Ombudsman in India

Introduction

Modern democratic systems are characterized by welfare orientation. The resultant expansion of the bureaucracy increases scope of abuse of this power and discretion by civil servants and gives rise to citizen’s grievances with administration[1]. A balance must be struck between the administration and the public at large to protect the ordinary citizens against violation of their rights or abuse of power and address their grievance. Control over the executive is exercised through the judiciary, Parliament or and internal review. However, they often prove to be inefficient or insufficient. Thus, an independent body is required to check administrative excesses impartially.

Ombudsman is derived from ‘ombuds’, a Scandinavian word which means officer or commissioner particularly one who has the duty of investigating and reporting to Parliament on citizen’s complaints against the government[2]. The Ombudsman is an official appointed to receive and investigate complaints of citizens against the government and its officers[3].

Today, the ombudsman exists in over 120 counties albeit with structural variations[4]. They may operate on the national or central level, state or regional level and even municipal level. Generally, the ombudsman exists outside the administrative hierarchy. Its job is to identify instances of maladministration when there is a complaint or when he acts suo moto. Its functioning is discreet and inquisitorial, not adversarial thus allowing the executive body an opportunity to correct itself. The complainant does not lead evidence. Rather, the ombudsman enquires into the matter to determine whether the claims are justified since it has access to departmental files and communications. It doesn’t have the same powers as a court. Expenses are generally paid out of taxes with no fee for filing complaints. Thus, an Ombudsman may be functionally defined as an independent government official who receives complaints against government agencies and officials from aggrieved persons, who investigates and who if the complaints are justified, makes recommendations to remedy the complaints[5]. The Ombudsman is an institution essential to ensure Rule of Law and human dignity in a society[6].

Origin and development

Although some authors claim that ombudsman like institutions are an age old phenomenon dating back to the Arab Mohtasib Rome’s Tribune or the Qin Dynasty’s version but the ombudsman we know today evolved in Europe.

The first ombudsman was a temporary post which was created in 1713 by Charles XII whose function was to ensure that various public officials followed the law and worked with fairness while the King was away at war. The office of the Hogsta Ombudsmannen was in operation for seventeen years. This mechanism was reived in 1809 which is often regarded as the first ombudsman. The parliamentary ombudsman’s office continues to this day. It allowed the Riksdag to monitor the executive and ensure that executive bodies complied with the law and avoid an all-powerful tyrannical King. The Chancellor of Justice, the Civil Ombudsman and Military Ombudsman acted independently communicating officially only to avoid overlapping duties. The Swedish Ombudsman and his deputy are appointed to office for four years by a special selection committee. He must supervise the observance of laws, prosecute those who improperly discharged public functions and inspect prisons and hospitals. He also acts as a prosecutor in some instances. He cannot reverse the decision of a court or administrative body.

Finland, whose administrative practices were similar to that of Sweden adopted Ombudsman 110 years later[7]. Norway established its own ombudsman for military affairs in 1952 and civil affairs in 1962.However, the institution gained attention and popularity in Europe only after Denmark adopted it in 1955.

It is often regarded that there are two versions of ombudsman, the Swedish and the Danish. In the Danish version, he is an investigator and reporter to the Parliament restricted to the central government and its programs. The Swedish version is one where he is a prosecutor as well and can examine the entire administration and courts too[8].

The Danish Ombudsman[9] is elected by the parliament to receive complaints about public administration. He may criticise authorities and recommend the reopening of any case or even persuade them to alter their Decision. However, he cannot make administrative decisions himself. He has jurisdiction to consider matters involving legal questions but not matters which require specialist knowledge. He makes visits to public institutions like prisons, psychiatric institutions and social care homes[10]. He consolidates parliamentary control over both ministers and officials unlike Sweden where the ministers are not under the control of the Ombudsman. His most important function however, is to protect the man on the street against injustice, arbitrariness and abuse of power.

