodities for which a separate efficacious law already exists.  That is how judicial power is combined with the executive power to enrich the amplitude of Executive Power.

In the year 1957, I happened to be posted as Deputy Commissioner Bahawalpur.  One of the main trains running between Lahore and Karachi used to stop at Bahawalpur Railway Station at midnight.  A series of robberies of passengers alighting from the train and on way to their homes started taking place.  We were really alarmed at the frequency and the manner it was taking place.  At the suggestion of Superintendent Police, I directed under Section 144 Cr. P. C. closure of cinema houses at midnight.  There was no abatement.  The closing time of cinemas was reduced to 11.30 p.m. but again with no improvement.  The S. P. was transferred and a young open-minded officer took over.  I put him in the picture and pointed out the helplessness of the administration.  Within a month he apprehended red-handed four of his own policemen belonging to that very Police Station which was supposed to guard the route, involved in the robberies that were being committed.  That was a situation where orders passed by me under Section 144 Cr. P. C. protected more the criminal than innocent.

In Bahawalpur district, there were a few Government owned fish reservoirs.  The right of fishing therein was seasonally auctioned.  The auction purchasers came mostly from outside the district.  On one occasion in 1957 the Commissioner insisted that I should control the prices and distribution of eatables including fish within the district by passing an order under Section 144 Cr. P. C.  I did that.  Two things happened thereafter.  Those in business went on strike making fish unavailable throughout the district.  The second was that my order was immediately challenged in the High Court.  Governor, then West Pakistan, visited Bahawalpur during this period of the strike.  Commissioner Bahawalpur invited him to dinner.  In my presence, he twice apologized to the Governor that he could not serve fish on that occasion, on account of the strike that had taken place due to the order under Section 144 Cr. P. C. passed by me.  I could not gather whether I got credit or discredit for it and from whom.  The High Court quashed my order in no time because availability or non-availability of fish could not lead to a law and order situation in a place like Bahawalpur.  Yet another lesson of the executive service that I then learned was that one should lose no opportunity of taking credit even when no credit is due to him and should be prompt enough to pass the blame to someone else who is not necessarily blameworthy.  I understood fully, the implications of the saying that ‘success has many fathers and failure is an orphan’.

An order under Section 144 Cr. P. C. can be passed only for

(i) Prevention of obstruction, annoyance or injury, or risk or obstruction, annoyance or injury to any person lawfully employed or

(ii) Prevention of danger to human life, health or safety, or a disturbance of the public tranquility, or a riot or an affray.

The violation of such an order is punishable under Section 188 P. P. C.  The important point to note is that violation of the order per se is not punishable.  The person violating it must have knowledge of it.  What is more, the disobedience should be such as to cause or tend to cause any of the consequences described in clauses (i) and (ii).  In case the disobedience results in a consequence described in clause (i), the punishment prescribed is up to one-month simple imprisonment, or with fine of Rs. 200 or with both.  The disobedience falling in clause (ii) is punishable with simple imprisonment up to six months or with fine, which may extend to one thousand rupees or with both.  This offense is ordinarily bailable and non-cognizable.  No proceedings for violating such an order can be initiated except on a complaint of the officer passing the order, or his superior.

The thought, the wisdom and the experience that had gone into the framing of this law and the protection provided therein were made clear by the framers of the law in the words following (Law of Crimes by Ratan Lal et al):

“We see some objections to the way in which we have framed this part of the law, but we are unable to frame it better.  On one hand, it is, as we have shown, absolutely necessary to have some local rules, which shall not require the sanction of the legislature.  On the other hand, we are sensible that there is the greatest reason to apprehend much petty tyranny and vexation from such rules, and this although the framers of those rules may be very excellent and able men.  There is scarcely any disposition in any ruler more prejudicial to the happiness of the people than a meddling disposition.  Yet, experience shows us that it is a disposition, which is often found in the company with best intentions, with great activity energy, and with a sincere regard for the interest of the community.  A public servant of more than ordinary zeal and industry, unless he has very much more than ordinary judgment, is the very man who is likely to harass the people under his care with needless restrictions.  We have, therefore, thought it necessary to provide that no person should be punished merely for disobeying a local order unless it is made to appear that the disobedience has been attended with evil or risk of evil.  Thus no person will be punished for disobeying an idle and vexatious order.”

There were in fact two legal protections against orders passed under Section 144 Cr. P. C.  One, as pointed out by the framers of the law that the Courts were to ensure that the punishments followed only when violation entailed danger to human lives, health or safety, or a disturbance of the public tranquility, or a riot or an affray.  Secondly, the violator of such an order could be prosecuted in Court, only and only on a complaint recorded and submitted for trial to the Court by the officer passing such an order or his superior, [Section 195(a) Cr. P. C.].  Before drafting such a complaint, the officer concerned had to apply his mind to determine whether it was a mere violation of the order or a violation attended with the evil consequences mentioned in the law.  Even in the latter case, the officer was not obliged to file a complaint.  A very illustrative instance of this power having been exercised tactfully and beneficially has been described in some detail by a very able and distinguished officer( Ghayasuddin Ahmed DM Allahabad) in his reminiscences published in the form of a small book in Urdu at Page 72.  On that occasion, the District Magistrate not only promulgated an order under Section 144 Cr. P. C. but saw to it that it was violated per se, in the letter, but not in spirit.

