IMPACT OF CORRUPTION ON JUDICIAL SYSTEM OF PAKISTAN, CREATING LACK OF TRUST AND DISSATISFACTION AMONG THE CITIZENS by - Waqas A. Khan
I. Abstract
The foregoing research involves exploring the dark side of judiciary in Pakistan. The Rule of Law requires strong adherence to the constitutional principles while respecting judicial independence and judicial impartiality. However, the justice system has been a constant victim of corruption, marriage of power, poor governance, inexperienced advocacy and violation of human rights on horizontal and vertical levels of Tehsils courts, District courts, High courts and the Supreme Court. Failure of the administration to maintain good governance and poor delivery of justice in courts have resulted in the public losing their faith and trust in the legal system. Good governance and Rule of Law are the state’s collective duty which should always remain a priority despite the numerous challenges that are dealt with within the state. Corruption and bribery have paved their way in becoming a cultural norm due to which immense controversy and criticism is dealt by the judiciary.
II. INTRODUCTION
In Pakistan, the role of the judiciary, advocacy, and courts have always remained a part of complexity and controversy. The courts have been divided between the military and civilian regimes(Siddique, 2010)2.
While the country struggles to cope with poverty, terrorism, lack of governance, and shortage of gas and electricity, the problem of corruption has become so vast that it has become too difficult to tame at this point. In the District and Tehsil, poor judiciary, politics, business, bribery, malpractices, and corruption have created hindrancestothe delivery of justice. These elements negatively impact the country’s economy.
“Law’s empire is defined by attitude, not territory or power or process”(Al-Najjar and Saeed, 2021)3
Rishwat and Safarwish are two words often used for the act of corruption;Rishwat indicates bribery through monetary means and gifts for the consideration of performing illegally and dishonestly. Safarwish indicates persuasion through social relations in order to require services wrongfully(ZAFAR and MUHAMMAD, 2022)4. Pakistani culture has evolved around Safarwishto such an extent that it has become an everyday practice. The legal system struggles to ensure that law and justice are served to society as corruption erupts on all levels of the judiciary, from district courts to court officials and court clerks. As per the TI-Pakistan Survey, 96% of the time, courts have faced corrupt practices at the hands of court officials and court clerks. It results in citizens suffering as they further undermine the rule of law(Rahman et al., 2019)5.
One of the major reasons for corruption to become such a common practice can be said due to the low ethics of lawyers and the lack of controls for bodies that ought to be responsible for ensuring that rule of law is upheld and at high standards. Money is required to be paid in order to prevent the judicial process from being halted. At times, through money, the process of cases is controlled either by decreasing the case time or by increasing the case time. Money is also paid while filing for cases in order to acquire a judge of personal choice(Andersen, 2013)6. Although it can be said that the corruption problem is not only limited to the subordinate judiciary; the practice has been common in the higher and superior
judiciary due to the reduction in the quality of the adequate judiciary and the shortcomings of the legal system, a great deal of criticism has been leveled against courtroom advocacy.
It is said that a citizen is more likely to experience corruption when they are likely to encounter the legal profession, a client approaches a litigator in order to acquire sound professional advice. However, unethical practices in the legal profession have established a culture of providing false optimism to obtain substantial fees for preparing a case that the client knows nothing about. Corruption in the legal profession reflects a low sense of professionalism, public service, and competence(Starkloff, 1999)7. Moreover, this malaise act seems to be associated with a lack of efficient legal education and mechanisms of legal accountability. A great level of unwillingness in undertaking the liability of legal mechanisms and maintenance of professional discipline, as well as ensuring high standards and principles are upheld.
When it comes to maintaining the accountability mechanisms, it is seen that discipline and control are not provided by the Bar councils when lawyers are practicing. The Bar Associations must provide adequate training and legal education and ensure that high standards of legal professionalism are maintained from lower courts to higher courts and superior courts. In reality, many politics and personal interests create an ineffective environment. Often, lawyers who aim to do good are ignored and never acknowledged while money is circulating to satisfy malevolence. While corruption may have begun through advocacy and the judiciary, it is not only the police, lawyers, and judges who are corrupt but those who are affiliated with courts, such as court clerks and other court officials. “….Corruption among the subordinate officials and process-serving staff as well as among the investigation staff is rampant with the result that they take no action unless the parties involved approach them and tender some extra-legal consideration….”(Wilson, 1985)8 The beginning of advocacy starts from legal education, which creates the judges and guardians of Pakistan’s legal system; however, if the quality of legal education in Pakistan remains outdated and poor, the question arises; What good would it do to the legal system of Pakistan? The essence of inadequate legal education in Pakistan produces lawyers deemed unfit and corrupt as they are presumed to enter the legal profession to make a quick buck.
