Saturday, November 17, 2018

Need for CAs to know IPC

ICAI Bhawan, New Delhi


Elections to the Central Council and Regional Councils of the Institute of Chartered Accountants of India would be held on 7th and 8th December 2018. CAs standing for elections are contacting for first preference vote like any other sundry politician. I used the term ‘any other sundry politician’ simply because, once the elections are over, these Members even refuse to look at you when you come across each other at any place or event.

For me ICAI is another UPA. Nepotism and Ghettoism is the hallmark. Disciplinary Council works only by ‘not working’. PM Narendra Modi had also brought this to the notice of the ICAI couple of years ago by highlighting the huge pendency of disciplinary cases. PM also reminded CAs of their duties and scolded them not to advice clients on how to evade taxes by dubious means with huge applause from the CAs themselves. However, I am not going into that aspect here.

The Institute is made from the members themselves. Unless the members are clean and upright in their own professional conduct, we cannot have an Organization that will live up to the expectations of the Public from this profession.

The observations made in an article dated 13/11/2018, by CA Amresh Vashisht  - “The President offices were having the allegations of money misappropriation, council members shaking hands with the Big 4, council members in jail, council members in armed booth capturing, council members disciplinary scams, council expenditure scams, examination scam and so on. All such events resulted in depreciation of the brand value of Chartered Accountants.” – underline one point that unless the individual members stand tall, the Institute would not stand tall.

I am covering only one aspect of the professional/individual conduct of a CA – viz., the way they deal with their articled clerks (CA students).

In last five years, many CA students from Mumbai, Thane, Nashik and Pune had contacted me on how to deal with the harassment meted out to them by their principal CA and seek transfer to a humane CA. The tactics employed by the Principal CA are nothing short of a harassment of criminal nature. I have guided them to deal with the errant CA without aggravating the situation, to the extent possible. But some CAs need thorough cleansing.

This is something more than a mere “professional and other misconduct” by a Chartered Accountant within the meaning of the CA Act and CA Regulations. I want to share one such case from Pune as this case amongst the cases that came to me had crossed all known barometers of civility, propriety and sobriety. The name of the CA student as well as her Principal CA is withheld at her request.

This female was an articled clerk and was pursuing her CA course. She wanted a transfer from her existing principal CA to another CA. The reasons for seeking transfer were as follows:

1.    Regular use of derogatory language and constant name calling such as idiot, dumb, fool, donkey etc.;

2.    Expressing constant displeasure and rude attitude;

3.    Not even allowing to have lunch during lunch time;

4.    Not allowing to do GMCS-I course before completion of one year of articleship thus further leading to postponement of her CA final attempt by six months and further derisively stating in public that “You will not be able to clear the CA final exam”.

5.    Not at all caring about her career & wasting six months of her life which has caused her to lose her self-confidence.

6.    When she requested the Principal CA to give her transfer to another CA firm, the Principal CA started yelling & shouting on top of his voice in a fit of rage & bluntly refused stating “I will not sign your transfer document, do what you want”.

7.    Threatening to ruin her career by using his contacts in the Regional and Central Council of the CA Institute.

The constant abuse and name calling had taken a toll on her health and the poor girl had lost about 6 kgs in 8 months.

She had approached some CAs in the Pune Branch of ICAI for help and guidance. However, to her shock, everyone advised her to adjust to the said CA. They not only discouraged her from complaining to the CA Institute but also cautioned her against filing any complaint on the ground that it would ruin her career.  

When her father finally approached me, I told him it is useless to approach Disciplinary Council or any other Council of the ICAI. My experience with one Central Council member has been discouraging so much so that I feel Council is a ‘coterie’. However, I tried to contact one member of WIRC. The gentleman did not respond to my repeated WhatsApp and SMS messages. Ironically, this CA had called me repeatedly for first preference vote before previous election. Since I do not want to embarrass this member, I am withholding his name. However, his nonresponse made me to refer to the news item 'ICAI disciplinary panel decisionswere forged' that appeared in Times of India on 23rd May, 2014.
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Considering this experience and the sorry state of affairs as per the news item, I advised her to forget the provisions of the CA Act and CA Rules and invoke the provisions of Indian Penal Code and other applicable laws dealing with harassment at work place, intimidation, humiliation, torture, etc. I advised the girl to send her harassing boss for a thorough cleansing under IPC in a Laundromat in Police Station.

The Girl gathered courage and finally lodged the complaint with Women’s Cell, Crime Branch of the Police as per the advice given by me. One phone call from the Women’s Cell and the errant Principal CA signed the transfer form with profound apologies. His threats of ruining the career and taking revenge evaporated in thin air. The harsh reality that his actions as narrated above have exposed him to criminal prosecution attracting a fairly long sentence of imprisonment suddenly dawned on him. The justice was done. This quick and effective justice would not have been possible under the present non-existing mechanism in the Institute.

ICAI has to be more sensitive to the plight of Articled Clerks arising out of inhumane treatment given by their own members and a students’ resultant desire for transfer from their existing Principal. The existing Principal is always reluctant as he stands to lose the cheap labour force. I use the terminology ‘cheap labour force’ mainly because as compared to the salary paid to a normal clerk, the stipend paid under the CA Regulations is always at a substantially lower level. Even though the stipend is not the issue at all, the ICAI has to show sensitive approach towards the issue of harassment meted out to the Articled Clerks when they apply for transfer and/or leave.

It should be noted that ‘articleship agreement’ executed between the Principal CA and the CA Student does not make that student a ‘bonded labourer’ of that Principal CA.

I am told by a sitting Central Council Member that unfortunately, the ICAI has no such mechanism in place at the moment, even though the matter has been under active consideration for quite a long time. The reason why ICAI has no mechanism in place again defies all barometers of logic – to say the least. I am told that according to the Central Council, ‘articleship agreement’ is a private agreement between the CA and the Student and the ICAI cannot do anything in case of dispute between the Principal CA and the Student. Simply bizarre and absurd – to say the least.

Is it a case of the Central Council that the articleship agreement is not an essential and inbuilt ingredient of CA course formulated under the CA Act and CA Regulations?

Is it something that is undertaken voluntarily by the students outside the ambit of CA course by mutual negotiation with the Principal CA?

Is it not a fact that the entire agreement in the prescribed Form 102 is formulated by the Central Council under Regulation 45?

Is it not a fact that the CA and the Student has to sign on the dotted lines by filling only their individual particulars?

Then how does the agreement become private agreement between the CA and the Student? Read Regulation 45 and other relevant regulations carefully. It is high time Central Council Members did a crash refresher course in CA Act and CA Regulations.

Remove this mandatory condition and then see how many students sign such articleship agreements with CA firms to work! Such bizarre argument not only exposes the insensitivity of the Council Members but also their lack of knowledge. Or is it a case that since Central Council members themselves have many article clerks, they are wary of creating such a platform?

It is high time ICAI also introduced one paper on Indian Penal Code in the final course that would sensitize the CAs about how many of their acts of omission and commission committed in the course of their practice would constitute criminal offence under IPC and what are the consequences of such criminal offence.

The ICAI should also set up mechanism where complaints against refusal to give transfer would be dealt with within 2-3 working days without any bias against the concerned student.

Hope ICAI listens.  


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