Near about 1932, the subcontinent experienced disturbance of public peace and turmoil on large scale.  A law was then enacted (Act XXIII of 1932) authorizing the provincial governments to make, by notification in the official Gazette, among others, the offense under Section 188 P. P. C. cognizable and non-bailable.  The Government of West Pakistan invoked this provision, issued two notifications 14.03.69 and made the offense under Section 188 P. P. C. cognizable by the police and non-bailable.  What is alarming is not that such notifications were an issue in the middle of March 1969 but that they have remained in force, throughout Pakistan since then, unnoticed, unchallenged.  In one sweep all the protections envisaged by the makers of such an unusual law have disappeared giving strength to the raw power of the police.

In April 1975, as a High Court Judge, I was inspecting the District Courts.  It was the Court of Sub-Divisional Magistrate.  I found among pending cases, a case U/S 188 P. P. C. registered with the police on 31.05.69, complaining that the harvested produce was laying at the spot but the tenant was not giving landlord’s share out of it.  The prohibitory order in force at that time directed “no tenant shall remove wheat, barley, gram and other crops from the spot where the aforesaid crops have been harvested before handling over the lawful share of the landlord concerned or his duly authorized agent.  The tenant was arrested on 14th of June 1969 and was soon thereafter released on bail.  The challan was submitted.  The accused appeared in Court on 15th August 1969 for trial.  During the six years that the case remained pending, it came up for hearing on one hundred and twenty dates.  On thirty dates of hearing the presiding officer was absent or was attending the other duties.  On four dates, the accused absented himself.  Two witnesses were examined on 22.10.69 and one more on 13.07.72.  The three official witnesses, the Tehsildar, one Head Constable and the investigating officer had not appeared though three hundred and fifty summonses had been issued to them for attendance during this period.  The prosecution evidence was closed three times and every time restarted without giving any reason.

This case has not left haunting me.  To date, I have found no satisfactory explanation for such a massive and pervasive failure of the system.  The police officer registering this cases failed to notice that on facts stated no case was made out for even registering it as such.  The prosecutors handling the case in Court on these hundred and twenty dates of hearing and earlier failed to notice the futility of the trial.  The Readers of Sub-Divisional Magistrate, who are usually very experienced officials, failed to attend to the material aspects of the case.  The lawyer defending the accused, at no stage attended to his duties.  The Presiding Officers of the court, both of the provincial and the central service never applied their mind to the case.  The only reason that can partly, though not satisfactorily, explain this state of affairs is that within the District everyone was wary of dealing with the alleged breach of an Order passed in the name of the District Magistrate or the Sub-Divisional Magistrate.  I had not till then experienced a more illustrative case of the oppressiveness of the judicial process at the hands of the Executive Officers.

The irrationality of the Orders passed by taking recourse to Section 144 Cr. P. C. always irritated me after 14th of March 1969.  The orders always had a wide range.  For example, preventing a sugar cane grower from making ‘gur’ out of the sugar cane grown by him.  Fixing the price of buffalo milk, leaving untouched the milk sold in cartons, banning kite flying till it became fashionable and prestigious and Lahore and Bhurban appeared on the map of national international kite-flyers.

An amazing order came to my notice in January 1994.   It was published in the English newspapers on 21.01.1994.  A Sub-Divisional Magistrate had prohibited under Section 144 Cr. P. C. ‘operation of photostat machines in the city from 08 a.m. to 12 noon and from 2 p.m. to 5 p.m.’ This order was to remain operative till January 31st.  No reasons were disclosed.  Subsequently, I learned that it was an attempt to stop the photocopying of examination question papers, which leaked.  Everyone concerned with the enforcement of law knows that there is a self-contained and effective law against malpractice in the examination.  It only requires sound homework before resorting to it.  Such vexatious and idle orders could be tolerated and even totally ignored if the two pristine protections already noted had remained intact.  After the offense became cognizable and non-bailable, such orders became highly oppressive, manipulative and unguided in the hands of Executive and Police Officers.  This is reflected in a new item published in an English daily on 16.05.1994.  It reads as follows, “The pillion-riding ban violation will be a non-bailable offense under Section 188 Cr. P. C.” (Actually it should be P. P. C.) “It has also been learned that the administration will accept bail in these cases only after the lapse of three days”.

A foreigner on a visit to this country showed interest in the carpet industry, equipped with a video camera and escorted by a Magistrate, he visited one such factory.  He found three hundred children employed there, all appearing on the videotape.  A human right activist, on the basis of these facts and the videotape, instituted proceedings directly in the Supreme Court.  Before the proceedings could take off, his brother was prosecuted for violation of an order passed under 144 Cr. P. C.  This order was promulgated just few days before, and required pesticide and fertilizer manufacturers and distributors, dealers and retailers to do as many as fifteen different things, regulatory of their entire business, like ensuring the purity of their product, maintaining of their stock registers and registers of sale, issuance of receipts and exhibition of price lists.  The brother, it appeared, was in the fertilizer business.  The department overseeing the employment of children in carpet industry reported to the Court that it considered that carpet industry to be a family enterprise, which is exempted from prohibition, contained in the law with regard to the employment of children.  This case was awaiting decision when I left.

In the matter of form, I equate this power of the District and the Sub-Divisional Magistrate with the Ordinance making the power of the President and the Governor with the exceptions that there is no substantive sting in it but it has far more oppressive and inhuman procedural fall-outs after the notifications dated 14.03.69.  Coupling such a power with judicial power leads to outright tyranny and widespread corruption in the society, directly touching a large section of the public, not so organized and articulate.