Guyana was the first developing country to adopt it. In spite of being a former British Colony, it introduced the office of the Ombudsman in 1966 prior to its introduction in the United Kingdom. One of the primary reasons for its establishment was

The Ombudsman in England is known as the Parliamentary Commissioner whose office was created by the Parliamentary Commissioner Act 1967. He is appointed by the monarch and remains in office till the age of 65 years. The statute also states which departments lie or and outside its purview. Since several aspects of potential mal administration like government contracts, appointments dismissal and others lie outside its jurisdiction. He doesn’t investigate cases where the court may be approached. He has a discretionary power to refuse to investigate cases where there are insufficient grounds of mal administration shown. The Ombudsman has no power to enforce its decisions but only to report. The Parliamentary Commissioner for Administration (PCA) investigates complaints against central government and certain other bodies controlled by ministers to reports to the parliament and a complaint may be made only through a minister[11]. Thus, a citizen cannot reach the Ombudsman directly. He can compel the attendance and examination of witnesses the same way a court can. He is free to investigate in any manner he thinks is appropriate. He lays before each house a general report every year on his performance and a special report on his investigating on any case which so requires it.

The Australian Ombudsman system established in 1976 is a two tiered where most states have one Ombudsman and the Centre has one too. He is appointed by the Governor General. He cannot investigate into actions of Ministers but only his delegates and departmental advice given to him. He can investigate general administrative activities of the government and its business activities too. Ombudsman has no power to set aside or substitute an administrator’s decision. When he notices a defect in the system he may report the same through a special report to the House of Parliament.

Its presence in a large number of counties, although with substantial legal and governmental differences shows that it is a highly flexible system.

Reasons for Growth

The formation of a Welfare State in India lead to a proliferation of administrative agencies. The state took over a large gamut of functions in order to raise the standard of living of the people and incentivise economic growth. The government grew in size and extensive powers were given to government agencies. Existing mechanisms for adjudicating grievances are weak and ineffective to deals with the problems of administrative personnel accountability. It made necessary new protection against executive and administrative mistakes and abuse of power.

The traditional concern of guarantee of legal rights of the individual has become greater in modern times. The individual and private businesses required protection from misuse of administrative discretion.

The legislature often makes legislation is skeleton form and delegates wide quasi legislative powers to the executive. These wide discretionary powers must be controlled

The legislator does not have enough time after studying and discussing legislation to adjudicate complaints. He also lacks the funds to do the same. He is often unable to have direct access to the files of other ministries and may not Party considerations effect a legislator’s efficiency in handling complaints.

Courts play a role in correcting governmental abuse. Litigation is an expensive remedy and the adversarial system places a heavy burden on the aggrieved person to substantially prove his claims which is often difficult because the litigant doesn’t have access to departmental files. Courts are also restricted by various legal technicalities by which certain administrative acts lie outside the purview of the court. Administrative tribunals also follow an adversarial system with legal representation. They are also slow and do not have a significant impact on dispute resolution in instances of maladministration.

Internal grievance resolution mechanism exist in government department but they are not effective because they form a part of the same organization against whom the grievance is. Even if the higher authority record the complaint, it has a tendency to affirm the decision of its subordinate rather than inquire into it. Thus, all of these channels are time consuming, rigid and lack independence.

The ombudsman on the other hand evolved as an independent body unlike internal executive mechanisms. It is a part of the legislature but parliamentary control over its workings are generally limited. Its independence leads to impartiality. Its method is inquisitorial unlike the administrative tribunals and courts. It is also inexpensive because there are no fees involved. Thus it would appear that the ombudsman makes up for all the flaws of other channels of redressal. However, this would be a fictitious opinion because the ombudsman is not without its limitations. It cannot make policy or reverse the decisions of the administrative officials. There are no appeals. Its decisions are not binding reportable judgement.

An ombudsman supplements existing mechanisms like courts, legislatures, executives and administrative courts.

Indian Ombudsman

In India, control over the executive through Parliament and Parliamentary Committees. Judiciary can also exercise control over the government when it flouts a statute, the constitution of principles of Natural Justice. However, propriety rather than legality should be a greater concern while assessing executive decisions[12]. Legality can be achieved through judicial control for propriety however, independent scrutiny is required. The need was brought to light with the India Against Corruption movement from 2011 and 2012 which gained national attention and encouraged legislature on the subject.

The Central Government has attempted to establish an Ombudsman over the administration for the last several decades but these attempts proved to be abortive. In 1966, the Administrative Reforms Commission suggested the adoption of the Ombudsman institution in India. It look into account the unique situation in India with the parliamentary, quasi-federal government. This was accepted by the Government and the Lok Sabha enacted the Lokpal and Lokayukta Bill, 1968. The Lok Sabha passed it but Rajya Sabha did not. Thereafter, it was introduced seven more times in Parliament, the last time in 2001. However, the Bill lapsed each time except in 1985 when it was withdrawn.

