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Submission to Sixth Central Pay Commission By IPS (Central) Association December 2006

IPS (Central) Association


IG Northern Sector st 1 Floor, West Block 8 Sector 1 RK Puram New Delhi 110 066

-----------------------------------------------------------------------------------------------------------------------------December 29, 2006 The Chairman Sixth Central Pay Commission New Delhi Sir Submission on behalf of IPS Officers India is in the midst of a revolution; a transformation driven by an era of unprecedented economic reform and increasing interest from the world at large. We are fortunate to be rated amongst the most attractive investment destinations by the likes of the Economist Intelligence Unit (CEO Briefing) and Goldman Sachs (BRIC Report covering Brazil, Russia, India and China). We have also witnessed a distinct rise in investor confidence through enhanced ratings by Moodys as well as Standard & Poor. These developments have manifested themselves in the form of record levels of foreign investment and domestic growth rates. While greater integration with the global economy has facilitated development, it is also brought with it an increasing divide between the urban and the rural, between rich and poor, and equally, between the private and the public sector. More than ever before, we are living in an age of uncertainty, economic disparity and rising social tensions. At another plane, the country is also witnessing an alarming rise in armed militancy. Whether it is the foreign inspired low intensity conflicts in J&K, the long drawn fissiparous struggles in the North East or the Left Wing Extremist inspired armed struggles in many states across the country, at no time in the history of our Nation have we faced so many serious threats to Internal Security. Police leadership is a crucial player in this arena. By creating a climate of peace and security it contributes to national growth and globalization and is therefore a partner in overall development of the country and not merely an enforcement agency. The adverse international scenario of unfriendly border States such as Pakistan, Bangladesh, China and self-determination movements in Sri Lanka and Nepal, has intensified dramatically in the last few years. Global terrorism and resultant international response has further enhanced the need for security consciousness, skill enhancement and upgradation of levels in all spheres, particularly the leadership of the Indian Police. An IPS officer is typically recruited as a mid-twenties, young academic with 30-40% of them holding professional degrees. To attract and orient the officer to combat severely life-threatening situations such as those in various parts of the North-East, the Naxal-ridden States and J&K, is not just a matter of skill upgradation but that of emoluments, compensation and comparability with other avenues available to modern day professionals.

It has been a decade since the Fifth Pay Commission reviewed the structure of emoluments of the personnel of the All India Services, including those of IPS officers. The Indian Police Force is undergoing a process of metamorphosis across the ranks from a lathi wielding guardian of law and order to a sophisticated and technology savvy officer and a gentleman. There is increased pressure from society at large for the police to measure up as the worlds best, to increase accountability and contribute effectively to the process of development. There is pressure from within the political system to deal with the growing complexities of crime and insurgency. Clearly, as a country, we cannot afford to subject such an important arm of the State to suffer the depredations of lag, subsequent inefficiencies and resultant failure. It is in light of this environment of constant change that we seek support of the Sixth Central Pay Commission in alleviating some of the major difficulties faced by the Police Force. The attached document, which is being submitted in hard copy along with an electronic copy on CD as well as by e-mail, summarises our concerns, hopes and aspirations. We sincerely wish that the Pay Commission would take steps to restore the pride of the police and make suitable recommendations to enable the service to attract, retain and motivate its members as we continue to make our best contribution in service of our countrymen. We would greatly appreciate an opportunity to present the salient points emerging from the attached Submission in person before the Pay Commission. We would be happy to provide a copy of the presentation a week in advance of the specified date. We would also request permission for submission of supporting documents, statistics, etc, in furtherance of the points made in this Submission, within 15 days of this Submission. We look forward to hearing from you. Yours faithfully

Rajiv Singh Joint Secretary, IPS (Central) Association, and SP, CBI

CONTENTS
Page

I. II. III. IV. V. VI.

Context & Purpose1 Principles of Wage Determination..2 Work Environment.4 Inadequate Attractiveness as a Career11 Response to Questionnaire20 Summary of Submission.....32

Submission by IPS (Central) Association

I.

CONTEXT & PURPOSE

The Government of India has been giving due consideration to the changes that have taken place in the past with respect to the structure of emoluments of Government employees over the years. The conditions have also changed in several respects since the last Pay Commission made its report in 1997. With regard to the change in structure, the 6th Central Pay Commission has been appointed with specified Terms of Reference as under: To examine the principles that should govern the structure of pay, allowances and other facilities/benefits 1. To transform Central Government Organizations (CGO) into modern professional and citizen-friendly entities which are dedicated to the service of the people. 2. To work out a comprehensive pay package suitably linked to promoting efficiency, productivity and economy through rationalization of structures, organizations, systems and processes 3. To harmonise the functioning of CGO with demands of the emerging global economic scenario 4. To examine the principles which should govern the structure of pension, death-cumretirement gratuity and family pensions 5. To make recommendations with respect to the general principles and feasibility of introducing a Productivity Linked Incentive Scheme 6. To examine desirability and the need to sanction any interim relief With reference to these TOR, the IPS (Central) Association is taking the opportunity to voice its demands for enriching the prospects of IPS officers and simultaneously making the emoluments more attractive for young professionals, who otherwise would find gainful employment in the ever-expanding and highly remunerative Indian corporate sector. The adverse international scenario of unfriendly border States such as Pakistan, Bangladesh, China and self-determination movements in Sri Lanka and Nepal, has intensified dramatically in the last few years. Global terrorism and resultant international response has further enhanced the need for security consciousness, skill enhancement and upgradation of levels in all spheres, particularly the leadership of the Indian Police. An IPS officer is typically recruited as a mid-twenties, young academic with 30-40% holding professional degrees. To orient the officer to combat severely life-threatening situations such as those in various parts of the North-East, the Naxal-ridden States and J&K, is not just a matter of skill upgradation but that of emoluments, compensation and comparability with other avenues available to the youngsters of today.

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Submission by IPS (Central) Association

II.

PRINCIPLES OF WAGE DETERMINATION FOR THE IPS

In the USA, the period since the late sixties, the public sector wage setting policy has been guided by the objective of achieving equality in pay. This comparability principle stems from the fact that the public (government) sector is not a profit making institution and, therefore, cannot depend on any market-determined wage. But it can depend on the private sector where wages are determined by the market forces. Thus legislation in the USA now requires that the pay in the public sector be made comparable to that in the private sector (Choudhury, 1994). Pricing Theory for a Police Commanders (IPS officers) salary depends on the following factors, non-existent in other, comparable Govt. jobs: 1. 2. 3. 4. 5. 6. 7. 8. Threat to life Risks of assault and injury; Long working hours (without overtime) Working on holidays (without compensation) Deprivation of the Fundamental Right to expression (without compensation) Disruption of family life; Higher degree of stress Ever changing nature of skill-set on account of organized crime and terrorism, requiring constant upgradation

The Sheehy Commission (UK) appointed in July 1992 under the chairmanship of Sir Patrick Sheehy to examine the rank structure, emoluments and conditions of service of the police in England and Wales, Scotland and Northern Ireland submitted its report in June, 1993. Some important observations / recommendations of the Commission are reproduced below: a. Police officers are ordinary citizens with extraordinary powers. They have a special position under the law. b. A number of features are particular to policing and require its officers to possess special qualities and skills. These include the extraordinary nature of police power, principally the police monopoly on the use of legitimate force. c. Also notable is the degree of individual discretion, which the law vests in each officer, irrespective of rank or length of service. d. Acute, unforeseen, demands face officers when, for example, they take operational command in public order incidents and emergencies. e. The police are expected to exercise control in sensitive, quite often dangerous and sometime explosive situations, often at considerable risk to themselves. f. An exceptional high level of integrity is required by the very nature of policing. g. to recognize the importance of securing the recruitment, retention and motivation of officers of the right quality. h. We accordingly consider that the benchmark for police pay levels should be the median of private sector pay. i. We recognize that this recommendation will break the existing pay link between the rate for the Commissioner of Police of the Metropolis and the rate for the Permanent
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Submission by IPS (Central) Association

j.

Secretary of the Home Department. We recommend that the link should be broken; in our view the special features of policing mean that the jobs are not comparable. We recommend that one-off non-pensionable individual bonuses should be available as should team bonuses.

The Prime Minister of UK earns GBP 186,429 a year The Police Commissioner of the Metropolitan Police of London earns GBP 210,000 per annum i.e. nearly Rs. 2 crores per annum.