Law schools have no selective filtering process for law students; they require a mere pass to be eligible enough to apply for law schools. Moreover, even in 2022, the “RATTA” learning system remains a thing for law students. As a result, they lack basic legal skills and inadequate practicing skills since all that is taught in law schools is to pass an exam. Law students are not provided with sufficient training for application in courts. Therefore, once these students graduate, they struggle to adhere to the court’s environment.
As the quote goes, a tree can only be as good as a seed. To start by creating a better legal environment, the state may be required to pull apart the way legal education is provided for future advocates and the judiciary. Mandatory training of a minimum of three years should be provided as a part of the law school. It should allow students to familiarize themselves with the judiciary system and courts’ challenges. A challenging bar exam should be made mandatory,eliminating inefficient students who fail to meet the criteria. A procedure like this would prevent unfit and corrupt lawyers from entering the legal profession.
“..When courts are corrupted by greed or political expediency, the scales of justice are tipped, and ordinary people suffer..”(Cain, 2012)9
This state outrightly highlights the issue of corruption associated with the miscarriage of justice. This practice bars the citizens from accessing justice and their basic human rights toa fair and impartial trial. At times, citizens are barred from even having a trial unless they provide a handsome amount of Rishwat or have a good source of Sifarish. Judicial impartiality and independence are stressed throughout the legal profession as the poor suffer the most at the hands of corrupt justice. They cannot pay for the bribes,so they are not provided access to fair trials and bails. It is common knowledge in Pakistan that the poor are openly exploited and oppressed. In certain situations, the judges are honest and provide an unbiased verdict. However, the rest of theproceeding activities on other levels of the courts mostly stand upon corruption. For many court clerks and government officials, bribery is not unethical or an evil act; rather, it is a sense of morality for them. They consider it right because they believe a wealthy man is above the law. When clients refuse to satisfy their bribery claims, they label them as arrogant and filled with attitude. For them, their evil acts are righteous, which may be the initial root of the problem.
For the rich, the environment of courts is like their own kingdom. They can hire well- acquainted and expensive lawyers who give them special documents and perks for winning their cases. Many arbitrary casesdo not reach the courts; wealthy people can settle them outside through bribery. At times, the poor have to adhere to whatever is being provided by the rich to get something rather than get nothing if they proceed with a case in court for justice. In Pakistan, the rich have a high social circle which allows them to favor the people, while the flawed system only encourages this heinous act.
“..powerful and corrosive influence a corrupt judiciary can exert on the rule of law and society as a whole. Success in attacking judicial corruption will boost citizens’ trust and national efforts to achieve transparency and accountability”(de Swardt, 2021)10 Transparency International creates an effort for a global coalition against corruption; accordingly, they propose certain ways to combat judicial corruption and strengthen judicial independence. First and foremost is to appoint an independent judicial body through a strong judicial selection process. The appointments should be carried out following merit-based exams and publicized election criteria requiring the candidates to demonstrate competence and integrity. Moreover, civil society ought to be linked with the judicial activities and merits of the candidates. Judicial salaries should be provided per the judiciary’s experience and professional development.
Moreover, pair pensions at retirement, protections to provide security, and satisfactory working conditions should be maintained. In order to ensure that impartiality, independence, and miscarriage of justice are prevented, the judicial transfers ought to be based upon objective criteria. Accountability and discipline ought to be practiced through limited immunity and discretionary power provided for the judiciary, and allegations against judges should be investigated through an independent body to ensure that biases and favoritismare not exercised. In cases where judges are wrong, the removal process should be strict, fair, and transparent, and where corruption is found against a judge, a liable prosecution process should be provided. Transparency International has created several reports and efforts to evaluate corrupt judicial practices globally.
The jurisdiction of Pakistan stands upon the pillars of good governance and Rule of Law; these are inter-connected phenomena; it is essential to adhere to good governance at overall levels of Pakistani courts, especially starting at district courts. Under the umbrella of the Supreme Law, it is crucial to have a collective duty to perform efficiently under the principle of good governance.
