INDIVIDUAL RESEARCH PAPER

33rd SENIOR MANAGEMENT COURSE

(SMC)
Comparative analysis of NAB and FIA laws/acts with regard to
corruption: Gaps in legislation/implementation and Way
Forward
NATIONAL INSTITUTE OF MANAGEMENT, PESHAWAR

By

MASOOD NASEEM (FIA)

A paper submitted to the Faculty of the National Institute of Management (NIM),
Peshawar, in partial fulfilment of the requirements of the 36th Mid-Career Management Course.
The paper is the end product of my own efforts, research, writing and its contents are not
plagiarized. The paper reflects my own views and is not necessarily endorsed by the faculty or
the NIM.
Signature: ………………
Date: 2023

Paper Supervised by:

 D.S Mr. ZIAULLAH SHAMS

Table of Contents Page

INTRODUCTION
Statement of the Problem
Objectives of the Study
Research question
Significance and Scope of the Study
LITERATURE REVIEW
Methodology
Organization of the Paper
SECTION-I: Brief Overview of the Corruption
1. Index of Corruption
Corruption Formula
Types of Corruption
Corruption Definition
1.5 Corruption in Pakistan
1.6 Corruption in India
1.7
SECTION-II: Anti-Corruption Laws
2.1 Anti-Corruption Laws in Pakistan
2.2 Anti-Corruption Laws in India
SECTION-III: Investigation Practices
3. Investigation Practices in Pakistan
FIA
NAB
ACE
Investigation Practices
Identification of Key Challenges
3. Investigation Practices in India
3 CI
Investigation Practice
Identification of Key Challenges
Comparative Analysis
Conclusion
Recommendations
 Glossary
ACA Anti-Corruption Agencies

ACE Anti-Corruption Establishment

AMLA Anti Money Laundering Act

FIA Federal Investigation Agency

NAB National Accountability Bureau

CBI Central Bureau of Investigation

SFO Serious Fraud Office

IPC Indian Penal Code

PPC Pakistan Penal Code

NAO NAB Accountability Ordinance

Cr.PC Code of Criminal Procedure

PPC Pakistan Penal Code 1860

PCA Prevention of Corruption Act 1947

PMLA Prevention of Anti Money Laundering Act 2002

SECP Securities and Exchange Commission of Pakistan

UNCAC United Nations Convention against Corruption

INDIVIDUAL RESEARCH PAPER ( IRP)

 a) Statement of the problem
The key principles of good governance are transparency and accountability. Despite of anti-graft
bodies at federal and provincial levels, the position of Pakistan has not improved. According to
the 2022 Corruption Perceptions Index reported by Transparency International, Pakistan has
been ranked at 140th corrupt nation out of 180 countries. Despite of special accountability laws at
federal and provincial levels, its position could not be improved. In spite of the legal and
institutional framework, Pakistan could not succeed in curbing corruption within the public and
private sectors. The genesis of this evil came from weak institutional mechanisms, political
instability, flawed legislation, untrained investigation agencies, and a less independent judiciary.
These statutory gaps create obstacles in the implementation of legal instruments in their true
perspective. The low conviction rate raised the level of corruption in the masses which needs
immediate redressal. Some key change in the anti-corruption strategy is the need for time. This
paper aims to find out the legislative gaps in our accountability laws in order to improve the
efficacy of these instruments and also suggest a way forward with tangible recommendations.

b) Scope of the study:

The scope of this paper is to critically analyze the statutory gaps which hinder the true
implementation of accountability laws of the premier agencies of Pakistan

c) Outline:

Title Page

Preface:

Executive Summary:

Glossary of terms:

Table of Content:

Introduction:

Statement of the Problem:

Significant and Scope of the Study:

Research Methodology:

Analysis:

Challenges:

Conclusion

Recommendations:

References:

Bibliography:

Name: Masood Naseem

Ex-cadre FIA

Name of DS: Sir Ziaullah Shams