Whistleblowers Protection- Scenario In India In Light Of The Whistleblowers Protection Act, 2014 by - Gaganjot
Whistleblowers
Protection-
Scenario
In India In Light Of The Whistleblowers Protection Act, 2014
Authored by - Gaganjot
BA., LL.B. (Hons.) 5th year
School of Law, Lovely Professional University,
Phagwara.
Mob. 9501538787
ABSTRACT
The
phrase “Satyameva Jayate” meaning- ‘Truth alone triumphs’ is a kind of mantra
which is followed by the people of India when it comes to decide any
matter. The basis of the Indian
judiciary is also the same. But when it comes to the practical implementation
of this, we’re somehow lacking into this and are still unable to ensure proper
transparency and accountability of the government and its policies in India. We
all know that the height of corruption and other unfair activities into the
governmental offices is so high that if we try to measure it, we could not even
do that because the corruption rates are so high and unmeasurable. Not only
into the governmental but also into the non-governmental offices, the
corruption is at peak and there’s not much differences between the both. Any
person who tries to speak up or blow a whistle against such illegal activities
is being suppressed by the people in power. To ensure that the whistleblowers
do not get into any trouble for standing beside the truth, the Indian
government need to take strict legislative actions in order to ensure
transparency and accountability into the system.
In
this paper, we’re going to cover the concept of whistleblowing, the Indian
scenario of whistleblowing, modes of whistleblowing, situation before and after
the Whistleblowers Act, 2014 came into picture, what is the standing of the
Whistleblower law in India and the features of this law, landmark judgments on
the Whistleblowers and the judiciary’s views onto it, shortcomings/loopholes of
the Whistleblower law and the suggestions would also be shared at the end of
this Research paper as to what steps could be taken by the government to
improve the Whistleblowers law in India.
Keywords- #Whistleblower #Laws #Government
#Corruption #Accountability #Transparency #Truth
-Dr. A.P.J. Abdul Kalam
INTRODUCTION
I speak about the
Divine Truth, I speak about the Absolute Truth,
May That Protect Me,
May That Protect the Preceptor,
May That Protect Me,
May That Protect the Preceptor.
Every organisation
expects from his employees the honesty and truthfulness towards his duty. These
are the natural and moral ethics as well as commanded by the law which ought to
be followed by each and every person while discharging their duties. But, our
duty not only ends till our honesty towards our work/ profession. We have some
other duties as well which needs to be followed other than the truthful work.
Other than that, we also have the duty to report the wrong things or wrong work
ethics followed by some other people in the organization which not only
deteriorates the working environment, but also is damaging the reputation of
the organization and ultimately causing a huge loss to the country as well. The
major source of this is corruption because people are running behind the money
like blinds.
So, Whistleblowing is a
mechanism which promotes transparent structure and effective and clear
communication. This whistleblowers protection law was highly needed in India
because unfortunately in India, the percentage of the people who pays bribe is
51%[1].
Although, in the year of 2018, the corruption rate of India was overall 58% and
it fell to 51%, but still it is a huge number and to prevent this also, a
series of laws are required and are needed to be strictly implemented.
Whistleblowing law
introduced in 2014 is also indirectly affecting the rate of corruption which
would contribute in reducing corruption rate in India.
Before proceeding
further, let’s get to know the concept of Whistleblowing in detail-
What is Whistleblowing?
It’s the disclosure of
TRUTH against misconduct, wrongdoing, unethical activity which is going on
within Public, Private or Third-Sector organisations.
Definitions of Whistleblowing
·
United Nations Convention against Corruption (UNCAC)[2]
defines Whistleblower as-
“Any person who reports in good faith and on
reasonable grounds to the competent
authorities any facts concerning offences established in accordance with
this Convention.”
·
International Labour Organisation
(ILO)[3]
defines it as-“The
reporting by employees or former employees of illegal, irregular, dangerous or
unethical practices by employers.”
·
Koehn (2003)- “Whistle Blowing occurs when an
employee informs the public of inappropriate activities going on inside the
organization.”
·
The Council of European Civil Law Convention on
Corruption[4]-
“Employees who have
reasonable grounds to suspect corruption and who report in good faith their
suspicion to reasonable persons or authorities.”