“..The existence of massive corruption, institutional clashes, Constitutional crisis and lack of accountability, poor law and order conditions may harm the good governance in the country”.(Khan, 2020)11
I. RESEARCH METHOD
The research was normative legal research, and it analyzes the laws and regulations of Pakistan concerning bribery, corruption, judicial independence, judicial impartiality, inexperienced advocacy, and miscarriage of power and justice.
II. IMPORTANCE OF GOOD GOVERNANCE
Subsequently, it is the prime responsibility of the executive to ensure that good governance is conducted to keep the Rule of Law intact, as otherwise, the country’s judicial independence would be in danger. In several cases, it is seen that the executive has failed to take measures to maintain governance. Such a situation gives rise to criticism and debates over the issue of courts’ good upholding fundamental rights and impartiality. In the famous case of Maulvi Tamizuddin, ex–Gilgit Baltistan Chief Judge Rana Shamim triggered the controversy over the role of judicial independence(Kyriacou et al., 2015)12. Moreover, a recent report by the International World Justice Project emphasized the criticism of the Pakistani judiciary; it has placed Pakistan among the lowest ranked countries to ensure that the Rule of Law is upheld. The findings involved that government accountability has a high perception of impunity in Pakistan. Although, these perceptions vary according to the cities, as Lahore remains rather more optimistic in concerns about its government accountability while Quetta remains more pessimistic over the poor government accountability(Gisselquist, 2012)13. Many high authorities are involved in corrupt practices ranging from advocates and magistrates to judges.
Moreover, the police were labeled as the most corrupt authorities in the report. More than half of Pakistani citizens pay a handsome amount of bribery to the police and court officials to receive assistance which in most cases should have been provided as a part of the administrative proceedings. Even a basic right, such as receiving medical attention at a public hospital, is accessed through bribery. So, the question arises, where do the governance and the rule of law stand in Pakistan?
Accordingly, the report further concluded that Pakistan lacks legal awareness as only a moderate number of Pakistanis know. Access to civil justice is dealt with several common hardships; the survey shows that at least 82% of citizens face legal problems while trying to acquire civil justice. Only 14% of people can resolve their issues through arbitration, mediation, and adjudication. As a result, many Pakistani citizens have lost faith and trust in the judiciary and administration.
One of the reasons why people in Pakistan resort to crimes, local jirgas, panchayats, and other ways to acquire justice is due to the delay in justice provided by the judiciary and the inexperienced practices conducted through advocacy(Grindle, 2012)14. In many circumstances, impatient people take the law into their own hands and get revenge, eventually leading to increased crimes. The local panchayats provide unfair and inhumane punishments that provide little to no justice.Theconfidence in Law Enforcement Agencies has also been affected due to inefficient judiciary. In many circumstances, the LEAs can capture and arrest terrorists; however, they are released in courts through bribery. In Swat, the functions of the government have been undertaken through terrorist organizations such as Tehreek e Nifaz e Sharia Regulation and Nizam e Adl Regulation. Due to a failure in good governance, the Pashtun society eventually resorted to a cheap and effective judicial system of the State of Swat. Although, post-1969, several changes have been made in the legal system.
As per the World Justice Project, only Afghanistan is behind Pakistan for lack of adherence to the rule of law. Out of 139 nations, Pakistan ranks 130th nation for poor governance. Political affiliations, involvement of courts, poor advocacy, and lack of judicial independence and impartiality have created malice in the justice system(Camdessus, 1998)15. It can be seen through the darkest case of the judiciary of Maulvi Tamizzuddin. The judiciary and courts have used different military governments, administrations, and civilians to obtain political gains. Several years ago, the death of former Prime Minister Zulfiqar Ali Bhutto demonstrated that politics is practiced amongst the judiciary. However, even today, not much has seemed to change. The case of Noor Muqaddam is seen as one of the examples where courts had delayed justice despite sufficient evidence. While one may argue that courts were undertaking precautionary measures in the Noor Muqaddam case, it is undeniable that the judicial system of Pakistan remains inefficient. Cases involving political parties and politicians, such as the Model Town Case, provide a reason for the country to lose faith in the judicial system. At the same time, the Sahiwal incident demonstrates an inefficient criminal justice system, as in the following case;the culprits succeeded in evading punishment. Justice delayed is equivalent to justice denied.
