The right way to reform the public administration
The fourth chapter of the report by the Public Administration Reform Commission (PARC), constituted by the interim government, offers crucial recommendations on reforming the behaviour and mindset of public service holders. The commission underscores that to help achieve the government's policy goals and uphold democratic values at the same time, a set of core professional values must be instilled in civil servants. To this end, it recommends the formulation of a Civil Service Code incorporating these values. The proposed values include: people-centric attitude, accountability, transparency, integrity, leadership and innovation, equity, and professionalism.
It remains unclear whether the interim government is in the process of formulating a Civil Service Code based on these recommendations. However, it recently amended the Public Service Act, 2018 and issued the Public Service (Amendment) Ordinance, 2025, which emphasises ensuring the subordination of government employees. This amendment is not in line with the original vision of PARC, because while the commission emphasised accountability and transparency, the new ordinance defines a vague and undefined concept—"insubordination"—as a punishable offence.
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Under a new provision concerning misconduct and disciplinary measures, the 2025 ordinance stipulates that any act of insubordination, incitement of insubordination among peers, disruption of discipline, or obstruction of official duties by a civil servant will be deemed as misconduct, punishable by demotion, dismissal or termination. Government employees fear that this ordinance will force them to follow unfair orders from their superiors in the office. If they don't, they will risk losing their jobs. They have launched a movement against this ordinance.
There are laws and regulations already in existence that provide sufficient grounds to penalise insubordination, corruption or negligence. The problem here is the slow, improper, and inadequate implementation of these laws and regulations. It is unclear what role the promulgation of a new ordinance, with provisions for punishment for vaguely defined "insubordination," will play in resolving this issue. It is necessary to ensure transparency and accountability among government employees and to make them provide public services promptly, without bribery and corruption. It is not clear why it is necessary to ensure blind obedience in this case. PARC has made many important recommendations to eliminate irregularities, corruption, and negligence among government employees, but I have not seen any recommendation to enact a law to terminate employees from their jobs for insubordination.
According to the Government Employee (Discipline and Appeal) Rules, 2018, misconduct is one of the grounds for which serious punishment can be given to government employees, ranging from temporary suspension to dismissal from service. This rule also clearly explains what is meant by "misconduct": i) disobedience of lawful orders by superiors; ii) negligence of duty; iii) ignoring government orders, circulars or directives without a lawful reason; iv) filing frivolous, baseless or false complaints against other employees; and v) any action defined as misconduct under any other existing laws or rules.
Importantly, the rules only penalise disobedience of lawful orders, not any order. In contrast, the new ordinance criminalises "insubordination" without clarifying what it entails. Insubordination to whom: the government, the state, or one's superior officer?
This opens the door to abuse, where senior officials or political authorities might compel subordinates to act unlawfully under the threat of punishment for insubordination. Conversely, public servants could also use this clause as a shield to justify illegal actions—such as electoral fraud—by claiming they were merely being "loyal." Under the Government Employee (Discipline and Appeal) Rules, 2018, as misconduct is defined as "disobedience of lawful orders by superiors," such justifications would not hold.
There are laws and regulations already in existence that provide sufficient grounds to penalise insubordination, corruption or negligence. The problem here is the slow, improper, and inadequate implementation of these laws and regulations. It is unclear what role the promulgation of a new ordinance, with provisions for punishment for vaguely defined "insubordination," will play in resolving this issue.
Another concerning aspect of the new ordinance is the disciplinary procedure it outlines. Under the existing rules, punishment follows a multi-step process with proper safeguards: (in order) i) framing of charges; ii) show-cause notice; iii) reply; iv) hearing; v) formation of an inquiry committee; vi) inquiry findings; vii) another show-cause notice based on the findings; viii) consultation with the Public Service Commission; and ix) final decision.
The new ordinance trims down this process to (in order): i) framing of charges; ii) show-cause notice; iii) reply; iv) hearing; v) show-cause based on the hearing; and vi) final decision.
There is no provision for an investigation or mandatory consultation with the Public Service Commission. While excluding the latter may help expedite cases, the elimination of investigation into the charges is troubling. It creates a risk of politically motivated or personal vendetta-driven dismissals. Without impartial investigation, a predetermined verdict can easily be enforced, regardless of how strong the defence may be.
Instead of weakening procedural safeguards and punishing ambiguous behaviour like "insubordination," the government should prioritise the Public Administration Reform Commission's actionable recommendations to improve service delivery without bribery or corruption.
Public expectations from the civil service are focused on efficient, impartial, and corruption-free service delivery. While complete transformation may require deep structural change, significant improvement is possible through the PARC-proposed reform recommendations. Key recommendations in this regard include: defining service quality standards; introducing online service tracking systems; simplifying service processes; adopting token-based systems; enforcing service delivery timelines; and evaluating the performance or failure in delivering services.
The commission also recommends establishing an institutional grievance redress system in all ministries and departments, following the formation of the ombudsman's office. Community-based feedback collection systems could help assess public satisfaction and improve responsiveness. Citizens wronged by service failure should be entitled to compensation.
To evaluate government officials' effectiveness, PARC calls for the introduction of Key Performance Indicators (KPIs) and a new Annual Performance Evaluation (APE) system to replace the outdated Annual Confidential Report (ACR). Officials would submit Annual Work Plans (AWPs), and evaluations would be conducted at the year's end through a discussion with superiors. Employees' performance can be evaluated in four categories: unsatisfactory, satisfactory, good, and excellent. Financial benefits, training, and other amenities may be provided to the employees based on their performance.
Bangladesh needs a bureaucracy that serves its citizens with professionalism and integrity, not one driven by blind obedience. Real reform lies not in enforcing subordination, but in ensuring proper service.
To ensure neutrality of public administration, the reform commission also recommends abolishing the practice of seeking political background information for promotions, and limiting police checks to verifying pending criminal charges only during recruitment. It proposes banning civil servants from attending political programmes, restricting appointments of private secretaries from outside the civil service, setting clear boundaries for political intervention in administrative decisions, and prohibiting changes to official decisions without written instructions.
Over the past five decades, Bangladesh has seen 26 commissions and committees for public administration reform (Public Administration Reform Commission Report, January 2025, Pg 2). But they were not fully implemented and sustained for two main reasons. First, the political leadership did not accept all the recommendations, neither were they sincere or determined to implement the recommendations they did accept. Second, the concerned bureaucrats did not cooperate in their implementation due to conflict of interest.
To avoid repeating this cycle, the government must act with conviction and foresight. Hastily issuing flawed and undemocratic ordinances could backfire, inviting criticism and eventual retraction under pressure. Broad consultation with political parties, civil society, and stakeholders is essential to build consensus and ensure the sustainability of meaningful reforms.
Bangladesh needs a bureaucracy that serves its citizens with professionalism and integrity, not one driven by blind obedience. Real reform lies not in enforcing subordination, but in ensuring proper service.
Kallol Mustafa is an engineer and writer who focuses on power, energy, environment, and development economics. He can be reached at [email protected].
Views expressed in this article are the author's own.
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