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TIB also submitted 19 recommendations to the government, seeking substantial revisions to the draft law and urging meaningful public participation in finalising the legislation.

One of TIB’s key concerns relates to Section 3(2). While the 2025 ordinance stated that the commission would be an independent institution and would not fall under any ministry or division, the new draft omits the latter provision. According to TIB, this could enable executive control over NHRC and hinder its ability to operate independently.

The anti-corruption watchdog also criticised the composition of the selection committee under Section 7, which includes the Speaker, two ministers, a ruling party lawmaker and the cabinet secretary. TIB warned that the structure could lead to executive dominance and political influence in appointing commissioners.

TIB called for amendments to Section 13 to explicitly empower the commission to regularly inspect and investigate detention facilities operated by law enforcement agencies, intelligence bodies, and armed forces.

It also recommended granting the commission authority to propose improvements to detention conditions, recommend closure of unlawful detention facilities and seek action against those responsible.

Regarding accountability for public officials accused of human rights violations, TIB proposed changes to Section 16 so that arrests of public servants or members of disciplined forces and intelligence agencies would require approval from a court, tribunal or, where applicable, the commission itself, instead of prior government authorisation.

The organisation also recommended repealing Section 20, arguing that it retains restrictions from the 2009 law that prevent the NHRC from independently investigating allegations against members of disciplined forces.

According to TIB, this limitation has been a major reason the NHRC has never achieved “A Status” from the Global Alliance of National Human Rights Institutions.

Warning that a weak and dependent human rights commission could have serious consequences for citizens and democratic institutions, TIB called on the government to revise the draft law through an inclusive process that takes into account the views and recommendations of all stakeholders.