·
Section 3(c) of the Whistleblowers Protection Act,
2014-
A Whistleblower or a
Complainant means any person who makes a complaint
relating to disclosure
under this Act.
Types of Whistleblowers
Ø Internal- When
the whistleblower discloses the illegal misconducts or wrong doings to the
higher officials in the organisation itself, this is called Internal
Whistleblowing.
Ø External- When
the misconduct is reported to the authorities which are not the part of the
organisations and the people who are outside the organisation, when the matter
is reported to them then it refers to as
External Whistleblowing.
Ø Alumini- When
the former employee of an organisation reports the matter, it refers to as
Alumini Whistleblowing.
Ø Open- When the
identity of the Whisleblower is not kept secret and is kept open, then it’s the
Open Whistleblowing.
Ø Personal- When
the misconducts of an organization or a person is to harm one person only, then
it becomes Personal Whistleblowing.
Ø Impersonal-
When wrong activities are done to harm multiple people, it is Impersonal
Whistleblowing.
Ø Government-
When the wrong activities/ misconducts adopted by the Government Officials are
disclosed, it is Government Whistleblowing.
Ø Corporate-
When the whistleblowing is about the wrong activities done in a business
corporation, it’s called Corporate Whistleblowing.
OBJECTIVES OF THE STUDY
ü To find the major causes which lead
to enact a specific law for the Protection of the Whistleblowers.
ü To gather data from the Primary and
Secondary sources which corroborate the concerning issue.
ü To thoroughly analysis the data
obtained and provide appropriate suggestions.
RESEARCH METHODOLOGY
The research methodology
which is being used for the preparation of this Research Paper is Doctrinal
Research. The data gathering and identification of the concepts is done with
the help of Primary and Secondary sources which includes-
·
Library
sources/ Reports/ Internet Sources.
·
Case
Laws/ Judgments.
·
Propositions.
·
Case
Studies.
The data is analyzed by
grouping the information on the basis of its collection and testing it to a
tentative conclusion. The adequate analysis is framed after collecting the
appropriate data on the concerned research topic.
IDENTIFICATION OF PROBLEM
The Governmental,
Non-Governmental and the Corporate Structures are assumed to be as big entities
which carry on huge businesses/ works. So, in exercise of their authority, they
have been provided with the wider powers which causes complicated mechanism of
governance of an organisation. So, this is most common with these kinds of
entities that in the desire of more and more wealth, they use unfair means and
follow corrupt practices in order to get more richer faster. These kinds of
practices are not in harmony with the public interests as these kind of
activities could actually bring great losses to the government and ultimately,
to the country as well. And, in India, we could see these kinds of corruption
practices and scams casually. The lust of money has resulted into murders of
many people who tried to disclose these scams and there are many landmark cases
which are directly linked to these practices only which would be discussed
further in this research.
Due to all these incidents and cases arising
out, the Parliament of India felt a great need to enact a law which could
really help out and protect those which actually wants to be honest with the
nation and who cannot see the scams happening right under their nose and as a
consequence, they expose these scams.
SCENARIO IN INDIA
This point cannot be
doubted upon that India needs a strict and effective Whistleblowers Protection
Law urgently which actually ensures transparency and accountability in the
system while elimination the menace of corruption side by side. Other than the
statutory enactment, the following could be considered as the modes of
Whistleblowing-
Modes of Whistleblowing
Basically, there are two
main modes of Whistleblowing perataining to the Indian pretext which can be
categorized under the following groups-
A.
The Traditional methods of
Whistleblowing are as follows-
i.
The Constitution of India.
ii.
The Statutory Enactments.
The Constitution of India- The Whistleblowing under the ambit of
the Indian Constitution could be done through the instrument of PIL i.e. in the
form of Public Interest Litigation. “PIL or Public Interest Litigation” is a
Socio-Justice tool through which the aspirations of the Constitution itself as
well as the common public are achieved.
Ex. In
the famous case of S.P. Gupta v. Union of India[5],
Justice P.N. Bhagwati became the torchbearer of Public Interest Litigations and
observed that-
“Where
a legal wrong or a legal injury is caused to a person or to a determinate class
of persons by reason of violation of any constitutional or legal right or any
burden is imposed in contravention of any constitutional or legal provision or
without authority of law or any such legal wrong or legal injury or illegal
burden is threatened and such person or determinate class of persons by reasons
of poverty, helplessness or disability or socially or economically
disadvantaged position unable to approach the court for relief, any member of
public can maintain an application for an appropriate direction, order or writ
in the High Court under Article 226 and in case any breach of fundamental
rights of such persons or determinate class of persons, in this court under
Article 32 seeking judicial redress for the legal wrong or legal injury caused
to such person or determinate class of persons.”