All the above observations / recommendations of Sheehy Commission are fully relevant to the Indian Police, since there are no differences in kind in the basic functioning of the police in any country the differences in any, can be of the degree of arduousness, of the variety of problems, of the enormity of challenges and of the level of sophistication of the crimes and the crime preventing and detecting apparatus. The police role in India is as, if not more, exacting and risk-prone as in other countries including Britain on account of the wider canvas of the police role in the country, and greater hazards emanating from the menace of terrorism, religious fanaticism, secessionism, militant movements and naxalite violence. The Sheehy Commissions recommendations regarding the need for raising the police relativity and erecting the superstructure of police hierarchy on purely professional lines without unnecessarily being bogged down with the archaic system of maintaining pay linkage with other wings of the civil service are, therefore, as much relevant to India as to Great Britain.

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Submission by IPS (Central) Association

III.

WORK ENVIRONMENT

Terrorism

Terrorism is not simply a series of incidents or an inventory of casualties. It is an extremely lethal low-intensity-Iow-cost instrument used by State and non-State actors to manipulate the policies and socio-political and religious agendas of target countries. The phenomenal growth in the spread, reach, networking and lethality of terrorist groups has ensured that wars are no longer confined to borders but are constantly waged in the unsuspecting heartland. It is, therefore, one of the key factors in national security planning and the principal challenge at the global and regional levels. As far as changes in the character of terrorism are concerned, the short point is that terrorism is no longer a localized phenomenon as earlier. It is not dependent on local issues or local resources nor is its impact and target confined to a local area. This can be vividly seen in the dramatic changes in its infrastructure. The focus of terrorism in Kashmir has been expanded and significant effort was being expended in organizing terrorist acts in the Indian hinterland. The target profile now covers individual and institutions over the entire spectrum of political, security, social, and economic activity. Iconic targets (Parliament, Red Fort, IMA, NPA etc) are being consciously selected. A significant part of the weaponry, funds, planning and guidance come from Pakistan. The planning of terrorist groups to target nuclear plants (e.g. Kaiga), dams etc which had the potential for mass destruction, needed to be viewed with concern. In the recent incidents, national destabilization - and not simple terrorism - was the objective. The fidayeen attack in Ayodhya, blasts in Varanasi and Delhi, attack on religious shrines such as the Raghunath temple in J&K, Akshardham in Gujarat, attempted attack on RSS headquarters, selective mass killing of Hindus in Doda etc. are incidents that have the potential of precipitating communal conflagration on a large scale. The emergence of left wing extremism is a matter of serious concern. The groups have consolidated their ideological position and have overcome the earlier fragmentation by reuniting the major groups. This has resulted in a major resurgence not only in violence but also in the area of operation, which now extends from Kerala to Bihar in what is known as the "Compact Revolutionary Zone". Fraternal linkages have given these groups access to the terrorist outfits in the North East, further expanding their reach and lethality. Growing international linkages and the emerging fraternity of left extremist formations through increased coordination, indicate that it is the most significant evolving threat to national security.
A very conscious police force using a combination of human intelligence and with connectivity across police forces in many states is the need of the hour. Such a modern police force can effectively contribute to the eradication of the terrorism and extremism so that the nation can pursue its cherished goal of a developed India in a more focused way. - Dr APJ Abul Kalam, at the inauguration of the International Seminar on Criminal Justice under Stress: Transitional Perspective November 24, 2006

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Submission by IPS (Central) Association

In the North-East, constructive engagement with certain groups has led to significant progress. While the violence profile is under control, a new dimension is the effort of other insurgent groups in Assam, Manipur are trying to mobilise the support and sympathy of the large section of the people through contacts, media etc and inciting innocent people against the security forces to create confrontation. New technologies open up many avenues of criminal activities. Financial and high-tech crimes currency counterfeiting, money laundering, payment card fraud, computer virus attacks and cyber-terrorism for example can effect all levels of society. Funds and financing channels are no longer confined to resources locally mobilized through individual contributions, extortion and crime. They are generated globally through a gamut of activities including narco-trafficking, money-laundering, cover businesses and trade, donations and collections from religious congregations and in no small measure, through State funding. All channels, legal or otherwise, including through organized crime, are available and extensively utilized by terrorist groups.
Crime

Over the years the police force has had to transform from an essentially rural, feudal, autocratic organisation to a rural-urban-metro mix, sophisticated, tech-savvy, democratic entity, without any change in the statutes that form the foundation. Similarly, the IPS, as leaders, have developed appropriate tech-skills such as digital orientation, communication sophistication and managerial development, to be able to handle the vastly complex and everincreasing race to handle the growing needs of galloping population growth and unrestrained urbanization. Property Crime has shifted from village based thefts and robberies worth hundreds and thousands to bank robberies and cyber crimes of the magnitude of many crores. Body offences have transformed from being easily identifiable given established enmity to that of faceless, cross border, hired criminals and organized gangs. Given extended real estate prices and enormous Govt. tenders, land mafia and contract mafia have raised the threshold of the response required from an IPS officer.
Year 1981 1986 1990 1996 2000 2004 IPC Crimes in millions 1.39 1.41 1.66 1.71 1.77 1.83

Source: Indiastat.com

The table above shows that there has been a steady rise in IPC Crime in the past 14 years. Since the last Central Pay Commission there has been a 7% rise in the crime rate. This is despite the fact that there are problems with regard to widespread under-reporting/nonregistration of crime one of the largest challenges before the police leadership.

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Submission by IPS (Central) Association

Public Order

The ever-increasing levels of population and declining levels of the police to population ratio has caused severe strain to manpower resources in handling breakouts of violence such as those related to communal, caste or other sectarian conflict. The traditional lag with which police recruitment follows population growth, tends to exceed a decade in many States. As a result, the IPS officer (1:2,50,000 in India and 1:25,00,000 as a district SP) is under great stress and pressure to prevent, combat and contain public order break-outs. In order to maintain law and order it is essential to have a good police to population ratio. As opposed to the trend in the 1980s the police force has been growing at a higher rate than the population of the country. From the graph below it can be seen that in the past 5 years the police force growth has been higher than the population growth but the police to population ratio in the country is still very low, considering the increase in crime across the country.
8.00% 7.00% 6.00% 5.00% 4.00% 3.00% 2.00% 1.00% 0.00% 2000 2001 2002 2003 2004 2005 2006

Population growth

Police force growth

The ratio of Police to Population for various nations are presented below to show the abysmal figures for India and the resultant pressure on the police leadership.
People to police ratio Bangladesh 1:1200 India 1:712 Phillapines 1:665 Pakistan 1:625 Japan 1:563 Canada 1:529 New Zealand 1:416 England & Wales 1:393 South Africa 1:325 Scotland 1:323 Singapore 1:295 France 1:255 Malaysia 1:249 Thailand 1:228 Hong Kong 1:220 Country
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Submission by IPS (Central) Association

Stress

It is noticed that the underlying cause of stress in the force are derived from the nature of its deployment with 85% of the police in operational areas in difficult counter-insurgency duties or in difficult isolated areas under adverse climatic conditions, negligible peace slots for posting and therefore little chance for turnover of a war zone into a peace zone, there being a large number of vacancies and consequent increase in workload and all the negative concomitants that emanate from such a profile. The working hours are not fixed and can be long and strenuous of more than 13 hours a day.
It is found that the number of police with measurable mental illness has doubled over the past 10 years.

As compared to civilian employees, police personnel have always been on duty on Sundays and closed holidays. Civilian employees who perform extra hours of duty get Over Time Allowance (OTA) which is not extended in the case of Police personnel. Civilian employees who perform duties on Sundays and closed holidays get compensatory leave is also not extended to Police personnel. Therefore, Police personnel have to work through out all days. Extra days work being done by Police personnel compared to other civilian employees of Central Government are as under: 1. 2. 3. 4. 5. Number of Sundays Saturdays Gazetted Holidays Total Proportionate deduction for 2 months when POLICE personnel remain on leave as an average (10 weeks). 6. Excess working days for Police personnel. : : : : : 52 52 15 119 25

94

Police personnel perform duties for 94 non working days compared to their counterparts in civilian departments. The table below gives details on the extra hours of duty for police personnel.
Hrs of duty by Civilian employees for five day week 08 40 200 Hrs of duty by Police personnel for 7 days 20 140 560 Excess hours of duty by Police personnel 12 100 360

Details

Duty per day Duty per week Duty per month Duty per year or 10 months (less leave) Difference of extra hours of duty converted into days per year.