The first successfully enacted anti-corruption law was 1947 was the Prevention of Corruption Act and criminal liability was added in 1988. According to the statute, any public official receiving gratification except for legal remuneration as a reward for performing his duties or omitting to perform them is liable for the act[13]. Structurally, these institutions are nothing like the traditional Ombudsman but they do increase administrative accountability.

The Right to Information Act was enacted in 2005 which appointed Information Officers and made Government Departments liable to reveal information on a nominal fee in compliance with a fixed timeline. However there are several exceptions and no protection for whistle-blowers. The Lokpal and Lokayuktas Act was finally enacted by the parliament in 2013.

United Nations Convention against Corruption was drafted in 2003. It required states to create mechanisms at the domestic level to combat bribery, nepotism, embezzlement and money laundering. It required the implementation of preventive measures too. India has signed and ratified the treaty.

Central Vigilance Commission

The Central Vigilance Commission was created in 1954 on the recommendation of the Committee on Prevention of Corruption[14]. The committee was tasked to examine the various aspects of corruption in Government Departments and recommend measures to check it[15]. The CVC became a statutory authority with the Central Vigilance Commission Act 2003.

Composition

It is comprised of the chairperson who and two other Commissioners who are appointed by the President. The Chief Technical Examiners Wing consists of engineers who conduct audits of construction works and investigate into them. The Commissioners for Departmental Inquiry consists of fourteen officers whose function is to conduct oral inquiries into public officials against whom there are departmental proceedings.

Jurisdiction

Members of All India Services, Group ‘A’ officers of the Central Government, Public Sector Banks, Executives and officers of Public Sector Undertakings and other government employees fall within the CVC’s Jurisdiction.

Powers

It exercises superintendence over the functioning of the Delhi Special Police, investigates offences under the Prevention of Corruption Act, enquires or causes an inquiry on a reference of the Central Government and reviews the progress of the applications for sanction of prosecution under the Prevention of Corruption Act. It exercises powers of a civil court[16]. It has the power to accept written complaints for disclosures on any allegation of corruption. Citizens may file online complaints and mechanisms are created to record whistle-blowers as well. It is free from all executive control.

Lokpal

The Lokpal is a central, autonomous apex body empowered to investigate and prosecute politicians, bureaucrats and judges. The ARC recommended setting up of institutions moulded on the Ombudsman of Scandinavian Countries and the Parliamentary Commissioner for investigation in New Zealand.

Composition

Lokpal according to the 2013 Act shall consist of a former Chief Justice of India or a Judge of the Supreme Court or any eminent person. Fifty percent shall be judicial members and the fifty percent shall belong to the Scheduled Caste, Scheduled Tribe, Other backwards classes Minorities and women[17]. Selection committee is diverse. Consists of the Prime Minister, Speaker of the Lok Sabha, Leader of Opposition, Chief Justice and one eminent jurist[18].

Generally a judge or a lawyer or high officer appointed by the parliament. Makes a report to the parliament and sets out reactions of citizens against the administration. Makes his own recommendations to eliminate the causes of complaints[19].

Jurisdiction

The body will have powers of a civil court. It will have access to all departmental files and other powers to enable it to conduct enquiry

Lokayukta

The Lokayukta is a state level Ombudsman. He deals with complaints of maladministration against public officials like Ministers, Members of Legislatures, civil servants, bureaucrats and the police. He is usually a former High Court Judge or Supreme court Judge. The first Lokayukta enactment was passed by Orissa in 1970 but the first Lokayukta was established in Maharashtra in 1971. Karnataka established its Lokayukta in 1984.

Structure

The structure of the Lokayukta differs from state to state. Some states have created a Lokayukta and an Up Lokayukta like Rajasthan, Karnataka, Andhra Pradesh and Maharashtra while other states only have a Lokayukta. Punjab and Orissa have designated officials as Lokpal[20].

Jurisdiction

There is no uniformity in jurisdiction either. The Chief Minister is Included within the jurisdiction of the Lokayukta in Himachal Pradesh, Andhra Pradesh, Madhya Pradesh, and few other states while he is excluded in Maharashtra, Bihar, Rajasthan and other states. The members of State Legislatures, authorities of local bodies, corporations, companies and societies are included in the jurisdiction of the Lokayukta in most states.