The Statutory
enactments- The
Indian statutes like The Indian Penal Code, 1860[6],
The Code of Civil Procedure, 1908[7],
The Code of Criminal Procedure, 1973[8],
The Indian Evidence Act, 1872[9]
etc. Could be sought for help against any kind of Civil or Criminal wrong
committed against a person if he/ she blows the whistle and discloses the
malpractices and due to that if any kind of loss caused to a person.
B.
The Cotemporary Modes
As we know that today is
the modern era of Internet and Technology. So, by utilizing this facility, an
effective Whislteblowing could be done and it would be having a low risk also
because people will get to know about the activities of the officials they
those people will have fear of harming the Whistleblower also. Also, with the
enactment of the Information Technology Act, 2000[10],
more transparency and accountability is expected from the government officials.
This act also facilitates
e-governance by accepting electronic records and digital signatures in the
government offices and its agencies.
Due to this, the
authorities will have the fear in their minds also before committing any kind
of scam because everything and every record is on the internet now-a-days. This
will make the government offices hassle free and will promote transparency
within the administration.
The Concept of
Information and Communication Technology has been beneficiary to the general
public for the following purposed
SITUATION BEFORE THE ENACTMENT OF THE
WHISTLEBLOWERS PROTECTION ACT, 2014
The Constitutional Law of
India has placed the status of a Public Office at a high level and provides it
with a great duty of trust and fiduciary duty towards the people. But
unfortunately, even after the presence of the highest Grundnorm which itself
specifies the duty of public and other offices towards the public good, they
themselves commit the malpractices which gives rise to higher number of crimes.
No matter whatever
guidelines are issued to the public authorities, there would always be the
presence of maladministration in these departments in one way or the other as
the corruption is omnipresent everywhere now even after taking so many
measures.
The number of wrongdoers
is so huge that the people who want to be honest and doesn’t tolerate the
things like corruption and other malpractices, can’t fight alone with that big
bunch because ultimately it causes threat to their life as well. So, to ensure
transparency in the system and to empower the watchdogs of the democracy and
the administration in India, a strong legislation was required from the side of
the Indian Parliament to the citizens so that when they disclose the scams of
authorities, they could have some sort of protection with them also and which
can protect them from danger to their life, loved ones and their property.
CASE LAWS ON WHISTLEBLOWERS
(A brief glimpse of landmark cases which emerged out a great
need to enact a particular statute pertaining to the protection of Whistleblowers
in India)
Satyendra Dubey Case[11]- Satyendra Dubey was an Indian
Engineering Services officers. He was being deputed as Project Director of
Golden Quadrilateral Corridor Project of NHAI (National Highway Authority of
India)[12].
When he was appointed there, he saw many financial irregularities there. When
he investigated the matter he got to know that the Construction Companies are
bending the rules for their own profit.
It was a large scam and
there was use of worst quality material and in this scam, many big politicians
were also involved. He then thought to write a letter to Prime Minister Atal
Bihari Vajpayee detailing the financial and contractual irregularities in the
project. Even after making a direct request that his identity would be kept
confidential due to letter’s sensitive content, the letter, despite reaching to
the PMO office, it directly forwarded to the Ministry of Road Transport and
Highways along with his bio-data also due to which his identity revealed which
forwarded this letter to the Deputy head of this project which made allegations
on Dubey for the mistake of writing this letter directly to the Prime Minister.
After this, Dubey started remaining tensed and ultimately on Nov. 27, 2003, he
was shot dead.
Murder of Social Activist Satish Shetty[13]- Satish Shetty was a Social Activist
who lodged a complaint against IRB officials- A Mumbai based land developer who
used forged documents to deceitfully grab over 85 hectares of the state-owned
land which was kept for constructing Mumbai-Pune Highway.
On the date of October
15, 2009, he filed a cheating case in Lonavala Police Station alleging 13
officials in this case. It was only about 2 and a half months were passed and
Shetty was brutally killed outside his house. After that, a CBI committee was
established to enquire into the matter who filed a closure report after 7 years
of this incident.