2000 -

5600 -

3600 450

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Submission by IPS (Central) Association

Sectional view of above tables clearly indicates that Police personnel are performing 2 times more duty than an average civilian staff; however, while talking about pay and other benefits they are compared with civilian staff working in other central Government departments. An average civilian staff has to work for 2000 hours a year while Police personnel are compelled to perform for 5600 hours i.e. 3600 hours extra hours. The civilian employees are entitled to Over Time Allowance if they are put on extra duties. The table below indicates the duty performed by police personnel on gazetted/closed holidays.
Being Being availed by availed Difference Civilian by Police employees personnel

Details Number of Closed Holidays per annum Closed Holidays i.e. Saturdays and Sundays Total

15 94 109

15 94 109

Police personnel can be posted at different, uncertain locations at short notice, making their life nomadic and unsettled. Many a times the staff resides in deplorable living and working conditions, aggravating stress. A survey carried out by the Bureau of Police Research and Development (BPR&D) in the year 2000 showed:
As many as 2846 Police Stations and 2797 Police Outposts, besides 799 SDPO offices, 180 SP offices and 67 Range DIG offices did not have proper, official buildings and were functioning from makeshift arrangements. While 30% of the districts had makeshift Police Lines, about 60% of the districts did not have proper Police Control Rooms.

On account of the above mentioned reasons for stress among police, there are alarming suicide rates concerning them.
In 2004, 70 Police Personnel committed suicides in the country. This has gone up to 176 in 2005 showing a more than 100% increase in the suicide rates.

Besides suicide trends, what is worse is the homicidal trends in the police force because of the highly negative impact they have on society at large and within the forces in particular. Such acts are qualitatively different from similar occurrences in society in general as they indicate a propensity amongst men especially recruited, armed and trained at the expense of the state exchequer to achieve a particular objective and instill confidence in the people at large, turning upon their own colleagues and comrades in arms.

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Submission by IPS (Central) Association

Also, in recent years police personnel have developed proficiency in the responsibility of protecting VIPs who are threatened by militants and other hostile forces. Quite a large number of personnel have sacrificed their lives in the line of duty. The graph below depicts the police personnel which have been killed/ injured on duty.
4500 4000 3500 2975 3000 Number 2500 2000 1500 1000 500 0 2001 2002 2003 Total Killed 2004 2005 828 781 827 830 805 2350 2918 3936 4005

Total Injured

Based on the facts mentioned above IPS officers are facing immense levels of stress as they are expected to manage a force which is under immense pressure. They need to provide counseling, leadership and motivation to men working under these conditions which calls for extra efforts, stress and strain as the resources are limited. To keep the morale of men working under these conditions and to make them deliver results is even tougher.
Stress Survey Saharanpur (UP) March 2005 (published in Hardnews, July 2005)

A study based on the questionnaire method and covering 828 policemen of all ranks of Saharanpur district in UP was conducted in 2004-05. All of them were administered a 41-point questionnaire and were asked to mark out the felt-stress on each issue on a grade of 1 to 5. It was found that motivation surfaced only when offered postings of pecuniary benefit, with very few police personnel today working for status, honour and prestige. They showed reducing levels of loyalty to the department and exhibited no desire to work selflessly for the nation. Their concerns were more towards their hitherto neglected families and an undying urge to live a normal, dawn to dusk, life. The average level of stress was at an astounding 78 per cent. A similar sample survey of 30 respondents each was conducted on administrative clerical staff in the District Magistrates office, which showed an average of only 48 per cent.

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Submission by IPS (Central) Association

Concern for family was an important stressor touching 88 per cent. The children's future, inability to live with family, lack of leave when most required and shortage of time for personal work were important attributes. Also, the instability quotient of mid-season and very frequent transfers caused 10 per cent more than average stress. The level of stability in the police force was the least, being inversely proportional to the rank - transfers at higher levels being more frequent whereas the mid-season malaise was equally proportional across all ranks. No time for physical exercise, night duties, irregular eating hours and lack of proper food while on duty led to a stress level of 85 per cent. The highest stressor, at 91 per cent, was inequity in work distribution a cemented, perceived notion that exists in almost the entire police force that they are doing much more work for much less. A police officer puts in a minimum 84 hours a week and has a long, unending seven-day week. He compares very poorly to the government clerk, a better paid third class employee who does work 40 hours a week, has the weekend off, is rarely on call, has a relaxed workplace and is fully able to utilise leave. Also, there is almost no risk of injury in the work place for the average clerk, a factor that stresses the constable 83 per cent. One could think that a compensatory allowance or a higher salary would be in place to compensate for this attendant risk. There is nothing of the sort. The only dole is the paltry ex-gratia payment handed to the family in the event of a death on duty. An allied stress factor of 88 per cent is due to insufficient salaries. Caste-based discrimination scored an 89 per cent stress factor. Another high stress factor is the anti-police outlook of the media.
Enhanced responsibility and transparency The police in modern India must become partner in development. It is an essential component of our institutional framework to ensure economic prosperity of our people. - Dr Manmohan Singh, PM, India at DGsP/ IGsP Conference, November 23, 2006

The growth of human rights movements and public pressure groups, all across the country, has enhanced the visibility, transparency and answerability of the IPS all over the country. The NHRC and other watch groups have been instrumental in engineering attitudinal change in the outlook and skill set required to tackle such situations. The onset of the electronic media and the ever-increasing depth of the vernacular press has also led to a new pressure group that presents variegated challenges to the leadership.

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Submission by IPS (Central) Association

IV.

INADEQUATE ATTRACTIVENESS AS A CAREER

Low levels of professional intake

In comparison to the high intake of IIT/IIM graduates in the AIS and IPS in the 1970s and 1980s, the figures for the last ten years have shown an abysmally low level of professional intake.
IIT/IIM intake in the IPS (%) 100%

80%

60%

40%

20%

0% Others IIM IIT

1996 134 0 13

1997 119 6 12

1998 132 2 13

1999 68 0 5

2000 31 0 2

2001 23 0 10

2002 30 0 2

2003 43 0 6

2004 65 0 13

2005 64 0 15

2006 83 0 15

Non-IIT Engr / Non-IIM MBA intake in the IPS (%)

100%

80%

60%

40%

20%

0% Others Non-IIM MBA Non-IIT Engr

1996 131 1 15

1997 103 6 28

1998 123 3 21

1999 64 1 8

2000 20 2 11

2001 29 3 1

2002 25 2 5

2003 40 3 6

2004 68 2 8

2005 57 4 18

2006 82 4 12

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Submission by IPS (Central) Association

The number of IIM PGDMs are almost insignificant and those from IITs are in the 10-20% range (except one exceptional year 2001). A further study of all non-IIT Engineers and nonIIM MBAs also exhibits much the same trend, as shown below The total of non-IIT and non-IIM professionals varies from 10-23% per batch. The increasing lure of corporate salaries of the highest magnitude, are a clear reason for the AIS and the IPS not being able to attract the best talent, with brain drain occurring for the nation and also the Govt.
Equanimities with regard to sister services

There are also stark differentials in the eligibility for IPS for holding posts in the central Government compared with the IAS. As per the MHA, the eligibility for holding post in the central government is 18 years for the IPS post of IG and 26 years for the IPS post of ADG. As per the DOPT, the eligibility for holding the IAS post of joint Secretary at the Centre is 17 years and for Addl. Secretary its 25 years. According to these provisions there is a differential of one year between the IAS and IPS postings at the Centre with in actual practice extends to two years.
The incentive to grow to higher levels within the hierarchy has been diminishing over time in terms of net salary in hand. In 1947, the ratio of DGs salary to that of the constable was 30. This reduced to 13.5 in 1976 and further to 8 times in 1996.

Similarly there is differential when it comes to empanelment at the level of the Secretary to Government of India and DG of CPMFs/ CPOs. The situation is particularly bad when it comes to the placement of IPS officers at the level of Joint Secretary to the Government of India. There is a requirement of the IPS officers being empanelled at the level of IG as a pre requisite to empanelment at the level of Joint Secretary. This should be done away with and IPS officers who have put in 17 years service should be considered for empanelment simultaneously for the post of IG as well as Joint Secretary by making photocopies of their CC rolls. In the same manner, doing away with the existing differential in the empanelment and placement at the level of Joint secretary, Addl. Secretary and Secretary to the Government of India on one hand and IG, ADG and DG at the Centre on the other, will not dilute the superiority of the IAS. Both, the IAS and the IPS applicants give the same exam which is the Civil Services exam. Except for the candidates who specifically opt for IPS, those with a higher score get allotted to the IAS. This reinforces the fact that the IAS is no doubt a premier service which will remain so even after pay parity with other AIS and doing away with empanelment and placement in different senior level posts at the Centre. With respect to the pay parity between the IPS and IAS, it is at par at the level of Junior Scale, Supertime scale and Above Supertime scale.

