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Transnational Issues In Investigation

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TRANSNATIONAL ISSUES IN INVESTIGATION

Rahee Chaudhari, Symbiosis Law School, Pune

ABSTRACT

New forms of criminals and new forms of crime are being introduced to the investigating agencies all over the world. As a continuously changing phenomenon, agencies under investigation must constantly upgrade their machinery, infrastructure, data communication and data sharing in an effort to catch the criminals. Economic offences using Cryptonetworks and aided by Artificial intelligence, the criminals are masquerading wicked execution of offences. This paper is a critical reexamination of the normative and institutional frameworks to regulate cross-border investigation as well as legal frameworks, challenges and an endeavor to seek solutions. The entire transnational investigation also encompasses the cross border crimes enquiry and investigation besides encompassing extradition arrangements, mutual legal assistance treaties and cooperation among countries.

It also questions the main legal and practical dilemmas, including simultaneous and overlapping jurisdiction claims, procedures and formalism in inter-state cooperation, the admissibility of evidence, the conflicts between investigational requirements and data protection rules, and the consequences of the State sovereignty and protections to due process in technology-intensive investigations. The paper puts forward a more lean and time limited version of MLAT processes, more transparent regulations regarding the extraterritorial collection of evidence, the further harmonization of the standards of digital evidence and privacy and a closer integration of activities of law enforcement agencies, the courts and the service providers.

Introduction

Transnational criminal investigation takes a rather paradoxical but: The field of transnational criminal investigation stands in an important but disputed position on the border between criminal law and public international law, human rights, and technological disruption. Criminal enterprises have defied the traditional paradigm of territorially-bound State investigations, organized crime syndicates, cyber-crimes, financing terror activities, human trafficking, and international financial fraud-that go across state lines smoothly, by taking advantage of digital infrastructure and global financial networks. Research is thereby turned into not a national practice, but an elaborate transnational affair, which is controlled by treaties, mutual legal assistance frameworks, extradition regimes, and new protocols on electronic evidence-sharing.

The conflict between three imperatives of criminal justice performance, the sovereignty of the State, and the protection of individual rights is the core. The gap is attempted to be bridged by such instruments as the United Nations Convention against Transnational Organized Crime (UNTOC), mutual legal assistance treaties (MLATs), and regional mechanisms, including the European Investigation Order provided by the EU. However, real-life practice shows breaches and failure of completion. This picture is further complicated by the emergence of cloud-based service providers, putting the private corporations in the position of the gatekeepers of the access to investigations in many cases without sufficient control mechanisms (public) and accountability.

These issues cannot be perceived as ordinary technical problems but illustrate underlying structural disparities when viewed from a socio-legal perspective. Strong States exercise extraterritorial jurisdiction and corporate compliance to impose investigative jurisdiction on less-resourced jurisdictions in the global arena, whilst those not yet so resourced are left reliant on reciprocal partnership, which may never be realised. The rights of the suspects are disjointed where they have been caught in the transnational webs. Research Objectives: The researcher will present bold and dynamic solutions to ensure that the autonomy of the investigation agencies is preserved yet at the same time collaborate with the cross border investigation agencies. Thus, the researcher has selected the following research objectives as a guide to this research paper:

To examine the environment of transnational investigation with a focus on the successful convergence points assisting and the divergence points supporting transnational investigation that renders the process tedious. • To determine and examine the issues encountered in the fiscal coordination, resource sharing, bottlenecks and mutual support to law enforcement agencies. • To give policy suggestions to enhance the efficiency and fairness of relations to aid transnational criminal investigation actions. Limitations: • Legal Uncertainty and absence of consistency: the legal and jurisdictional uncertainty that exists among several investigating machineries cannot enable the machinery and the independent agencies to operate in freedom. • Poor access to the information of the machineries employed during cross border investigation that are discussed in this paper.

• Territory is also a restriction to the researcher since the researcher is located in the city of Pune and is pursuing the full time course of LLM 2025-2026 in Symbiosis Law School, Pune. Literature Review The academic environment in transnational criminal research has changed significantly within the last twenty years, as the rate of transnational crime rises and the legal frameworks of individual countries fail to keep abreast with the growth rate. According to Finckenauer1, in his publication on globalised crime, the inherent incompatibility is found between criminal organisations as networked and borderless, and the law enforcement as disintegrated by its jurisdiction. It is this lack of fit that has led to the establishment of what Boister calls the transnational criminal law. He has called it a regime different to international 1 James O.