Killiing of Karnataka IAS Officer Anurag Tewari[14]- Karnataka Food and Civil Supplies
Commissioner was an IAS officer who was died unnaturally and under mysterious
circumstances. His dead body was found in Lucknow and he didn’t die because of
natural causes. His family had said that Anurag had came to know about a
serious scam worth thousands of crore rupees in Karnataka Government. He was
finding and collecting the evidences to expose them with cogent evidences but
before doing so, he died. Also the autopsy report also revealed that his death
was unnatural as there were scars of assault on his body.
Murder of RTI activist Lalit Mehta[15]- Lalit Mehta was an RTI activist who
worked for National Rural Employment guarantee programme.
He came across social
audit of NREGA (National Rural Employment Guarantee Act, 2005)[16].
While conducting the social audit, he came to know that there’s huge amount
given to the authorities for the appropriate implementation of this act at the
grass root level for the employment of the rural people.
He found that the data
which they were having was showing much more number than the actual number of
the people employed. Also, the forged
signatures of the innocent villagers were taken and the job cards were issued
even in the names of the persons who either already had a job with them or the
persons who were already died. This was all done to maintain a fake employment
record and to swallow the huge amount given to them by the government for
effective implementation of the act. One day, he was also brutally stabbed to
death.
SITUATION AFTER THE ENACTMENT OF THE
WHISTLEBLOWERS PROTECTION ACT, 2014[17]
BACKGROUND OF THE ACT
We have seen that there
are many cases emerged in India which have brought the focus on Whistleblower’s
safety in India. Approximately all of those cases were related to the
misconduct of corruption either directly or indirectly. So, in order to remove
the discrepancies and to bring uniformity within the system, the Legislature
was compelled to bring such law which would be specifically drafted for the
whole and sole purpose of protecting the Whistleblowers only. But, the act of bringing this law was not a
one time action or a work of one day. There’s also some history behind it.
A bill of protection of
Whistleblowers was firstly initiated by Mr. N. Vittal (The then Vigilance
Commissioner) in the year of 1993. After that, The Law Commission of India[18]
in 2001, brought a recommendation to make Whistleblower’s Protection
Law in order to eliminate
corruption. Law Commission also drafted a bill[19]
for the purpose of addressing this issue in a well mannered structure.
In 2004, after the murder
case of NHAI official, the Supreme Court of India issued guidelines to the
government to activate the administrative machinery in order to receive
complaints from the Whistleblowers and as a consequence, the government
notified a resolution named ‘Public Interest Disclosure and Protection
of Informers Resolution (PIDPIR)[20].’
This resolution vested the Central Vigilance Commission[21]
(CVC) with the power to take an action on the complaints received from the
Whistleblowers.
In 2007, Second Administrative
Reforms Commission also made a recommendation to the Legislature that a
specific law needs to be enacted for the protection of the Whistleblowers.
ENACTMENT OF WHISTLEBLOWERS LAW
After analyzing the
situation we can say that Corruption is the social stigma which has its deep
down strong roots in the Indian society. The lack of adequate protection to the
persons reporting the wrongdoings ultimately lead to victimization of the
Whistleblower only. After taking into considerations so many recommendations
which were being put forth to the Legislation, it was decided to enact a
separate law for the protection of the persons who perform their duty towards
the nation truthfully.
And, finally the decision
of the Legislation went fruitful when in the year of 2011, Whistleblower
Protection Bill[22] was
proposed. On, December 27, 2011, Lok Sabha approved the Whistleblowers
Protection Bill and the bill subsequently got passed by the Rajya Sabha on 21st
February, 2014 & received the President’s assent on 9th May
2014.
The Whistleblowers Act,
2014 is having an overriding effect on the Official Secrets Act, 1923[23]
and a person can make a public interest disclosure even if it is violative of
the latter but doesn’t harms the sovereignty of the nation. It means that the
provisions of the Whistleblowers Act would be followed in the same way even if
the infringes or are with the conflict of the provisions of the Official
Secrets Act.
Features of the Act-
Ø This act provided a mechanism to
investigate the alleged corruptions or wilful misuse of power or wrongdoing, against
the Public Servants. This wrongdoing could be of any kind i.e.