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Submission by IPS (Central) Association

Scale of Pay wef 1st Jan' 1996 Time Scale Senior Scale Junior Scale i) Time Scale ii) Junior Administrative Grade iii) Selection Grade

Grade IAS Rs. 8000-275-13500 Rs. 10650-325-15850 Rs. 12750-375-16500 (Non Functional) Rs. 15100-400-18300 Rs. 18400-500-22400 IPS Rs. 8000-275-13500 Rs. 10000-325-15200 Rs. 12000-375-16500 (Non Functional) Rs. 14300-400-18300 a) DIGRs. 16400-450-20000 b) IGRs. 18400-500-22400 IFS (Indian Forest Service) Rs. 8000-275-13500 Rs. 10000-325-15200 Rs. 12000-375-16500 (Non Functional)

Super Time Scale

i) Rs. 22400-525-24500 Above Super Time Scale ii) Rs. 26000 (Fixed) iii) Rs. 30000 (Fixed)

Rs. 14300-400-18300 Conservator of Forests Rs. 16400-450-20000 Addl. Chief Conservator of Forests/ Chief Conservator of Forest Rs.18400-500-22400 i) ADGPi) Addl. Principal Chief Conservator of Forest Rs. 22400-525-24500 Rs. 22400-525-24500 ii) DGPii) Principal Chief Conservator of Forests Rs. 24050-650-26000 Rs.24050-650-26000 -

Taking into account the daunting challenges confronting the IPS officers as detailed above, there doesnt seem to be any reason why this pay parity should not be extended right across all the pay scales. The fact that such pay parity exists at the lower levels of IPS and IAS means that both the services are important and does not detract from the importance of the post of commissioners and secretaries and principal secretaries to the Government.
Inability to attract the best given corporate sector remuneration

Subsequent to the opening of the Indian economy in the 1990s salaries in the private sector have increased tremendously. The Government had an important role to play in the salary boom of that period. It initially raised the ceiling on remuneration of managerial personnel and later relaxed the ceiling for profit making companies. In the past 5 years there has been a 7 fold increase in the CEO salaries. According to a survey by Hewitt Associates, a global human resource firm, India has the maximum salary increases in the Asia Pacific region of around 13% in the year 2005 and in 2006 the Hewitt report reveals 14% increase in the same. The trend of increasing salaries in the Indian Private sector is owed to 1. Globalization and the increasing importance of the Indian economy in the todays world scenario. India is now seen as a major market not just a mere back office operation destination. 2. There is a very high demand for skilled and talented people at the executive levels. If the demand continues to outweigh the supply then one can expect salaries to increase a great deal in the future. The table below enlists a few CEO/ Directors in the private sector and their annual remuneration:
Name V Bali Deepak Parekh K Venkataraman C Jayaram Ravi Kant Company Designation Salary (in Rs mn) 25.58 24.89 22.27 17.66 16.98

Britannia CEO HDFC Chairman Larsen & Tourbo WTD & CFO Kotak Mahindra ED Bank Tata Motors MD

Source: Business India, November 5, 2006

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Submission by IPS (Central) Association

According to the 5th Central Pay Commission report, a seminar held in January, 1995 by the Centre for New Perspectives on the Salary System in the Government, the public servants argued for a comparable status with the private sector in respect of salaries. It was also argued that over offerings by multinationals to the fresh IIT and management graduated, which were as high or higher in salaries of senior Government officials, were eroding the morale of all Government functionaries. Such glaring disparities between the pay structure in the Government and the private sector might create a serious crisis of talent especially at high levels. This disparity in the pay of the private and public sector salaries has caught a lot of media attention. In order to have first hand information the Pay Commission in 1997had appointed Management Development Institute (MDI) , Gurgaon to carry out and objective assessment of the situation comparing the salaried and the perquisites obtained in the Central Government as opposed to those in the private sector. After making some assumptions regarding the comparable levels in the private sector and the government and other assumptions regarding the non quantifiable benefits MDI had computed the average cost to the organization of maintaining officers at various levels in the Government and the Private sector. Some of the key findings of the study are enlisted below: 1. The Secretary to the Government of India (GoI), on an average, costs his employer around half of what a CEO costs his employer in the private sector 2. The CEO of the private sector draws and incentive of 65% of his basic salary, the secretary does not earn any payment of this nature. 3. CEOs on the private sector enjoys a little more than their basic salaries in the form of housing and car benefits. The secretary too enjoys such benefits but not of commensurate value 4. A CEO in the private sector draws sundry allowance such as books and periodicals, club memberships, credit cards, LTC, medical entertainment, services and amenities, servants etc. which is nearly 55% of his basic salary. Whilst the Secretary to the GoI is entitled to some medical benefits and LTC by rail only which could constitute 16% of his basic. 5. A Head of Department (HoD) gets about 40% lesser than his CEO. However in the Government the differential between the emoluments of a Secretary and the joint secretary is very little. Another important fact which comes to light is that the HoD has approximately 8-10 years of work experience and a Joint Secretary would have approximately 16-22 years in service. 6. In some cases the entry level executives reach a compensation level that is nearly 2 times the compensation at the highest level available in the government. 7. In the private sector performance criteria are well laid down and salaries are revised annually. 8. Amongst the non-executives in the private sector it is observed that there is a high degree of flexibility and multiple functionality 9. Salaries are deliberately structured in the private sector so that the employee is able to save on income tax. A significant component of the pay in the private sector is that of cash allowance, which are given as reimbursements.

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Submission by IPS (Central) Association

From the above highlights of the study, it is evident that there is a vast gap between the salaries and benefits available in the private sector and the public sector. Even though this study was conducted in 1997, a recent article in the Business India November 5, 2006 on the salaries in the private sector gives ample evidence that this gap would only have widened over the years. The main points in this article made are: 1. Salaries of Indias highest paid executives have been hitting new peaks and much faster than ever before 2. Salaries are increasing in this manner owing the wide gap in the demand and supply of skilled and talented executives 3. Performance is the prime parameter 4. India had maximum salary increase in the Asia Pacific region
Cost of owned housing

As property prices in metros are shooting up, Tier I and Tier II cities are following the trend. With the onset of foreign investment in real estate, prices are expected to continue to rise at approximately 20% per year. The property market is growing rapidly mainly due to the expansion of information technology industry and the simultaneous growth of its middle class. Retail and residential development is growing even faster. The investors favorite markets are the growth centers of Bangalore, Bombay, Hyderabad, Madras, and Gurgaon, New Delhi and all its surroundings, Pune in the west, Jaipur and Chandigarh in the north, and Calcutta in the east. Prices in prime areas in Mumbai are as high as Rs 50-70,000 per square foot and Rs 1,00,000 per sq ft in Delhi and the NCR (National Capital Region) - almost three times than prices in New York. A survey, based on empirically observed data and figures published in Outlook Money, was undertaken to ascertain the average cost of a 3 bedroom and a 2 bedroom flat in the 4 metros and the NCR. The assumptions were: 1. A 3 bedroom flat is 1,500 sq. ft super area 2. A 2 bedroom flat is 1,200 sq. ft super area 3. Premium localities have been excluded from the survey 4. Only rates for apartments have been surveyed 5. Upper-middle class localities have been included

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Submission by IPS (Central) Association

Average rates of flats in metros

City Delhi Delhi Gurgaon Noida Mumbai Mumbai Faridabad Kolkata Kolkata Chennai Chennai

Area GK, South Ex, Delhi Punjabi Bagh, Delhi Gurgaon Noida Vile Parle, Mumbai Goregaon, Mumbai Sector-10-20, Faridabad EM Bypass, Kolkata Salt Lake, Kolkata Basant Nagar, Chennai Shastri Nagar, Chennai

Range (Rs/sq ft) 8000-12000 12000 - 18000 6500 - 9500 7000-9000 5,411 - 8,411 4,411 - 6,011 2700 - 2880 2,500 - 3,000 2,600 - 2,700 2176 - 2226 1716 - 1866

Average (Rs/sq ft) 10,000 15,000 8,000 8,000 6,900 5,200 2,790 2,750 2,650 2,200 1,790

Average cost of flats (as on 27 Dec, 2006):

Area GK, South Ex, Delhi Punjabi Bagh, Delhi Gurgaon Noida Vile Parle, Mumbai Goregaon, Mumbai Sector-10-20, Faridabad EM Bypass, Kolkata Salt Lake, Kolkata Basant Nagar, Chennai Shastri Nagar, Chennai