Finckenauer, Meeting the Challenge of Transnational Crime, 284 NAT'L INST. JUST. J. 3 (July 2000).

criminal law and one not characterised by supranational courts but by cooperative suppression systems within domestic systems. Mutual Legal Assistance: Development, Effectiveness, and Dysfunctions of the Contemporary. The MLAT regime is the basis of the transnational cooperation. Classical literature considers MLATs as neutral facilitative mechanisms but modern literature takes a critical view. Currie analysis2 of cross border evidence gathering shows that although MLATs have transformed into multi-media and digital data transfers instead of the previous documentary requests, they are still burdened with procedural formalism and route-through diplomacy to add average of 10 months or more delays. The article by Woods3, 2017, discussing the topic of the mutual legal assistance in the digital age.

defines what he calls the MLA crisis that is the severe malfunction that will occur when treaty structures that were initially created to work with paper records are subjected to the large demands of digital data, frequently involving millions of records and necessitate substantial computing capabilities to search and delete. There are more systemic bottlenecks that are identified through empirical research within the Indian context4. The report on cross-border data-sharing by the Centre of Internet and Society shows that dual criminality conditions, along with the gaps in the MLAT network (especially with key countries such as the UAE and Singapore) and the centralised decision-making power held by the Ministry of External Affairs significantly hinder the investigative speed and effectiveness.

Such results indicate that MLAT dysfunction is not of a technical nature but is instead more indicative of profound structural decisions regarding sovereignly and institutional capacity. Electronic Evidence, Jurisdictional conflict and lack of rights. The modern literature is becoming more preoccupied with the clash between the demands of digital evidence and transnational legal fragmentation5. The Budapest Convention on 2 Robert J. Currie, Cross-Border Evidence Gathering in Transnational Criminal Investigation: Is the Microsoft Ireland Case the 'Next Frontier'? , 2017 SSRN ELECTRONIC J. (Mar. 15, 2017),

3 Andrew Keane Woods, Mutual Legal Assistance in the Digital Age, 2017 SSRN ELECTRONIC J. (Mar. 24,

2017), 4 Amber Sinha, Elonnai Hickok, Udbhav Tiwari & Arindrajit Basu, Cross Border Data-Sharing and India: A Study in Processes, Content and Capacity, CTR. FOR INTERNET & SOC'Y (2016)

5 Andrew Keane Woods, Mutual Legal Assistance in the Digital Age, in THE CAMBRIDGE HANDBOOK OF

SURVEILLANCE LAW (David Gray & Stephen E. Henderson eds. , 2017) (forthcoming Mar. 22, 2017) Cybercrime (2001) has effectively increased the efficiency of cross border investigation. The deeper conflict shown in the Microsoft Ireland case6 involves US warrants seeking data stored on the servers physically located in Ireland coming into conflict with the Irish data protection law, which led to transnational jurisdictional standoffs resolved by legislative accommodation (the CLOUD Act 20187). The role of private intermediaries also is brought out by scholarship on digital evidence. Providers of services are increasingly playing the role of a gatekeeper of access to investigation, but they do so with little public control or transparency demands8. Gaps of Rights Protection and Structural Asymmetries.

Study Critical scholarship challenges the distributional implications of transnational regimes. The Global North states use extraterritorial jurisdiction and corporate compliance requirements to exercise investigative power of international example of US Securities and Exchange Commission into foreign corporations and US Internal Revenue Service into diaspora income9. Transnational issues of human rights erosion are identified in human rights focused literature. Joint investigation teams, even though they share evidence, have less procedural protection; undercover operations that would be subject to judicial warrant in the national context are conducted with limited restraint in the international context; and people in the countries of cross-border investigation receive cumulative rights losses as procedural safeguards are eroded across 10borders.

New Problems and Reforms: The recent literature is related to convergence phenomena. The report on transnational organized crime and cyber convergence by UNODC (2024) defines how criminal systems become more technologically integrated and suggests the need to reorganize investigation 6 District Court: In re Warrant to Search a Certain E-Mail Account Controlled & Maintained by Microsoft Corp. ,

15 F. Supp. 3d 466 (S.D.N.Y. 2014)

7 CLOUD Act § 103, 18 U.S.C. § 2713 (2018)

8 Ishii, Yurika, 'Introduction

Unconventional Investigations of Transnational Crimes', International Law and the Investigation of Transnational Crimes, Oxford Monographs in International Humanitarian & Criminal Law (Oxford, 2025; online edn, Oxford Academic, 8 Oct. 2025),