Mismanagement, Fraud or Corruption.
Ø Under Sec. 3 of
the Whistleblowers Protection Act states that, a person even a
government or non-government person, could make a Public Interest Disclosure
before the competent authority. Here, the term “Public Interest Disclosure”
implies that the disclosure made by any person, notwithstanding with the
provisions of The Official Secrets Act, 1923, shall be treated as a disclosure
for the public interest i.e. for the public.
The competent authority is defined by
the law itself. Under this act, the Central Vigilance Commission (CVC) has been
given the responsibility to protect the identity of the complainant or the
other corroborating material or documents.
Ø Sec. 4 of the act states that any disclosure made
under this act shall be treated as a public interest disclosure and shall be
made before the competent authority.
Ø Sec. 5 of the act mandates the competent authority to
conceal the identity of the complainant unless he himself has revealed his
identity to some other authority or in his complaint or otherwise.
Ø This act provides for the adequate
safeguards to the Whistleblowers against their Victimization so that they
should not face any kind of harm. The only purpose of this act is to ensure
protection against the victimization or harassment of a person who makes
disclosures or has assisted in doing so and this protection is the
responsibility of the Central Government.
Ø Further, Sec. 11 (2) of the Act
provides that if a person is being victimized or is having an apprehension that
he/she may be victimized due to making a public disclosure, then he/she can
make an application before the competent authority seeking for redressal and
the competent authority, as deems fit to it, could issue directions to
appropriate public authority for the protection of such person to prevent his/
her victimization.
Ø Sec. 13 of the act specifically deals with the matter
to concealment of the identity of the complainant as well as the documents or
the information furnished by him.
Ø Sec. 16 of the act states that any person who
negligently or mala fidely reveals the identity of a complainant shall be
punishable with imprisonment for a term which may extend up to 3 years and also
to fine which may extend up to 30 thousand rupees.
Ø The Vigilance Commission is empowered
to pass an interim order against that public authority or the public servant,
against whom the disclosure is being made so as to prevent any kind of further
act of corruption while the enquiry is in continuance.
Ø Sec. 20 of the act provides for the opportunity of
filing an appeal to the High Court if any person is aggrieved by any order of
the Competent authority relating to the imposition of penalty.
Ø Sec. 21 of the act barred the
jurisdiction of the civil courts to deal with the matters of Whistleblowing on
which the Competent authority is entitled to decide.
WHERE THE LAW STANDS ON
WHISTLEBLOWERS PROTECTION ?
India’s Whistleblower law is not operational yet
Although the
Whistleblowers Protection Law has been enacted in India after achieving the
assent of the President Shri Pranab Mukherjee in May, 2014, still it’s a bigger
bigger lacunae that it is not in operation yet.
It was reported that
there’s some amendments which needs to be done in the act and for the same, a
Whistleblowers Protection (Amendment) Bill, 2015[24]
was also brought into the Parliament. This amendment bill was cleared by the
Lok Sabha with majority but the bill lapsed in Rajya Sabha due to the dissolution
of Lok Sabha before 2019 General elections. So, somehow the amendment was not
been able to get cleared from both the houses.
Shortcomings of the Whistleblower Law
Ø The major drawback of this act is
that it is only enacted for public i.e. governmental authorities, the private
entities are not included in this which disturbs the uniformity of this law as
it is not covering every authority in it.
Ø The next thing is that this act is
not at all made enforceable till now. This act provides for the Whistleblowing
against the Public Official so executive is also covered under the ambit of
this act and for the enforcement of any law, executive is responsible. So, it
could be possible that these authorities are saving themselves to fall under
any kind of trouble and due to that this act is not operational yet.
The same case is there with the
Lokpal and Lokayuktas Act, 2013 which is itself lacking in many provisions like
it is itself not at all free from Politicial influence as the appointment of
Lokpal could be manipulated in many was as there’s no specific criterion
pertaining to ascertain that who is an ‘Eminent Jurist’. This act also didn’t
provide concrete immunity to the Whistleblowers as somehow or the other,
there’s always been some influence of either the executive or the Politics over
it. Also, it doesn’t has any Constitutional backing so it is more difficult to
make its enforcement hurdle free.