I. THE LAWYERS’ MOVEMENT IN PAKISTAN
Accordingly, in a report by the Chief Justice of Pakistan, Iftikhar Muhammad Chaudry, it was highlighted that corruption has caused Pakistan’s criminal and civil justice system to suffer from unacceptable delays and poor and disproportionate mismanagement. In his report, he encouraged the judicial system to exercise impartiality and good governance by taking responsibility for the court of law(Shafqat and Inquiry, 2018)16. Traditionally, due to a lack of sufficient judicial policy and ownership, the system suffered. There was no effective implementation of the National Judicial Policy,and the stakeholders had not made sufficient methods to eradicate the root of the problem. Implementing adequate judicial policies at horizontal and vertical levels of the court; these policies should also be stressed to make the administration more promising while dispensing justice. The delays carried by district and session judges should be worked upon by ensuring that the aims and objectives of national judicial policies are well understood amongst the Bar council, District, and Tehsils courts.
“…the face of the judiciary to the common man in the country. Therefore their character must be unimpeachable…”(Ahmed and Stephan, 2010)17
He stressed the support from the bar in the struggle to uphold the nation’s faith, as, without the cooperation of the bar, it would be complex, stressful, and difficult to ensure that policies are well implemented. Moreover, to achieve future strategic goals, it is also crucial for the relevant governmental agencies to adhere to and respect the policies, as this would represent the collective aspirations of the people of Pakistan and the judiciary.
“..5th of July marks a sad day in our constitutional history. On its day, thirty-two years, ago constitution was suspended, and the democratic process was thwarted. Thirty-two years later, by the Grace of Allah,the country is being governed under a democratic dispensation..” (Khan, 2007)18
This statement was represented when Chief of Army Staff General Muhammad Zia-ul- Haqoverthrew the government of Pakistan by resorting to a Cold War. The day marks the country’s history, yet the question arises, what has Pakistan truly learned from it? The constitution and governance of Pakistan have suffered tremendously at the hands of the judiciary, advocacy, and politicians. It is crucial to erragainst the malicious and heinous acts and practices commonly carried out at all court levels. Iftikhar Muhammad Chaudry also stressed the importance of the judiciary to remain impartial and carry out their duties even during the toughest conditions.
Moreover, for that, it is also important that the nation’s support is provided(Zaidi, 2008)19. Without cooperation, the implementation of judicial policies will remain a challenge. From 2007 to 2009, The Lawyer’s Movement created significant changes to overcome the challenges of decentralized organizations and leadership. Iftikhar Chaudry had prompted the movement in Pakistan to oust former President General Pervez Musharraf. The legal society of Pakistan had been adversely affected by Musharraf’s actions of restricting the discretionary power of the Supreme Court’s Independence under the leadership of Iftikhar Chaudry. Approximately 80,000 attorneys had come to provide their unity and support for the position of Chief Justice and regain judicial independence; while these protests were non- violent, the authorities had dealt with them violently, as the Human Rights Watch stated it; “Authorities aggressively crushed the resistance by beating lawyers, opposition activities, and media workers covering unfolding events.” (Khan and Joseph, 2008)20
Regardless of the authorities’ opposition, the advocates remained peaceful, and gradually the movement grew powerful through coordinated, peaceful acts. Judges who had refusedto face complexities and arrests. The initial focus of men in black was primarily on upholding the rule of law and judicial independence that allowed it to transform the country’s political landscape. It was a two-year-long period of struggle and continuous movement against the politically incorrect and miscarriage of power. Ninety-seven senior judges of Pakistan had refused to adhere to implementing emergency rules and policies(Khan, 2019)21. This situation represented an unusual act of disobedience necessary for the country’s rule of law. This period was crucial for restoring democracy in Pakistan as it established the fundamental change required in the society and the state.