Flat Area in sq. ft. (3 bedroom) 1,500 1,500 1,500 1,500 1,500 1,500 1,500 1,500 1,500 1,500 1,500 India Average

Cost in Rs (3 bedroom)

Flat Area in sq ft (2 bedroom)

Cost in Rs (2 bedroom) 12,000,000 18,000,000 9,600,000 9,600,000 8,280,000 6,240,000 3,348,000 3,300,000 3,180,000 2,640,000 2,148,000 7,121,455

15,000,000 1,200 22,500,000 1,200 12,000,000 1,200 12,000,000 1,200 10,350,000 1,200 7,800,000 1,200 4,185,000 1,200 4,125,000 1,200 3,975,000 1,200 3,300,000 1,200 2,685,000 1,200 8,901,818 India Average

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Submission by IPS (Central) Association

Cost of Flats in Metros (Rs)


24,000,000 22,000,000 20,000,000 18,000,000 16,000,000 14,000,000 12,000,000 10,000,000 8,000,000 6,000,000 4,000,000 2,000,000 0 Goregaon, Mumbai Vile Parle, Mumbai EM Bypass, Kolkata GK, South Ex, Delhi Punjabi Bagh, Delhi Basant Nagar, Chennai Sector-10-20, Faridabad Salt Lake, Kolkata Shastri Nagar, Chennai Gurgaon Noida

Average Cost (3 Bed) Rs 89.01 lacs

Average Cost (2 Bed) Rs 71.21 lacs

Cost (3 bed)

Avg (3 bed)

Cost (2 bed)

Avg (2 bed)

An average price for each locality was calculated and then multiplied by 1500 and 1200 to arrive at the cost of the 3 and 2 bedroom flats, respectively. The highest prices here is in Delhi (Rs 1.5 2.25 cr), Gurgaon and Noida (Rs 1.2 cr) and Mumbai (Rs 1 cr). Apartment costs in Chennai and Kolkata were found to be lower at Rs 30 lacs and Rs 40 lacs, respectively. Though, the largest number of retiring IPS officers (40%) have been found to have settled in Delhi, Noida and Gurgaon, traditionally. The trend is expected to continue. The national average for a 3 bedroom flat was found to be Rs 89 lacs and for a 2 bedroom, Rs 71 lacs as on 27 Dec 2006. With a 20% growth in real estate prices, expected on reasonable assumption, these prices are expected to grow in the following way:

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Submission by IPS (Central) Association

Dec-06 Dec-07 Dec-08 Dec-09 Dec-10 Dec-11 Dec-12 Dec-13 Dec-14 Dec-15

Cost in Rs. (3 bedroom) 8,900,000 10,680,000 12,816,000 15,379,200 18,455,040 22,146,048 26,575,258 31,890,309 38,268,371 45,922,045

Cost in Rs. (2 bedroom) 7,100,000 8,520,000 10,224,000 12,268,800 14,722,560 17,667,072 21,200,486 25,440,584 30,528,700 36,634,440

On the basis of the above, the same flat will be valued at a national average of Rs 1.85 cr (3 bed) and Rs 1.47 cr (2 bed) in Dec 2010 and Rs 4.6 cr (3 bed) and Rs 3.66 cr (2 bed) in Dec 2015. Calculating further, data from the official website of Punjab National Bank revealed the following EMIs (Equated Monthly Instalments) for a Home Loan of Rs 1 cr.
EMI as per Punjab National Bank rates as on Dec 27, 2006

Loan Rs 1 cr 7.00% 7.25% 7.50% 7.75% 8.00% 8.25% 8.50% 8.75% 9.00% 9.25% 9.50% 9.75% 10.00% 10.25% 10.50% 77,520 79,030 80,550 82,090 83,640 85,200 86,780 88,370 89,970 91,580 93,210 94,850 96,500 98,160 99,830

Loan Loan Rs 89 lac Rs 71 lac 68,993 70,337 71,690 73,060 74,440 75,828 77,234 78,649 80,073 81,506 82,957 84,417 85,885 87,362 88,849 55,039 56,111 57,191 58,284 59,384 60,492 61,614 62,743 63,879 65,022 66,179 67,344 68,515 69,694 70,879

Assuming a Home Loan rate of 9%, an IPS officer would have to pay Rs 80,000 and Rs 64,000 per month for 20 years for a loan of Rs 89 lacs (3 bed national average) and Rs 71 lacs (2 bed national average), as on Dec 2006. In Dec 2010, it would grow to Rs 1.65 lacs and Rs 1.33 lacs per month and in Dec 2015, to Rs 4.12 lac and Rs 3.3 lacs.

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Submission by IPS (Central) Association

Dec-06 Dec-07 Dec-08 Dec-09 Dec-10 Dec-11 Dec-12 Dec-13 Dec-14 Dec-15

EMI in Rs. (3 bedroom) 80,000 96,000 115,200 138,240 165,888 199,066 238,879 286,654 343,985 412,782

EMI in Rs. (3 bedroom) 64,000 76,800 92,160 110,592 132,710 159,252 191,103 229,324 275,188 330,226

Further, taking the starting salary of a DIG (IPS direct recruit) with 14-16 years of service at Rs 16,400, in the pay scale of 16,400-450-20,000, he is currently eligible for a House Building Advance of 50x ie. Rs 8.2 lacs (though limited by a maximum ceiling of Rs 7.5 lacs). To afford a 3 bed flat in Dec 2006, he would need an HBA of 543x for a 3 bed flat and 433x for a 2 bed flat. Therefore, if the 6th Pay Commission approves a 4x (theoretically) factor for raise in Basic Pay, the HBA would have to be 136 times Basic for 3 bed and 108 times for a 2 bed apartment. All these figures are valid only for 2006. Besides taking price of housing in India alone into the purview of our analysis to judge the cost of living, we can also consider the trend in the Consumer Price Index (CPI) in the metropolitan cities of Mumbai, Delhi, Kolkata, Chennai and Bangalore. Since the last Pay Commission, this index has shown a rising trend which reinforces the fact that expenses borne by consumers have increased implying that not only houses but other consumer goods have also become expensive. In the above cities, it is seen that the CPI has risen by 66% since the last Pay Commission.
600 550 500 450 400 350 300 250 200 1996-97 1997-98 1998-99 1999-00 2000-01 2001-02 2002-03 2003-04 2004-05 2005-06 Mumbai Delhi Kolkata Chennai Bangalore

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Submission by IPS (Central) Association

V.

RESPONSE TO QUESTIONNAIRE

As specified on its website (www.indiagov.in/govt/paycommission.php), the Sixth Central Pay Commission has sought suggestions/ comments from public and other interest groups through a questionnaire covering various aspects of the structure of pay, allowances and other facilities/ benefits relating to the specified categories of Government employees. While some of the aspects referred to in the questionnaire have been discussed in detail in the preceding section of this Submission, the views of the IPS (Central) Association in response to the specific questions are summarised in this section. QUESTIONNAIRE 1. Comparison with public/private sectors 1.1 Should there be any comparison/parity between pay scales and perquisites in Government and the public/private sector?

Ans: An absolute comparison/ parity in this regard appears to be unfair. What might be fair is to compare the pay and benefits of Governmet servants with those of the private sector before 1989 and apply the ratio to the present scenario. (1989 has been selected as the notional beginning of liberalization in India) 1.2 Is it possible to quantify all other benefits, excluding pay, derived by employees in Government and the public and private sectors from security of tenure, promotional avenues, retirement packages, housing and other invisibles? In view of these benefits, can there be any fair comparison between the salaries available in the government vis--vis the salaries in the private sector?

Ans: All benefits other than job security can be quantified. However, job security is vital for the inefficient in Government service. Lack of job security in the private sector leads to efficiency and also gives an option for the employee to jump companies and get accelerated promotions. 1.3 In order to ensure a fair comparison based on principles of equity and social justice, would it not also be appropriate to take into account the economic conditions of large sections of the community that are less privileged than Government employees and many of whom live below the poverty line?

Ans: It would be unfair to compare the Government servants with the underprivileged in society. Government select the officers from among the cream of society. Persons with similar Knowledge and skills can and do get lucrative jobs in the private sector.

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Submission by IPS (Central) Association

2. International comparisons 2.1 Some countries have raised civil service pay scales almost to levels prevalent in the private sector on the hypothesis that a well-paid bureaucracy is likely to be honest and diligent. To what extent would such a hypothesis be valid and how far would such a course of action be desirable?