So, by analyzing this, we could join
the links and could relate it with the Whistleblowers Law which is also going
through the same kind of situation and thus lacking appropriate operational
mechanism. As this law is for the executive also, so this could be the reason
for its unenforceable condition.
Ø There is no such provision in the Act
which encourages the people for Whistleblowing e.g. some kind of financial
incentives etc. As a matter of gratitude for the person who commits public
interest disclosure in dangerous situation.
The competent authority under this is very
limited i.e. there’s only Central Vigilance Commission to look into the
complaints.
Ø There is no specific procedure being
mentioned in the act according to which the enquiry process ought to be
conducted. This may because huge discrepancies as the system would become
complex due to absence of any kind of procedure.
Ø There is no right of appeal available
to the complainant if he/ she is not happy with the decision of the competent
authority. Appeal is allowed only in those cases where some sort of penalty is
imposed.
Ø A person can’t complain as an
anonymous. There should be a proper identity of that person with the competent
authority to whom he is making a complain.
Ø The Lokpal which is known to be as
country’s apex anti corruption agency and was established under the Lokpal and
Lokayuktas Act 2013[25],
is not included in the competent authority to whom the complain should be made.
This is the big shot missed by the legislature as approximately all the cases
of Whistleblowing are directly or indirectly linked with corruption only.
SUGGESTIONS
I.
First
of all, this law should be enforced so that its shortcomings could be sorted
out after applying it practically and so that the further steps could be taken
to improve this law for the ultimate sake of the society.
II.
The
next thing is that if we read the Whistleblowers Protection Act carefully, we
get to know that there’s no definition being provided in the act for the term
‘Victimization’. The thing for which this whole act is made is not mentioned in
the act. So, if the meaning of this term is not clear then the whole act will
loose its meaning & essence.
III.
The
term ‘Competent Authority’ in the act should be amended and should be made more
wider so as to include maximum adjudicating authorities in its ambit.
IV.
The
Whistleblowers Act should be amended and the Private enterprises should also be
covered under this act so that nothing should remain excluded from the fist of
law as there are so many scams existing in companies and firms also.
So, if they would not be covered under this
law, the objective of this law could not be accomplished completely.
V.
There
should be awareness camps and seminars should be organized so that more and
more people could be made aware about this law because as we see that most of
the people don’t even know the meaning of the term ‘Whistleblowing’. So, if
they are not even aware about the law then how would they contribute in
achieving the goal set by this law?
VI.
The right of appeal should be provided in all
Whistleblowers cases because it’s not necessary in each case that the order
given by the competent authority is right to its fullest, it may have some
discrepancies also which could be cleared through appeal.
VII.
This
act states that an anonymous person’s complain could not be considered. But
this should not be there. Anonymous complains should also be considered because
a person keeps his identity confidential or hidden just to protect himself from
harassment. For that purpose, the Special call centres or special complain
cells could be made to register anonymous complains also.
VIII.
The
Lokpal should also be appointed as the competent authority to take complains of
Whistleblowers because it is the highest anti-corruption authority which is
already being set up & could play a major role in these cases.
CONCLUSION
In India, we see that
there’s lot of corruption and people especially those who are bestowed with
authority are using wrongful means to get more and more richer which is
ultimately resulting into corruption, fraud and many other misconducts. We
studied and analyzed some case laws pertaining to Whistleblowers also through
which we came to know that if someone tries to disclose the scams or any
misconduct being committed by the authorities or anyone, he is being stabbed to
death.
The Indian Legislature
has tried to remove this problem from the society by bringing a legislation
which till now it is of no use because the law is not in operation yet. So,
what w can conclude from this is, we are still standing at the same place where
we were. Only passing of a law cannot make any difference, its appropriate
implementation is needed to make this law fruitful for the society. Only then
the objective of a fair, truthful and corruption free society could be accomplished.
BIBLIOGRAPHY
https://www2.deloitte.com/in/en/pages/finance/articles/whistleblower-protection-in-india.html
[1] India Corruption Survey 2019, available at: https://affairscloud.com/india-corruption-survey-2019-indias-corruption-rate-fell-by-10-in-2019/(Last visited on January 22, 2023).
[2] United Nations Convention against
Corruption (UNCAC), available at: https://www.unodc.org/documents/brussels/UN_Convention_Against_Corruption.pdf (Last visited on January 22, 2023).