Power

Lokayukta have the power to accept complaints from citizens in the form of grievances due to mal administration and allegations of corruption. In most states they are also empowered to act suo moto. They may also require the assistance of investigating agencies. They have the power to call for documents from government departments.

Banking Ombudsman

The banking Ombudsman was set up in 1995 but was greatly modified by Banking Ombudsman Scheme, 2006 in order to provide a speedy, impartial and cost effective forum for consumers to settle disputes outside the adversarial court system. It was brought into effect by a direction of the RBI under the Banking Regulation Act 1949[21]. The Ombudsman is an official in the rank of Chief General Manager or General Manager appointed by RBI. The appellate authority is the Deputy Governor of the RBI.

Nature of Matters

Complaints regarding banking services are received by the Ombudsman. Non-payment or inordinate delay in making payments, non- adherence to prescribed working hours, refusal to open or close deposit accounts or a delay in the same, violation of RBI directives, levy of charges without prior notice and deficiency in internet services are grounds for which a complaint may be made[22].

Powers

The Ombudsman’s territorial jurisdiction is determined by the RBI. He has the power to call for information, general powers of superintendence over his office, to make expenditure according to the rules, prepare the budget and send an annual review to the Governor of the RBI.  He has the power to exercise mediation and conciliation services. When the terms of settlement offered by the banking company are accepted by the complainant, the Ombudsman passes a final binding order enforcing the same. If no settlement can be reached in a month the ombudsman may pass an award or reject the complaint.

Insurance Ombudsman

It was created in 1998 through a government notification and its primary function is to protect the interests of consumers i.e. policy holders. The insurance ombudsman is a person belonging to the insurance industry, civil service or judicial services.  It is supervised by Insurance Regulatory and Development Authority of India and a governing body of representatives of insurance companies[23].

Nature of Matters

Complaints are made in writing addressed to the Ombudsman with Competent jurisdiction. The Ombudsman takes up complaints regarding repudiation of claims by an insurer, dispute regarding premium paid or payable, legal construction of the policy for claims, delay in settlement, mental agony and harassment and non-issue of insurance documents after payment of premium.

Powers

The power to perform conciliation and the power to pass awards is with the Ombudsman. The award is binding on the insurance company which must act upon it within three months. He may make recommendations as he thinks fit and send the same to both insurance company and complainant in order to encourage a settlement. The ombudsman has no jurisdiction over insurance contracts valued over Rs 20 lakhs.

Income Tax Ombudsman

This ombudsman is a person who is a former employee of the Government of India. He is independent of the Income Tax Department.

Nature of matters

Matters regarding delay in issue of refunds, non-acknowledgement of letters and documents sent to the department. Delay in allotment of pan number, delay in releasing seized books of accounts and documents, unwarranted rude behaviour among other issues may be complained of before the Insurance Ombudsman.

Powers

He has the power to facilitate settlement through conciliation and mediation, demand the production of from any Income Tax authority, suggest remedial measures and report his findings to the Revenue Department.

Judicial Development

The most important role of the judiciary in the Ombudsman mechanism has been its acknowledgement is the fact that a toothless Ombudsman is one which is ineffective. In other jurisdictions, the Ombudsman’s informal mechanism and non-binding recommendations act to its advantage and the mere mention of an official’s name in the annual report is sufficient threat to ensure compliance with the law and with the Ombudsman’s recommendation. In India, however, it makes the ombudsman weak. Legislative intent must be taken into account. In the Andhra Pradesh Lokayukta Act, 1983, the legislative intent was to make public servants answerable to the Lokayukta who would be a former Judge of the High Court. When an authority consists of high judicial dignitaries, they should be armed with appropriate powers so that their orders do not remain mere opinions and paper directions[24]. However, the court also realized the limitation of the statute which did not make implementation of the order mandatory.

It is plain as day that the courts would encourage treatment of an Ombudsman’s recommendations as mandatory. A constitutional bench of the Supreme Court observed that when an office of Lokayukta is held by a former Supreme Court Judge is difficult to assume that his report would be devoid of merits[25]. The Supreme Court in clear terms declared that it did not intend to lay down the abovementioned statement as law. It found that in the case at hand the Lokayukta had carried out detailed investigation and his report clearly reflected the same.  It also contained the materials which lead him to form the conclusion that the orders investigated were passed in a clandestine manner with the officials involved deliberately and knowingly ignored the realities of the case.