Ans: The hypothesis is equally valid in India. However, the dishonest and the inefficient have to be punished and weeded out ruthlessly. 3. Impact on other organizations 3.1 Salary structure in the Central and State Governments is broadly similar. The recommendations of the Pay Commission are likely to lead to similar demands from employees of State Governments, municipal bodies, panchayati raj institutions & autonomous institutions

Ans: This is natural. Such expectations have been raised in the past and have been met also. Remember, if you pay peanuts, you get only monkeys. Their paying capacity is considerably limited. To what extent should this factor be considered in devising a reasonable remuneration package for Central Government employees? 4. Salaries 4.1 How should we determine the salary to be paid to a Secretary in the Central Government? Please suggest an appropriate basic pay for a Secretary? Can appointment to this post be made on a contractual basis where salaries and tenure are linked to the performance in terms of achieving defined targets?

Ans: Unless a total reengineering is being considered by disbanding or marginalizing the All India Services, the salaries would have to be worked out within the present system. There is a case to Increase emoluments of the Secretary to Govt of India in the same percentage in which we increase the emoluments of other employees. It is difficult to fix any pre-determined formula to calculate the salary of any rank, all we can aspire is to enable each of the Government servant to live honorably, honestly and with his head held high, especially in the comparison to the salaries drawn by private sector executives of India, and officers of the developed countries like the USA holding corresponding rank. A 4 to 5 times increase in basic pay scales appear to be reasonable.

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Submission by IPS (Central) Association

4.2

What should be the reasonable ratio between the minimum and the maximum of a pay scale?

Ans: None. 4.3 Is it necessary to persist with a pre-determined minimum-maximum ratio on ideological considerations? Or is it more important to ensure efficient administration by preventing flight of outstanding talent from Government?

Ans: Flight of talents for Government is unlikely to take place to an alarming extent in the near future. What is more worrying is the inability to attract talents at the initial stages. 5. Relativities 5.1 Employees in the Secretariat and analogous establishments are entitled to higher pay scales than the corresponding field functionaries. This was supposed to compensate them for the loss of certain facilities available to them in field assignments and the extra effort required for decision-making at the policy level. Are these factors valid even today particularly in the context of decentralization and devolution of administrative powers? Is this discrimination between field and secretariat functionaries even justified today?

Ans: Relation between secretarial employees and those at field is not feasible at certain cases. To quote an example Many Police and para military Police force personnel are constrained on areas away from civilization, without basic amenities, works for about 20 hours a day, on all days in a week through out the year without any respite or recuperation through out their service. There is no rest or relief to them. Before deployment, Police personnel have to undergo arduous training for about one year followed by induction and in-service training. The training includes highly skilled discipline such as tactics, jungle warfare, thermo nuclear warfare, ecology and environmental aspects, use of most sophisticated gadgets, etc. His job also warrants use of hazardous weapons and high explosives and involves high level risk factors which needs due recognition. A Lower Division Clerk (LDC) in the secretarial level is hired/ appointed without any specialized training. A LDC works under the roof with all comforts while a Constable performs his duty in open facing all odds and lives in constant fear psychosis. Coincidently, Constable and Lower Division Clerk are placed in the same scale Rs. 3050-4590. Basic training being imparted to Police Constable is more value based than an ITI trade certificate but unfortunately it is ignored while determining his pay scale. In-service training being imparted to Police personnel is equally arduous to keep him abreast with the changing scenario. Therefore, job of a Constable be considered above the grade of LDC and his pay be placed to those applicable to ITI trade certificate holder.

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Submission by IPS (Central) Association

6. Group-A Services 6.1 Is there a case for a Unified Civil Service, merging therein all Central (both technical and non-technical) and All India Services, allowing vertical and horizontal movement ? Or should there be two distinct streams, one embracing all the technical services and the other for non-technical services?

Ans: The case for a United Civil Service at the entry and junior levels is feasible. Beyond certain ranks, vertical and horizontal movement may be thought of. 6.2 Do you feel that the pattern of pay scales for all Group A Services should be redesignated so as to attract candidates of the requisite caliber? Keeping in view some of the compensation packages being offered to fresh professionals by the private sector, what emoluments would you suggest for an entrant to a Group-A Service in Government?

Ans: It is essential to redesign pay pattern to attract candidates of requisite caliber in all services. The present system does not attract a talented lot. Resultantly, talented persons have started seek employment either abroad or in private sector within the country. This trend which was a tickle a few years back has become a significant stream now because of glaring disparity in wage structure between government and private sector. In other words, the Govt. has not been able to attract and utilize the top talent of human resource available within our country. New pay structure needs to target in such a manner so as to attract talented persons and pay should be so determined with a substantial increase at the rate of 20 percent each year. A total compensation package taking into account the cost to the Government may be worked out. An average Group A officer should get at least the mean salary offered to fresh graduates from Business schools after deducting the notional value of other perquisites like house, etc. 7. Professional personnel 7.1 Should there be a higher compensation package for scientists in certain specialized streams/departments like Department of Space, Department of Atomic Energy? If so, what should be the reasonable package in their case?

Ans: Yes. A separate package at par with the best in the private research labs should be given to them.

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Submission by IPS (Central) Association

8. Classification of posts 8.1 Presently, civilian posts in the Central Government are classified into four Groups (A, B, C & D) with reference to their scales of pay. The Fifth Central Pay Commission had recommended their reclassification into Executive, Supervisory, Supporting and Auxiliary Staff. Would you suggest any changes in the existing classification or should the classification recommended by Fifth Central Pay Commission be adopted with/without modifications?

Ans: It is suggested that existing classification should be continued. Instead of pay scales it be linked with decision making, responsibility level, accountability, span of control and hazards/risk involved. It has been noticed that in Group B establishment, certain posts in the pay scale Rs.6500-10500 enjoy gazetted status while in others they do not. All posts bearing pay scale Rs.6500-10500 should be treated at par. 9. Restructuring of Group C & D posts 9.1 Should all lower Group C functionaries in the Secretariat be replaced by multifunctional Executive Assistants, who would be graduates and well versed in office work, secretarial skills and use of modern office equipment including computers? Should similar arrangements can be evolved for Group C posts in other organisations of Government?

Ans: This is a good suggestion 9.2 Should a similar regrouping of Group D staff into fewer categories capable of performing diverse functions also be carried out?

Ans: This too may be considered. 10. Pay Scales 10.1 How should a pay scale be structured? What is a reasonable ratio between the minimum and maximum of a pay scale? The successive Pay Commissions have progressively reduced the number of distinct pay scales. The number of scales has therefore come down from more than 500 scales at the time of the Second Central Pay Commission to 51 scales before Fifth Central Pay Commission, which was brought down to 33 scales by the Fifth Central Pay Commission. The reduction in the number of pay scales brings in attendant problems like the promotion and the feeder grades coming to lie in the same pay scale, etc. Do you feel whether the existing number of pay scales should be retained or increased or decreased or whether the same should be replaced by a running pay scale?

10.2

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Submission by IPS (Central) Association

Ans: Pay scales must be reduced. Properly designed pay scales will help to remove stagnation, increase efficiency and harmonize functioning of the system. Pay scale with minor variations in minimum and maximum of the scale or in the rate of increment can be clubbed together. Also pay scales with lesser number of employees be merged with main stream pay scales. Fewer pay scales would make accounting and inter se seniority easier. A few scales may be merged with time bound jumps to avoid stagnation. 11. Increments 11.1 What should be the criteria for determining the rates and frequency of increments in respect of different scales of pay? Should these bear a uniform or varying relationship with the minima and/or maxima of the scales?

Ans: Increments should bear a uniform relationship with minimum/mid point of the scale and should be approximately 10 percent to 15 percent of the minimum/mid point of the scale. 12. Revision of pay scales 12.1 Is there any need to revise the pay scales periodically especially when 100% neutralization for inflation is available in form of dearness allowance?

Ans: This would be ideal. In the current context, the pay scales were last revised on 1.1.96. Since then, on account of neutralization of inflation, the Dearness Pay has been fixed at 50% and the DA at 29%. It would be appropriate that as soon as DP+DA reach 100%, the pay scales should be revised automatically thereby making DA start from zero once again. There should be no requirement for the setting up of a Pay Commission only on account of this. Another issue is the revision of allowances. A fixed amount granted today might look ridiculous after 5 or 7 years. These should also be linked to the basic pay. 12.2 How should pay be fixed in the revised pay scales? Should there be a point-to-point fixation? If not, please suggest a method by which it can be ensured that senior personnel are not placed at a disadvantage vis--vis their juniors and due weightage is given for the longer service rendered by the former.