[3] On Whistleblower Protection in the
UN System Note prepared by CCISUA (ILO), available
at: http://www.ilostaffunion.org/new/wp-content/uploads/Whistleblower-Policy-CCISUA.pdf (Last visited on January 22, 2023).
[4] Civil Law Convention on
Corruption, available at: https://rm.coe.int/168007f3f6 (Last visited on January 22, 2023).
[5]
AIR 1982 SC 149
[6] The Indian Penal Code, 1860, available at: https://indiankanoon.org/doc/1569253/ (Last visited on January 26, 2023).
[7] The Code of Civil Procedure, 1908,
available at: https://indiankanoon.org/doc/178223340/ (Last visited on January 26, 2023).
[8] The Code of Criminal Procedure,
1973, available at: https://indiankanoon.org/doc/445276/ (Last visited on January 26, 2023).
[9] The Indian Evidence Act, 1872, available at: https://indiankanoon.org/doc/1953529/ (Last visited on January 26, 2023).
[10] The Information Technology Act,
2000, available at: https://indiankanoon.org/doc/1965344/ (Last visited on January 26, 2023).
[11] Three get life in Satyendra Dubey
Murder Case, The Hindu, March 27, 2010, 16:00 IST, available at: https:www.thehindu.com/newa/national/Three-get-life-in-Satyendra-Dubey-murder-case/article
16625349. (Last visited on January 26, 2023).
[12] National Highway Authority of
India, available at: https://nhai.gov.in/
(Last visited on January 26, 2023).
[13] Shoumojit Banerjee, Satish Shetty
murder: CBI files closure report after 7 years, The Hindu, April 18, 2018 23:30
IST, available at: https://www.thehindu.com/news/national/other-states/satish-shetty-murder-cbi-files-closure-report-after-7-years/article23590596.ece
(Last visited on January 26, 2023).
[14] IAS Anurag Tewari’s Death: Father accuses CM
Siddaramaiah of having a ‘hand’ in murder, Times of India, Mar 8, 2018, 14:53
IST, available at: https://timesofindia.indiatimes.com/india/ias-anurag-tewaris-death-father-accuses-cm-siddaramaiah-of-having-a-hand-in-murder/articleshow/63215837.cms (Visited on January 26, 2023).
[15] NREGA activists who paid with
their lives Lalit Mehta (Jharkhand), A K Gupta, down to earth, 7th
June 2015.
[16] National Rural Employment
Guarantee Act, 2005, available at: https://www.nrega.nic.in/netnrega/mgnrega_new/Nrega_home.aspx (Visited on January 26, 2023).
[17] The Whistleblowers Protection
Bill, 2011, available at: https://www.prsindia.org/uploads/media/Public%20Disclosure/whistle%20blower%20as%20passed%20by%20LS.pdf (Visited on January 27, 2023).
[18] The Law Commission of India, available at: http://lawcommissionofindia.nic.in/ (Visited on January 27, 2023).
[19] The Law Commission’s Whistleblower
Protection Bill provisions, available at:
http://www.legalservicesindia.com/article/1187/Whistleblower-Protection-In-India.html (Visited on January 27, 2023).
[20] Public Interest Disclosure and
Protection of Informer’s Resolution, available
at: http://www.ireda.in/writereaddata/PIDPI%20Resolution%20and%20procedures(1).pdf (Visited on January 27, 2023).
[21] Central Vigilance Commission, available at: http://www.cvc.nic.in/ (Visited on January 27, 2023).
[22] The Whistleblowers Protection
Bill, 2011, available at: https://prsindia.org/billtrack/the-public-interest-disclosure-and-protection-of-persons-making-the-disclosures-bill-2010-1252/ (Visited on January 27, 2023).
[23] The Official Secrets Act, 1923, available at: https://indiankanoon.org/doc/61492784/ (Visited on January 28, 2023).
[24] The Whistleblowers Protection
(Amendment) Bill, 2015, available at:
https://prsindia.org/billtrack/the-whistle-blowers-protection-amendment-bill-2015-3784 (Visited on January 27, 2023).
[25] The Lokpal and Lokayuktas Act,
2013, available at: https://prsindia.org/billtrack/the-whistle-blowers-protection-amendment-bill-2015-3784 (Visited on January 27, 2023).