Vigilance Manual (Updated 2021) — Handling of Complaints in Vigilance Administration

1. Where a Vigilance Complaint May Legitimately Come From

Before any complaint can be acted upon, it helps to know what actually counts as one. Para 3.1.1 of the Vigilance Manual (Updated 2021) lists the channels through which information about corruption, malpractice or misconduct may legitimately reach an administrative authority, the Commission, the CBI, or the police:

• Complaints from employees or members of the public;
• Departmental inspection reports and periodic stock-verification surveys;
• Scrutiny of Annual Property Statements filed under the Conduct Rules;
• Scrutiny of transactions and permissions reported under the Conduct Rules (for example, a Government servant's intimation of a property purchase, or a request for permission to accept a gift);
• Irregularities detected in routine internal audit;
• Reports of the Comptroller and Auditor General and other statutory audit bodies;
• Reports of Parliamentary Committees — the Estimates Committee, the Public Accounts Committee, and the Committee on Public Undertakings;
• Proceedings of the Houses of Parliament;
• Press reports and published allegations;
• Verbal source information from an identifiable source, which must always be reduced to writing before it can be processed; and
• Intelligence gathered by agencies such as the CBI, State Anti-Corruption Bureaus, or Lokayuktas.

A worked example helps here. Suppose a Section Officer in a Ministry's Vigilance Section reads a newspaper report alleging that a particular Deputy Director sanctioned a contract to a firm owned by a relative. Under Para 3.1.1, this press report is itself a legitimate trigger for vigilance action — the Manual does not require the Ministry to wait for a formal written complaint before looking into a credible, specific press allegation. The CVO is, in fact, expected to continuously scan relevant news items concerning the organisation, precisely so that such matters do not go unnoticed merely because no one individually complained.

2. Complaints From Subordinates, and the Two-Sided Consequence

Para 3.1.3 addresses a question that comes up constantly in practice: can a junior officer complain directly about a superior's corruption, bypassing the normal chain of communication? The Manual's answer is unambiguous — while a public servant is generally expected to route communications through the proper official channel, there is no bar on entertaining a direct complaint or communication about corruption from a subordinate or another public servant. A genuine complainant of this kind is entitled to protection against harassment or victimisation for having spoken up.

But the Manual is equally firm in the other direction. If, after verification, a complaint turns out to be false and malicious — for instance, a disgruntled subordinate fabricating an allegation against a superior after an adverse ACR entry — there should be no hesitation in taking severe departmental action or launching criminal prosecution against that complainant. This dual protection is deliberate: it is designed to encourage genuine disclosure while deterring the complaint mechanism from being weaponised as a tool of personal vendetta. A CVO who receives a complaint should keep both possibilities in mind simultaneously, not just the possibility that the complaint is true.

3. Action on Audit Reports, C&AG Paras and Statutory Financial Reviews

Internal audit, statutory audit, and reports of the Comptroller and Auditor General are treated as a particularly important source of preventive vigilance, because they provide an independent, periodic, and technically competent check on internal controls that an organisation's own vigilance staff may not otherwise catch. Per CVC Circular No. 3(V)/99/14 dated 16.05.2001, CVOs are required to specifically scrutinise all such reports to identify vigilance issues, and immediate action must be initiated wherever misconduct or corruption is revealed. Serious C&AG-flagged irregularities perceived to carry a vigilance angle are also forwarded to the Commission for examination and follow-up, ensuring that a finding buried in a lengthy audit report does not simply disappear into the file without disciplinary consequence.

4. The Commission's Own Complaint Handling Policy and the 2021 Regulations

Complaints addressed directly to the Commission (as opposed to those handled within a Ministry or PSU) follow a distinct policy, most recently consolidated in CVC Circular No. 98/DSP/9 dated 15.12.2014, as modified by CVC Circular No. 004/VGL/020 (pt.) dated 01.07.2019, and now formally codified in the CVC (Procedure for Dealing with Complaints and Procedure of Inquiry) Regulations, 2021 — a full list of the Commission's current Acts, Rules and Regulations is maintained on the CVC Acts & Circulars page. The key operating principles are worth listing precisely, because a complaint that fails even one of them will simply not be taken up:

• The Commission may inquire into a complaint only against an official of a specified category and organisation falling within its jurisdiction, and only where an offence under the Prevention of Corruption Act, 1988 (or a connected offence triable at the same trial) is alleged.
• The Commission does not entertain anonymous or pseudonymous complaints (Regulation 3, inserted via the 2021 Regulations).
• Since the Commission deals only with matters of corruption, mere grievance redressal — a delayed pension, a disputed transfer, an unresolved service matter with no corruption element — should not be the focus of a complaint to the Commission.
• No fee is chargeable for lodging a complaint.
• A complaint should preferably be typed or clearly written, in English or Hindi, to facilitate prompt action.
• The Commission may dismiss a complaint in limine (at the threshold, without detailed examination) if it does not meet the prescribed criteria.
• The Commission does not entertain complaints against private persons, State Government officials, Members of Parliament or State Legislatures, elected representatives of other bodies, or members of the judiciary — these fall outside its jurisdiction entirely.
• Complaints sent to the personal e-mail IDs of Commission officers are not entertained or taken cognizance of; they must go through the prescribed channel.