A liberal interpretation is given to the powers of the Lokayukta wherever possible in order to allow it to cover a larger realm of matters. Such liberal interpretation clearly shows that courts believe that the office of the ombudsman should not be continually bound and gagged. The Lokayukta had the power to suo moto investigate into matters where the Upa Lokayukta had jurisdiction as long as it shows reasons[26]. It also has the power to recommend suspension in an interim report in order to further its investigations if a prima facie investigation brought allegations against that official.

Analysis

The effectiveness of the Central Vigilance Commission may be seen in its Annual Report of 2014[27]. The Commission tendered advices in 5867 cases during the year 2014 when the total number of cases reported to it were 64410. It advised major penalty proceedings in 624 cases and minor penalty proceedings in 270 cases. In pursuance of the Commission’s advice, the competent authorities granted sanction for prosecution against 133 public servants during the year 2014. Data is not available in the same manner for the various lokayuktas.

The Haryana Lokayukta had 1023 pending cases and received 692 complaints in 2013-14 out of which it disposed 807 complaints[28]. However, the government implements only a small fraction of the cases disposed by the Lokayukta.

The very existence of Ombudsman would increase transparency by acting as an independent viewer to government files. There is a growing demand in India to shift to a more open form of government. Part of the liberal democratic leaning. Actions and decisions of the government should be open to public discussion and criticism. Keeping administrative decision making may promote efficiency buy also breeds arbitrariness. Today, public suspicion has undermined public confidence in administration.

The fact that a decision of an Ombudsman like a Lokayukta is not binding but merely directory should be considered an advantage. This allows the ombudsman to ensure that the grievances of the citizens comes to the attention of the parliament without upsetting the administrative mechanism. However, lack of implementation would render the Ombudsman irrelevant.

The Lokpal Act fills several gaps present in the existing Ombudsman like institutions. Perhaps its most important advantage is its wide jurisdiction. It covers even the Prime Minister and Members of the Judiciary. The independence of the Lokpal would be protected by the fact that the composition Selection Committee. The Lokpal would not consist of bureaucrats and politicians. Remedy would be delivered swiftly because the act provides for time limits. A decision must be given in a year and executed in two years.

The power to sanction prosecution der the Prevention of Corruption Act would now lie with the Lokpal. It would also have its own prosecution Wing.

It would have the powers of a civil court in matters of securing attendance of a person, discovery and production of documents and issue commissions for the examination of documents and witnesses. It may direct seizure of important documents and retain the documents in custody. It may attach property. It may recommend transfer or suspension of an officer once a preliminary case is made out. It may utilize any authority or investigating agency. Thus it has extensive powers.

Special Courts would also be established under the act to decide cases arising out to the Prevention of Corruption Act and this act.

Perhaps the only disadvantage of the Lokpal is that it will not have the power to receive complaints of corruption from common people. It is the Parliament which will make these decisions. Also, it remains an advisory body. It may only forward its report to the competent authority which would have the final powers to decide whether to take action or not.

The Ombudsman is a very flexible mechanism which can alters its form to suit topical problems. Its use in developing countries is still worthwhile because it serves two purposes which all developing countries desire-it promotes the general efficiency of administration and bridges the gap between the government and the people[29].

However some authors argue that this institution may prove to be successful in countries with a small population but unsuccessful in populous countries like India.

Authors like Walter Gellhorn are of the opinion that the ombudsman’s potential as a procedural system is largely bound up with our commitment to the adversary system since the ombudsman and adversary systems are substantially competing procedures for the regularization of informal processes; each is based on a different conception of the dispute resolution process and reflects different underlying social and political values. While the two systems could coexist in harmony if spheres of influence were delineated reflecting the appropriateness of their respective procedures, the spread of the adversary system, in response to the perceived commands of procedural due process, into many areas of administrative decision making has stymied the development of the ombudsman alternative[30].

Conclusion

In a liberal democracy, justice and fairness are the pillars of administration. It is imperative to avoid administrative delay, dis courtesy and mal administration. In a developing country where large scale powers are conferred upon a government, there is a tendency towards corruption and maladministration.

It can be clearly perceived that the spirit and the structure of the Ombudsman of the Ombudsman has been emulated in various institutions in India. It may be said that as of today there in no central authority which clearly undertakes the role of the Ombudsman. Rather, a group of Institutions at the Central and State Level, have divided up the functions of the Ombudsman among themselves.