“Suspension of the Chief Justice of Pakistan and the Circumstances surrounding that event had led many observers to conclude that the country had seized of a judicial crisis. Several hundred lawyers have been marching on the streets in various towns and boycotting the courts as gestures of protest against the government’s action. Opposition politicians insist that it is at once a judicial and a political crisis” (Asian Journal of Social Sciences & Humanities.”(Sulehry and Wallace, 2022)22
This moment was an eye opener for the public, judiciary, administration, political governance, and the state of Pakistan as it allowed everyone to understand the importance of judicial independence and unity in the legal profession. In Pakistan, it was the first time in the history of the judiciary that a military coup was overcome by the authority of a seven- member bench of the Supreme Court of Pakistan. The alliance of attorneys represented the Rule of Law. “..the lawyer’s movement might not have the political power to challenge any government, but we hold the key to the persistence of this judicial crisis. The key is the withholding of legitimacy on the part of the lawyer’s movement. This judicial crisis will persist unless the lawyer’s movement confers legitimacy on any solution proposed by the PPP government… our ability, courage, and persistence to say ‘NO’ to any unconstitutional and incomplete resolution of this judicial crisis will determine the future of this judicial crisis, of an independent judiciary and the development of constitutional democracy in Pakistan..”(Khan, 2021)23
The defeat by the black coats has allowed the institutions to restore power, honor, and sanctity. Lawyers are highly recognized as it provides them the power to protect their clients’ legal and fundamental rights while ensuring that fundamental human rights are not breached by failure to deliver justice. Subsequently, the movement represented the standard of justice and public interest in upholding the Rule of Laws
I. BIBLIOGRAPHY
AHMED, Z. S. & STEPHAN, M. J. J. D. 2010. Fighting for the rule of law: civil resistance and the lawyers’ movement in Pakistan. 17, 492-513.
AL-NAJJAR, S. A. A. & SAEED, H. G. J. U. J. O. S. S. 2021. Ronald Dworkin and Human Dignity as Highest Constitutional Value: Philosophical Theorization of Rights and Human Dignity in a Comparative Perspective. 5, 82-89.
ANDERSEN, L. R. 2013. How the Local Matters: Democratization in Libya, Pakistan, Yemen and Palestine, DIIS Report.
CAIN, A. J. I. A. 2012. Foreign bribe prosecutions are rising: Transparency International reports inconsistent enforcement of OECD’s Anti-bribery Convention. 69, 13-15.
CAMDESSUS, M. 1998. The IMF and good governance. Navigating Stormy, Uncharted Waters.
International Monetary Fund.
DE SWARDT, C. 2021. 1993–2020: TI: A Short History of Holding the Powerful to Account.
Silencing a Whistleblower. Springer.
GISSELQUIST, R. M. 2012. Good governance as a concept, and why this matters for development policy, WIDER Working Paper.
GRINDLE, M. J. P. I. T. M. 2012. Good governance: The inflation of an idea. 259-282.
KHAN, A. J. J., MAY-DECEMBER 2007. The Lawyers’ Movement in Pakistan.
KHAN, M. 2019. Empowerment without Accountability? The Lawyers’ Movement in Pakistan and its Aftershocks.
KHAN, N. U. J. S. A. S. 2020. Constitutional Manacles on Superior Court’s Jurisdiction and Recent Scenario on Public Interest Litigation in Pakistan. 33.
KHAN, S. A. 2021. Judicial Independence in Pakistan: A Case Study of Lawyers’ Movement, 2007- 2009. West Virginia University.
KHAN, Z. & JOSEPH, B. J. J. O. D. 2008. Pakistan after Musharraf: The media take center stage. 19, 32-37.
KYRIACOU, A. P., MUINELO‐GALLO, L. & ROCA‐SAGALÉS, O. J. P. I. R. S. 2015. Fiscal
decentralization and regional disparities: The importance of good governance. 94, 89-107.
RAHMAN, K., ROBERTO, M., KUKUTSCHKA, P. & COOKSEY, B. 2019. Overview of corruption
and anti-corruption in Tanzania, JSTOR.
SHAFQAT, S. J. L. & INQUIRY, S. 2018. Civil society and the lawyers’ movement of Pakistan. 43, 889-914.
SIDDIQUE, O. 2010. Law In Practice–The Lahore District Courts Litigants Survey. Lahore, Pakistan: Development Policy Research Centre, Lahore University of ….
STARKLOFF, R. 1999. Farmers’ participation, empowerment and the institutional reform of Pakistan’s irrigation and drainage sector: key concepts and farmers’ perceptions, IWMI.
CELERY, R. S. & WALLACE, D. J. P. S. J. O. A. O. E. E. 2022. IDENTIFYING THE BLIND SPOTS: A CRITICAL ANALYSIS OF THE EXISTING ACADEMIC DISCOURSE ON THE PAKISTAN LAWYERS’MOVEMENT. 19, 301-315.
WILSON, J. D. J. M. L. 1985. Re-thinking penalties for corporate environmental offenders: A view of the law reform commission of Canada’s sentencing in environmental cases. 31, 313.