Once a complaint clears this threshold, the Commission may take one of four actions: get an inquiry or investigation done through the CBI or another agency and call for an Inquiry & Report (I&R); send it to an investigating agency for a Factual Report (FR) or discreet verification; send it to the respective CVO for Necessary Action (NA); or simply file/close the complaint. Before a complaint is sent out for I&R, the Commission first seeks confirmation from the complainant, along with identity proof, that they indeed own the complaint — if there is no response within 15 days, a reminder is issued, and if there is still no response after a further 15 days, the complaint may be filed. This confirmation step is what distinguishes a processed, genuine complaint from one that is quietly closed for lack of ownership.

5. The Rule on Anonymous and Pseudonymous Complaints

This is one of the most frequently misunderstood rules in vigilance work: the Commission does not entertain anonymous or pseudonymous complaints. This is not a loophole that lets wrongdoing go unaddressed — it exists because an unverifiable, unsigned allegation cannot be tested for authenticity, and experience shows such complaints are disproportionately used to settle personal scores or harass honest officers. However, where an anonymous or pseudonymous complaint contains specific and verifiable factual allegations, an organisation may independently decide to look into the substance of those facts on its own initiative, and may, if it wishes, refer the matter to the Commission — but this happens as an exercise of the organisation's own administrative judgment, not because the anonymous complaint itself commands action.

A practical illustration: an anonymous letter alleging that a particular officer has constructed a house far beyond their known income, with a specific address and approximate value mentioned, contains verifiable facts — the property records, the officer's declared assets, and the construction cost can all be independently checked. An anonymous letter that simply says “X is corrupt and takes bribes” with nothing more is not independently verifiable and would ordinarily be filed without action.

6. Category ‘A’ and Category ‘B’ — The Register Every Vigilance Section Must Maintain

Every Vigilance Section or Unit within a Ministry, Department, or PSU is required to maintain a Vigilance Complaints Register in Form CVO-1, kept in two separate parts: Category ‘A’, for employees against whom the Commission's advice is required before final action, and Category ‘B’, for employees against whom the Commission's advice is not required (broadly, more junior officers whose cases can be finalised at the organisation's own level). If a single complaint names both a Category A and a Category B employee, the whole complaint is entered against the higher category — that is, treated as Category A — so that it does not slip through at a lower level of scrutiny than the seniority of the officers involved actually warrants.

Two further registration rules matter in practice. First, only complaints containing an allegation of corruption or improper motive, or where the alleged facts prima facie indicate an element or potential vigilance angle, are entered in the register at all. Complaints about purely administrative matters or technical lapses — late attendance, insubordination, disobedience, lack of supervision, or ordinary operational irregularities — are not entered in the vigilance register; they are dealt with separately as “non-vigilance complaints,” through the ordinary administrative or HR process, not the vigilance machinery. Confusing the two is a common and costly error: routing a routine attendance-discipline matter through the vigilance channel needlessly stigmatises an officer, while routing a genuine corruption allegation as a mere administrative matter lets it escape proper scrutiny.

Second, where a complaint against an employee of a Public Sector Enterprise or Autonomous Organisation is received both by the administrative Ministry and by the organisation itself, it is normally sent for inquiry to the organisation employing that person and entered only in that organisation's register — not duplicated in the Ministry's own register — except where the Ministry has a specific reason to handle the matter itself without routing it through the employing organisation. This avoids double-counting the same complaint in statistical returns and prevents two separate, uncoordinated inquiries running in parallel on the same allegation.