The effectiveness of these institutions should not be measure by the degree of similarity with other Ombudsman. Their actual successes in dispute resolution should be their measure of effectiveness. From the above data, it appears that the Ombudsman institutions in themselves have managed to deal with a fair percentage of complaints and have also recommended penalties. The implementation is left to the government and is thus a matter for which they cannot be criticized.

Their effectiveness may also be determined by the extent to which they have been successful in raising public awareness and encouraging participation of citizens. The Lokayuktas have caused investigations over the last few years over matters which either treasury or opposition would have wished to suppress. Their reports have brought to light in various instances the complex problem of corruption which prevails.

There is no clear substitute to the Ombudsman. India requires a central ombudsman at the earliest which may work along with other legislative, judicial and administrative control mechanisms to check the powers of the executive increase administrative accountability and public confidence in the redressal mechanisms and the administration itself.

[1] M. Laxmikanth, Public Administration 218 (7th ed., Tata McGraw Hill Education Private Limited, New Delhi 2011).

[2] H.W.R. Wade &C.F. Forsyth, Aministrative Law 84 (9th ed., Oxford University Press, New Delhi 2013).

[3] C.K. Takwani, Lectures on Administrative Law 426 (5th ed., Eastern Book Company, Lucknow 2012).

[4] UNTERM, The Ombudsman available at http://unterm.un.org/dgaacs/unterm.nsf/8fa942046ff7601c 85256983007ca4d8/2e129932e6473e6a85256fd50061e131?OpenDocument (last visited on September 20, 2015).

[5] Bernard Frank, The ombudsman-a challenge 2 International Bar Journal 30 32 (1971).

[6] Bernard Frank, The Ombudsman Revisited 4 International Bar Journal  128 130 (1975).

[7] Hing Yong Cheng, The Ombudsman or Citizen’s defender: A Modern Institution 377 Annals of American Academy of political and social science vol 20 21 (1968). .

[8] Jan-Erik Lane, Public Administration and Public management :the principal agent perspective 134 (2nd ed, Routledge Taylor and Francis, London 2006).

[9] The office was created under the Parliamentary Ombudsman Act, 1955.

[10] Folketingets Ombudsmand, The Danish Parliamentary Ombudsman available at https://en.ombudsmanden.dk (last visited on September 19, 2015).

[11] John Alder, Constitutional law and administrative law 106 (6th ed., Palgrave Macmillan 2007).

[12] S P Sathe, Administrative Law (7th ed Lexis, Nexis Butterwoths Wadhwa, Noida, 2009).

[13] Section 7.

[14] Santhanam Committee.

[15] Laxmikanth, supra note 1 221(The government accepted 106 out of 137 recommendations. The committee also recommended to the Constitution, Indian Penal Code and other statutes).

[16] Section 11.

[17] Section 3.

[18] Section 4.

[19] C.K. Takwani, Lectures on Administrative Law 427 (5th ed., Eastern Book Company, Lucknow 2012).

[20] Laxmikanth, supra note 1 226.

[21] Section 35(A) (It gives RBI power to issue binding directions to one or more banking company).

[22] Section 8.

[23]Insurance Regulatory and Developmental Authority of India, Ombudsman available at https://www.irda.gov.in/ADMINCMS/cms/NormalData_Layout.aspx?page=PageNo233&mid=7.1 (last visited on September 30, 2015).

[24] Institution of A.P. Lokayuktas/ Upa Lokayukta v T. Rama Subba Reddy, (1997) 17 SCC 42 ¶ 17.

[25] M.P. Special Police Establishment v. State of M.P. (2004) SCC 788.

[26] Ch. Rama Rao v. Lokayukta (1996) 5 SCC 304.

[27] Central Vigilance Commission, Annual Report 2014 available at http://cvc.nic.in/ar2014.pdf (last visited September 24, 2015).

[28] Haryana Lokayuka, Lokayukta Haryana Annual report for the period from 01.04.2013 to 31.03.2014 available at http://www.hrlokayukta.gov.in/annual_reports/Annual%20Report%202013-14.pdf (last visited September 24, 2015).

[29] Cheng, supra 7 note 21.

[30] Paul Verkul, The Ombudsman and the limits of the Adversary System 74 (4) Columbia Law Review 846 (1975).

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