13. Compensatory Allowances 13.1 Is City Compensatory Allowance a sufficient compensation for the problems of a large city? If DA and HRA provide full neutralization, do you think CCA should continue? Is there a need for changing the basis of classification of cities and the rates of CCA? If so, please suggest the revised basis and rates.

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Submission by IPS (Central) Association

Ans: City Compensatory Allowances are not adequate to offset the increased cost of living. The CCA being given today was fixed as on i.i.96. Even today, the amount being given is a mere Rs. 300 which in no way compensates for the bigger cities one shifts to while coming on deputation from a smaller city. Even though DA provides full neutralization, HRA is a fixed amount of basic pay and does not provide for neutralization of a higher standard of living/ costs. It has also been seen that since 1996, the Indian economy has been developing at a very fast pace leading to increased prices of goods and services all round. Besides, on account of progressive policies, some of the States have developed faster than the others as a result of which some cities have become more expensive than others. It is, therefore, imperative that the basis of classification of cities be also changed to a new index. Further, as stated above, allowances such as these need to be linked to pay and DA. 14. Pay and perquisites for Armed Forces 14.1 What should be the basis for determination of pay scales for Armed Forces Personnel? What percentage weightage should be assigned to (i) parity with civil services, (ii) comparison with private sector, (iii) special and hazardous nature of duties, (iv) short career span and (v) restricted rights?

Ans: There is no justification for higher pay scales and benefits to the Armed Forces personnel from the members of the Para Military Forces. Most of the service conditions in the Central Police Organizations are worse than those of the Defence personnel. In fact, the total casualties on duty in the CPFs far outnumber those in the Defence Services. 14.2 How should the pay of a soldier, sailor and airman be determined? How should it relate to the minimum wage in Government and the pay of a constable in paramilitary or internal security forces?

Ans: The pay of a constable should be on par with that of the pay scale of a soldier, sailor or an airman. This is because both of them are performing duties for the safety and security of the country, which is of utmost importance to ensure peace and stability in the nation. It is only when such exists that a country can develop and grow faster. The constable as also a soldier, sailor and an airman are highly skilled personnel whose wages should be well above the minimum wages prescribed by the Government. He carries weapons and has a responsibility to ensure law and order, safety and security in his place of posting. He goes through a rigorous process of training and thereby acquires a specialized skill set. We must also remember that the defence personnel are entitled to free rations which a police constable is not and so his pay must be on par with that of defence personnel.

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Submission by IPS (Central) Association

To conclude, there is no justification for higher pay scales or benefits to the soldier, airmen or seamen. 15. Abolition of feudalism 15.1 Should all vestiges of feudalism in the country like huge residential bungalows sprawling over several acres, large number of servants quarters, retinues of personal staff, bungalow peons, use of uniformed personnel as batmen or on unnecessary security or ceremonial duties etc. be abolished? Please make concrete suggestions.

Ans: In the uniformed services, an element of feudalism and pomp, and glory have to be retained. These apparently incongruous benefits appear to the public as unnecessary. However, the aura of greatness thus thrust upon officers serve a purpose in the uniformed services. An element of hero-worship is built into regimentation and these help maintain this aura. 16. Specific proposals 16.1 In what manner can Central Government organizations functioning be improved to make them more professional, citizen-friendly and delivery oriented?

Ans: This can be achieved by reorienting the attitudes of the employees through retraining, constant guidance by seniors and laying down a strict code of conduct. Each employee has to have ownership of the new 16.2 Please outline specific proposals, which could result in: (i) (ii) (iii) (iv) (v) (vi) (vii) Reduction and redeployment of staff, Reduction of paper work, Better work environment, Economy in expenditure, Professionalisation of services, Reduction in litigation on service matters, Better delivery of service by government agencies to their users.

Ans: Large scale computerization and resorting to E-governance technology would not only reduce paper work, but also improve transparency, efficiency and reduction in manpower. However, the officer level has to be first initiated into encouraging supporting and motivating the transformation from paper to digital working. Professionalsim can be improved only if performance and efficiency become the sole criterion for promotion and retention in service. This is a hard decision and Government might not have the political will to take such a drastic step.

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Submission by IPS (Central) Association

For better service delivery to customers, a paradigm shift in the attitude of the Government servants at all levels is called for. Today, the Government servants consider themselves the masters of the public and all services are delivered as if they were rare favours. Reeducation and orientation is a tame taking and difficult process calling for 1) Political Will, 2) Commitment at the top levels, 3) Critical mass of devoted enthusiasts at middle levels and 4) Ownership of the programme at cutting edge. 17. New concepts 17.1 Do you think the concepts of contractual appointment, part-time work, flexible job description, flexi time etc. need to be introduced in Government to change the environment, provide more jobs and impart flexibility to the working conditions of employees?

Ans: These concepts need to be introduced in the government given the changing work environment. Indias burgeoning young population would need to be provided job opportunities. In a complex economic set up multi-skill work force would require multi-tasking with people adept at doing more than one job which obviously would require contractual, past time, flexible and flexi time concepts. But services involving enforcement work especially police would have to be precluded from these concepts as by their intrinsic nature the job involves long hours of continuous and dedicated work necessitating trained personnel with high level of commitment, dedication and ability to perform arduous tasks. 17.2 For improving punctuality/introducing new concepts like flexi time, should biometric entry/exit be introduced?

Ans: Yes biometric entry/exit should be introduced for improving punctuality. But proper and specific job description would also have to be introduced so that in the given time period in the office the employees potential is optimally utilized. Just mere presence in the office with under utilized work force would be a total waste of government resources. 17.3 What steps should be taken to ensure that scientists, doctors, engineers and other professionals with sophisticated education and skills are retained in their specialized fields in Government? Should they be appointed on contract with a higher status and initial pay, advance increments, better service conditions, etc.?

Ans: While these steps might help to an extent, it is to be noted that in case of scientists, money alone may not be the consideration. Scientists and specialists are not given their share of respect and status in India where by and large bureaucrats enjoy, often undeserved, respect, status and positions. Recognition of their worth, status and autonomy might be greater incentives than mere pay scales.

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Submission by IPS (Central) Association

17.4

Should there be lateral movement from Government to non-Government jobs and vice versa? If so, in which sphere(s) and to what extent?

Ans: Lateral movement from government to non-government jobs and vice-versa should be allowed to infuse new ideas and energy in the government sector. But sufficient safeguards need to be built into any such system so that the government benefits more from the arrangement rather than the individual government employee and vested interests do not develop in Government officers. 17.5 It has been suggested that existing Government employees should be encouraged to shift to employment on contract for specified periods in return for a substantially higher remuneration package. Would you agree?

Ans: Yes this can be encouraged except in services where continuity and experience on long term is required. Law enforcement services would have to be excluded from this arrangement. 18. Performance Appraisal 18.1 In what way should be present system of performance appraisal be changed? Should be ACR be an open document?

Ans: Performance appraisal has to be transparent and fair. The system of setting mutually agreed upon targets and appropriate resources at the beginning of the financial year through business plans and basing appraisal on the achievement of targets is a tried and tested fair method. Quarterly reviews as practiced in private sector is also good. ACR should be an open document to prevent cowardly officers spoiling the career of inconvenient subordinates. Making the contents know to the officer reported upon will also afford him a chance to improve. Counseling prior to recording adverse remarks should also be made compulsory. In essence it should become a developmental tool rather than a faultfinding process. 18.2 How far has the introduction of self-assessment helped in the process of appraisal?

Ans: It has helped in the process of appraisal only to a very limited extent as it has usually become an exaggerated version of ones performance. It can only become fruitful exercise if both subordinate and superior officer have a clear and shared understanding of tasks and objective to be achieved. An understanding of the potential and capability of the subordinate is very essential in fixing realistic targets alongwith with continuous and sustained efforts by the superior and organization to develop the employee to realize his optimum potential.

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Submission by IPS (Central) Association

18.3

Should appraisal be done for an entire team instead of for individuals?

Ans: Normally it should be done for individuals but if the individuals performance and output is largely dependent on the performance of other members of the team appraisal should also be done for the team as a whole. In any case his individual performance appraisal should be done. If it is required to be done then weightage can be assigned to both the ACRs. 18.4 In what manner can Government employees be made personally accountable for their acts of omission or commission, without any special safeguards? Would you recommend any amendments to Article 311 of the Constitution, Section 197 of the Code of Criminal Procedure, Section 17 and 19 of the Prevention of Corruption Act, 1988 and various rules relating to conduct of Government servants and disciplinary proceedings?