7. Complaints Against Secretaries, Chairmen, CMDs and Functional Directors — A Different Routing Altogether

This is the specific gap most self-taught vigilance officers get wrong, because it doesn't behave like an ordinary complaint at all. Para 3.4.4 of the Manual lays down a wholly separate routing mechanism for complaints against the most senior functionaries:

• Complaints against Secretaries to the Government of India, when received by an authority other than the Commission, are referred to the Cabinet Secretariat, for placing before a Group of Secretaries headed by the Cabinet Secretary. Where such complaints are received directly by the Commission, they are generally forwarded to the Cabinet Secretary — and, crucially, they should not be sent to the CVO of the Administrative Ministry in which the Secretary concerned is working or had worked in the past, since that CVO reports, in practice, into a chain the Secretary sits at the top of.
• Complaints against the Chief Executives and Functional Directors of Public Sector Undertakings, and against the CMDs and Functional Directors of Public Sector Banks and Financial Institutions, when received by an authority other than the Commission, are placed before a Group of Officers headed by Secretary (Coordination) in the Cabinet Secretariat. The detailed procedure for this route is laid down in DoPT O.M. No. 104/100/2009-AVD.I dated 14.01.2010 (as amended by a corrigendum of the same number dated 08.03.2010) and in DPE O.M. No. 15(1)/2010/DPE(GM) dated 11.03.2010 (as amended by OMs of the same number dated 12.04.2010 and 11.05.2011). Current DoPT circulars and Office Memoranda of this kind can be tracked on the DoPT Circulars page.
• By contrast, complaints against Chairman/CMDs/MDs/CEOs/Functional Directors of CPSEs and PSBs received directly by the Commission itself follow a different path again: they are forwarded to the CVO of the Administrative Ministry concerned for inquiry, and the resulting report is submitted back to the Commission by that Ministry — such complaints are specifically not sent to the Group of Secretaries or Group of Officers route (per CVC Circular No. 010/VGL/008 dated 14.03.2011, clarifying and consolidating the position taken in an earlier circular of 27.07.2010).

The logic threading through all three sub-rules is the same: who received the complaint determines the route, because the ordinary chain of command cannot be relied upon to investigate its own apex without an external check. A complaint against a Secretary that lands with their own Ministry's CVO would, if processed normally, ask a subordinate to sit in judgment on their own administrative head — which is precisely what this routing is designed to avoid. A CVO who receives such a complaint about their own Secretary or Chairman should not attempt to process it departmentally at all; it should be forwarded upward to the Cabinet Secretariat channel described above.

Separately, since the Lokpal and Lokayuktas Act, 2013 became operative, a specific category — Lokpal Complaints (Para 3.4A) — has been added to the Manual: complaints received from the Lokpal are to be dealt with strictly in accordance with the provisions of that Act, rather than through the general complaint-handling machinery described above.

8. Initial Action, Scrutiny and Disposal of a Complaint at the Ministry/Department Level

For the large majority of complaints — those handled at the Ministry, Department or organisation's own level rather than referred to the Commission — Para 3.5 sets out the operative sequence. Once a complaint is registered in Form CVO-1, the Chief Vigilance Officer examines it to see whether there is substance in the allegation worth looking into. Where the allegations are vague, general, and prima facie unverifiable, the CVO may, with the Head of Department's approval where necessary, decide that no action is warranted and the complaint should be dropped and filed. Where the complaint gives information definite enough to require further checking, a preliminary inquiry or investigation is undertaken to verify the allegations, so that a decision can be made on whether the officer concerned should be proceeded against departmentally, prosecuted in a court of law, or both — a subject we cover in full in our companion article on Preliminary Enquiry.

Disposal of a registered complaint takes one of four forms, mirroring the Commission's own framework: file it (with or without investigation); forward it to the CBI for investigation or appropriate action; forward it to the concerned administrative authority for action on the ground that no vigilance angle is involved; or take it up for detailed investigation by the departmental vigilance wing. Information passed by the CBI to a Ministry or Department about the conduct of one of its own officers is treated in exactly the same way as any other complaint reaching that threshold.

9. Update — Revised DoPT Complaint-Handling Guidelines (2024) and the Lokpal Interface (2025)

Complaint-handling procedure has been refined further since the 2021 Manual went to print. DoPT O.M. dated 9 October 2024 issued Revised Guidelines on handling complaints in Ministries, Departments and Organisations of the Government of India, building on the Commission's own Comprehensive Guidelines on Complaint Handling Mechanism dated 24 December 2021 (Circular No. 25/12/21) and its subsequent amendment dated 3 November 2022. Separately, the CVC Circular dated 18 February 2025 lays down the specific procedure for handling complaints referred by the Lokpal to CVOs — distinct from, though related to, the general Para 3.4A route described above — reflecting the growing interface between the CVC/CVO machinery and the Lokpal in recent years. A CVO handling a live case today should treat the printed 2021 Manual as the baseline text and check both of these more recent instruments, along with any subsequent circulars listed on the CVC's own Acts & Circulars page, for the current procedural detail before finalising any complaint-handling decision.

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