9 Marina Caparini, Transnational Organized Crime

A Threat to Global Public Goods, SIPRI (Sept. 2, 2022), https://www.sipri.org/commentary/blog/2022/transnational-organized-crime-threat-global-public-goods. 10 Transnational Organized Crime, U.N. Off. on Drugs & Crime, https://www.unodc.org/unodc/en/data-andanalysis/toc.html (last visited Jan. 14, 2026). systems to focus on the hybrid nature of emerging threats. The SIPRI analysis places transnational crime as a form of undermining global common goods, which is associated with weakening of the state capacity and illegal financial flows. Some concepts of reforms are as follows:

1. Selective MLAT measures within a time-constrained transmission of the electronics.

2. International standardisation of minimum digital evidence standards.

3. Enforcement capacity-building of the Global South, on a mandatory basis.

4. Asian-Pacific adjustments of Europa paradigms of regional integration. Ola (2024)

specifically suggests a centralised multidisciplinary agency of investigation and compulsory cooperation penalties to defeat the barrier as a sovereignty.

5. To have a more detailed view on the literature perspective, it should be supported with

the needed case laws. Case Law Analysis The study of jurisprudence in various jurisdictions sheds light on the problematic aspects of structural and procedural issues that transnational criminal investigation presents in territorially confined legal institutions and jurisdictions that can barely adapt to cross-border investigation requirements. United States v. Alvarez-Machain11: The case was a historic Supreme Court case that made it clear that American courts have jurisdiction over defendants regardless of how they are transported into the U. S. territory even by forceful kidnapping without the consent of a country in which the seizure took place. The Court believed that the lack of an extradition treaty did not mean that unilateral forcible abduction should not be used.

The case is an example of the jurisdictional asymmetry of transnational investigation, that is, the strong countries can export investigative power across their borders, but weaker ones. The case illustrates that the different approaches to jurisdiction

11 United States v. Alvarez-machain, 504 U.S. 655 (1992)

do form incentive structures, which prefer unilateral action instead of cooperative structures, such as MLATs, to the detriment of institutionalized cooperation and creating diplomatic friction. United States v. Microsoft Ireland Case. Microsoft Corp12 This case was of a U. S search warrant concerning customer information that was held on Microsoft servers that were physically based in Ireland. The Second Circuit reasoned that the Stored Communications Act did not permit extraterritorial performance of a warrant regardless of the sovereignty of the foreign state. The court ruled that it was not possible to force Microsoft to release data abroad. This ruling demonstrates the digital evidence crisis: the usual MLAT procedures, which are designed to produce documents, are ineffective when serving massive data requests in cloud format.

The case prompted Congress to pass the CLOUD Act (2018) which unilaterally extended U. S. investigative jurisdiction by establishing corporate compliance requirements instead of cooperative ones- exemplifying how the lack of jurisdiction in digital practice leads to unilateral systems of action that weaken the norm of cooperation. Prosecutor v. Tadic (ICTY Appeals Chamber, 1995): Even though a technical international criminal law decision, the ICTY ruling13 on personal jurisdiction has provided that the current transnational crimes justify the claim of jurisdiction on the basis of universal principles, rather than based on territorial presence. The court appreciated that hard-line territorial jurisdiction principles might be used to abet impunity of transnational criminals.

Nonetheless, the law later indicated the opposite issue: broad universal jurisdiction claims cause overlapping jurisdictions. Operation Lionfish: The case of Operation Lionfish is an example of an effective implementation of INTERPOL frameworks in transnational investigation. This global initiative to combat the organized drug trafficking within the Latin America used the INTERPOL I-24/7 to help the member countries share information quickly, leading to massive seizures and arrests. The success of the operation

12 United States v. Microsoft Corp., 829 F.3d 86 (2d Cir. 2016)

13 Prosecutor v Tadic (ICTY Appeals Chamber, 1995)

relied on standardized procedures that allowed the transfer of criminal intelligence to various legal systems in different countries. All these three cases have indicated that transnational investigation governance tends to swing between two dysfunctional extremes: on one extreme, inflexible territoriality that tolerates impunity, or on the other extreme, broad-handed unilateral jurisdiction that undermines the collaborative models. This judicial stalemate supports the existing literature that statutory MLAT change and procedural norm standardization is necessary to build a more predictable rights-compliant framework of transnational investigation.