ZAFAR, S. & MUHAMMAD, F. 2022. Impact of Destructive Leadership and Corporate Governance on ethical practices in the Financial Sector of Pakistan. Durham University.
ZAIDI, S. A. J. J. O. D. 2008. Pakistan after Musharraf: An emerging civil society? 19, 38-40.
1JSPS Fellow (Japan), ICFJ Fellow (USA), IAF Fellow (Germany) Advocate High Court, Lahore, Pakistan
2 AHMED, Z. S. & STEPHAN, M. J. J. D. 2010. Fighting for the rule of law: civil resistance and the lawyers’ movement in Pakistan. 17, 492-513.
3 AL-NAJJAR, S. A. A. & SAEED, H. G. J. U. J. O. S. S. 2021. Ronald Dworkin and Human Dignity as Highest Constitutional Value: Philosophical Theorization of Rights and Human Dignity in a Comparative Perspective. 5, 82-89.
4 ANDERSEN, L. R. 2013. How the Local Matters: Democratization in Libya, Pakistan, Yemen and Palestine, DIIS Report.
5 CAIN, A. J. I. A. 2012. Foreign bribe prosecutions rising: Transparency International reports inconsistent enforcement of OECD’s Anti-bribery Convention. 69, 13-15.
6 CAMDESSUS, M. 1998. The IMF and good governance. Navigating Stormy, Uncharted Waters. International Monetary Fund.
7 DE SWARDT, C. 2021. 1993–2020: TI: A Short History of Holding the Powerful to Account. Silencing a Whistleblower. Springer.
8 GISSELQUIST, R. M. 2012. Good governance as a concept, and why these matters for development policy, WIDER Working Paper.
9 GRINDLE, M. J. P. I. T. M. 2012. Good governance: The inflation of an idea. 259-282.
10 KHAN, A. J. J., MAY-DECEMBER 2007. The Lawyers’ Movement in Pakistan.
11 KHAN, M. 2019. Empowerment without Accountability? The Lawyers’ Movement in Pakistan and its Aftershocks.
12 KHAN, N. U. J. S. A. S. 2020. Constitutional Manacles on Superior Court’s Jurisdiction and Recent Scenario on Public Interest Litigation in Pakistan. 33.
13 KHAN, S. A. 2021. Judicial Independence in Pakistan: A Case Study of Lawyers’ Movement, 2007-2009. West Virginia University.
14 KHAN, Z. & JOSEPH, B. J. J. O. D. 2008. Pakistan after Musharraf: The media take center stage. 19, 32-37.
15 KYRIACOU, A. P., MUINELO‐GALLO, L. & ROCA‐SAGALÉS, O. J. P. I. R. S. 2015. Fiscal decentralization and regional disparities: The importance of good governance. 94, 89-107.
16 RAHMAN, K., ROBERTO, M., KUKUTSCHKA, P. & COOKSEY, B. 2019. Overview of corruption and anti-corruption in Tanzania, JSTOR.
17 SHAFQAT, S. J. L. & INQUIRY, S. 2018. Civil society and the lawyers’ movement of Pakistan. 43, 889-914.
18 SIDDIQUE, O. 2010. Law In Practice–The Lahore District Courts Litigants Survey. Lahore, Pakistan: Development Policy Research Centre, Lahore University of ….
19 STARKLOFF, R. 1999. Farmers’ participation, empowerment and the institutional reform of Pakistan’s irrigation and drainage sector: key concepts and farmers’ perceptions, IWMI.
20 SULEHRY, R. S. & WALLACE, D. J. P. S. J. O. A. O. E. E. 2022. IDENTIFYING THE BLIND SPOTS: A CRITICAL ANALYSIS OF THE EXISTING ACADEMIC DISCOURSE ON THE PAKISTAN LAWYERS’MOVEMENT. 19, 301-315.
21WILSON, J. D. J. M. L. 1985. Re-thinking penalties for corporate environmental offenders: A view of the law reform commission of Canada’s sentencing in environmental cases. 31, 313.
22ZAFAR, S. & MUHAMMAD, F. 2022. Impact of Destructive Leadership and Corporate Governance on ethical practices in Financial Sector of Pakistan. Durham University.
23ZAIDI, S. A. J. J. O. D. 2008. Pakistan after Musharraf: An emerging civil society? 19, 38-40.