Ans: Any act done in bonafide discharge of government duty should be eligible for safeguard as given in present laws. However to decide on what constitutes a bonafide act an independent statutory body or an ombudsman should be appointed. However, equally, Government servants who fail to deliver results or who deliver unsatisfactory service should be made liable for action departmentally, under criminal and civil law, especially under Torts. For example an engineer who built a bridge which collapses before its life is even half way through should be punished departmentally and also allowed to be sued by the public for damages. 19. Holidays 19.1 Kindly comment on the appropriateness of adopting a five-day week in Government offices when other sectors follow a six day week. Please also state whether the number of Gazetted holidays in Government offices should be reduced? Please also comment on the appropriateness of declaring Gazetted holidays for all major religious festivals.

Ans: Five day week is good. Making a Government servant work for six days is not going to result in more work being completed, but only the same job being stretched to fill the time available: Parkinsons Law in practice. A Government servant be allowed to chose six out of a number of restricted holidays to be drawn up. This is in addition to holidays under the Negotiable Instrument Act like Republic Day and Independence Day.

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Submission by IPS (Central) Association

19.2

What do you think is the state of work ethics and punctuality in Government offices? Kindly suggest ways of improving these.

Ans: The state of work ethics and punctuality in government offices leaves lot to be desired. Some suggestions to improve these are as follows: (i) (ii) (iii) (iv) (v) Improving office dcor, furniture, cleanliness, proper light, ventilation and temperature control. Proper work distribution through clear job description and work rationalization. Intensive work studies to be carried out so that employees are neither overloaded nor underworked. Induction and refresher training emphasizing proper work ethics and punctuality. Reward and recognition to employees showing improvement.

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Submission by IPS (Central) Association

VI.

SUMMARY OF SUBMISSION

In view of the difficulties faced by the police officers, as detailed in the preceding two sections of this Submission, we summarise below our requests before the Sixth Central Pay Commission: A. Changes to structure of career progression and parity across AIS (i) Integrated scale of pay and perquisites need to be evolved for all the AIS, as different from other Central Services / ancillary forces. The salary grades for various ranks could be evolved on time bound running pay scale pattern (open scale from rank of SP to DG of Police) under well defined categories to mitigate dissatisfaction arising at the higher echelons of administrative pyramid due to larger batches ahead. AIS have their inter-se seniority in a batch. They are allotted to different cadre as a working arrangement. Hence statewide differentiation on any parameter for any rank should be done away with. Similarly, service standards in a batch should be applied nationwide so as to remove the anomalies of rank or pay differentiation across the states in the same batch. If not rank, at least pay protection could be given. In view of the intrinsic job pressures, the differentiation of pay scales at the level of Directors General of Police, organization or State wise, ought to be removed and all be equalized at highest scale of pay fixed for Director General. Similar recommendation has also been made by Group of Ministries in Kargil Report. For empanelment of posts in the Central Government, officers of equivalent seniority (in terms of year of allotment), from all AIS should be considered together. Equitable distribution of top managerial posts in Government offices as well as PSUs to all AIS and Central Services could be ensured. There should be a provision for AIS officers to be eligible to go on employment in any place of their choice, including in private sector and NGOs after taking due permission and leave. Congruent number of posts in all the AIS be created in the pay scale of Rs.30,000 fixed. Disciplinary action against AIS officers, including suspension, to be brought under the realm of Government of India in order to save them from the pressure tactics of the State Governments. The anomalous rank of DIG exists in the Police force which puts IPS officers at a disadvantage for promotion vis--vis other Civil Services where no such rank exists. Accordingly, the need for continuing this rank needs to be reviewed.

(ii)

(iii)

(iv)

(v)

(vi)

(vii)

(viii)

(ix)

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Submission by IPS (Central) Association

B. Changes to Basic Salary (x) The Fifth Pay Commission had increased basic salaries by 3.1 to 3.2 times on an average as compared to the then prevailing salary levels. Keeping in mind this precedent and in light of the submissions made in this document, we seek an increase of 4 times in the current pay scales. Currently, at the time of promotion, the basic pay changes only to the extent of one increment as per applicable scale. At the time of promotion from one rank to the other, there should be a reasonable increase in pay in order to recognize seniority, reflect the increase in responsibility and to suitably reward officers for achieving another milestone in their career. It is suggested that this differential should be at least 10%.

(xi)

C. Changes to Allowances (xii) General: In line with the true spirit of the Dearness Allowance which is amended from time to time to reflect the inflationary situation, all other allowances should be linked to, and made variable with, the [Basic+DA] as against being fixed amounts which is currently the case. Equal opportunity: Allowance and perquisites such as LTC and home loans should be available to men and women alike and not restricted to one in case both husband and wife are in the AIS. Hardship Allowance: 50% of basic pay as hardship pay or Cadre compensation allowance could be considered for disturbed or difficult areas for all ranks. In all other cases, ie., other than those posted to notified disturbed areas, an allowance of 30% of basic salary should be considered. Encashment of Leave: The current cap of 300 days for carry forward of unutilized earned leave should be removed; one should be permitted to encash the entire balance of unutilized earned leave at the time of retirement. Further, in order to provide for special circumstances, such as childrens education, marriage or illness, encashment of earned leave should be permitted at up to three points in time over the career span. Leave Travel Concession: There is a need to build in flexibility in the way LTC can be utilized. First, in case it is not possible for an officer to avail of the LTC as stipulated, there should be a provision for partial encashment as is available to employees of Central PSUs (they can avail 65% of the amount that they would have otherwise claimed had they visited their home town). Second, officers should have the option to claim LTC for overseas visits as well subject to a monetary ceiling of the maximum amount that could have otherwise been claimed on domestic travel, as per current rules.

(xiii)

(xiv)

(xv)

(xvi)

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Submission by IPS (Central) Association

(xvii) Deputation Allowance: There should be an enhancement in the deputation allowance from the current cap of 3% of basic pay to at least 15% of basic pay for all ranks to enable the officer on deputation to maintain a reasonable standard of living. In addition, protection of pay scale, without any limitations or restrictions, should be granted while on deputation in view of overall scheme of AIS. (xviii) Training Allowance: In line with the recommendations of the Gore Committee, officers posted to training institutes of the police should be given a special allowance of 30% of basic pay to recognize the contribution they are making for the development of the police force, away from their main line of duty. In addition, such trainers may also be entitled to other facilities as recommended by the Gore Committee. Similarly, officers who are identified as high performers during the course of specified/ notified training programmes should be suitably rewarded for investing their time in training and demonstrating the value they have added to themselves through the training. (xix) Daily Allowance: The allowance payable while away from headquarters on official tour should be increased to one days [basic pay+DA] for each day of tour, as against the current fixed amount. Uniform and Kit Allowance: (a) The initial uniform grant at the point of joining should be set at two months [basic pay+DA] (b) The continuing kit allowance should be enhanced to one months basic pay, payable once every two years. Gallantry Award: Officers whose meritorious service is recognized through police awards also deserve a monetary benefit, depending upon the nature of recognition. The monetary amount could be Rs. 30,000, Rs. 60,000 and Rs 90,000 for Indian Police Medal, Presidents Police Medal and Gallantry Award respectively.

(xx)

(xxi)

D. Changes to Perquisites (xxii) Housing Loan: Provisions for AIS Officers be made liberal as they are liable to be posted anywhere across the Country. Hence, they could be granted two housing loans within the span of entire career. Further, the current cap on housing loans should be removed to reflect the changing real estate situation across the country. The limit for housing loan should be revised to 100 times monthly basic pay. Also, the interest rate applicable should be a concessional floating rate linked to the RBIs bank rate in force from time to time as this rate represents the borrowing rate of the Government. A concession of 2% to the RBI bank rate may be considered. (xxiii) Car Loan: The limit for car loan should be enhanced suitably keeping in mind the increased options in the market place and the nature of vehicle that a senior IPS officer is likely to want to purchase.

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Submission by IPS (Central) Association

E. Pension (xxiv) Basis of pension: Pension should be calculated on the basis of last pay drawn and not on the average pay of the preceding 10 months. (xxv) Settlement of spouse in the event of death of a serving officer in operations: At present there is no provision of giving employment or any special package to the aggrieved family of such unfortunate person. Therefore, it is recommended that there should be a provision for employment in a gazetted rank if within eligibility criteria. In addition, education of children and lumpsum grant at the time of daughters marriage should also be incorporated. F. Interim Relief In order to provide for the time lag between the making of final recommendations by the Pay Commission and the final notification by the Government, we request that as a measure of interim relief, an increase of 20% of current basic pay be provided for with immediate effect.

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