Comparative Analysis The structure of transnational criminal-investigation demonstrates some critical differences in the State commitment to cross-border cooperation, which is influenced by geopolitical interests, institutional capacity, and commitments on rule of law. Multilayered cooperation frameworks have been institutionalized in highly cooperating jurisdictions including the United States, United Kingdom, Canada, Australia and the European Union. EU, via the European Investigation Order (2014)14 and through Europol, has simplified the MLAT protocols to 60-

90 days to allow the digital evidence to be shared with little diplomatic routing. The US has

bilateral MLATs with 67 countries15 and uses the Mutual Legal Assistance Network to expedite requests; its 24/7 law enforcement coordination system based on the Legal Attache offices of the FBI makes real-time investigative backing. Conversely, the relatively cooperative jurisdictions like India are good examples in structural bottlenecks that hinder successful transnational investigation. India has only 39 MLATs with only 39 countries (as of 2024), largely Anglophone and Western, which is a far worse result compared to financial havens and the rest of emerging economies. The Centre of Internet and Society research work documents the way the centralized approval system that places investigative power of MLAT in the ministry of External Affairs instead of law enforcement results in delays of an average of 14-18 months.

The international investigations unit at CBI is also under-equipped, which does not have real-time digital forensics capability or specialised training on cybercrime. Additional complications in data localization requirements of the EUROPOL, Mutual Legal Assistance and International Cooperation in Criminal Matters (2023), https://www. europol. europa. eu/cms/sites/default/files/documents/mla_guidance_2023. pdf. U. S.

DEP'T

OF STATE, BUREAU OF LEGAL AFFAIRS, Mutual Legal Assistance Treaties, https://www. state. gov/key-topics-office-of-the-legal-adviser/mutual-legal-assistance-treaties/ Indian Information Technology Act, 2000 are that such information held on Indian soil cannot be access by external authorities without directly statutory authorisation- further complicating efforts to obtain evidence even with highly cooperative partners. The most acute transnational investigation challenges are those that exist in non-cooperating and intentionally obstructionist jurisdictions. Nicolas Maduro state has gradually left the international cooperation systems, declining the requests of the INTERPOL Red Notices and granting protection to narcotraffickers and those who violate the sanctions.

North Korea is functioning as a haven of cybercriminals and money launderers, refusing to give in to extradition and participation in international criminal justice. Likewise, Russia, despite being a member of INTERPOL, is not very cooperative and does not extradite the nationals of Russia and abuses the jurisdiction loopholes to accommodate oligarchs and state-sponsored criminals. The asymmetry of the structures is too clear: the rich, institutionally strong democracies control the networks of cooperation, whereas less developed countries, authoritarian regimes, and jurisdiction with parallel power systems deliberately hinder the investigations. This introduces a two layer system in which transnational criminals tactically use non-cooperating jurisdictions as switches in laundering systems because they know that the investigations cannot cross such borders.

Moreover, it should be emphasized that in the long term, such transnational investigation of the culprits turns into an issue of diplomacy. An instance of the case of Vijay Malya when the UK shelters such a white collar criminal but the extradition agreement is an issue in the discussion of other trade agreements and international relations. Critical Analysis Jurisdictional Fragmentation and Heterogeneity of the Law. The core barrier to successful transnational investigation is still the persistent division of the jurisdiction of criminals among the sovereign states. Although theorists of transnational criminal law have formulated advanced theories that encompass this fragmentation with suggestions of extraterritorial jurisdiction which are based on universal jurisdiction, passive personality, and effects doctrine16, the practical application is inconsistent and often controversial.

16 M. Cherif Bassiouni, International Criminal Law (3d ed. Brill Academic Publishers 2003).

Practical investigative barriers are developed by the heterogeneity of definition of criminal law. Two jurisdictions defining money laundering or organised criminal involvement differently, investigators can not confidently determine that evidence collected in one jurisdiction can comply with elements to prosecute in another jurisdiction17. This difference of definition goes up to the evidentiary requirements: jurisdictions vary considerably in their admissibility of evidence in form of hearsay, intercepted communications, and electronic evidence. This standardization deficiency, as one practitioner study found, makes harmonization efforts hard to provide... equivalent, fluent cooperation between parties operating by differing legislation18. Transnational investigation is also complicated by the difference between the civil and common law systems of the world.

Adversarial procedure is the focus of common law systems, and the investigation is shared between the police and prosecutors and the judicial system. The civil systems of law focus investigative power in judicial examining magistrates. These differences in procedures imply that certain investigative procedures may be considered as permissible in one jurisdiction nad not in other jurisdictions. Delay of Time and Delay of Process. Practitioner research studies have documented that timelines of cross border investigation are many times longer than that of domestic investigation. In cases where local investigations are carried forward by way of police questioning, court hearings and trial, in the range of 12-18 months, transnational investigations often take 18-36 months or more19.

It has been shown that the implementation of MLAT can take weeks or even months20, and that even with digital evidence across jurisdictions it is common to take over two years to collect evidence. These delays are brought about by various sources. To begin with, diplomatic channels are still the official route towards MLAT request in most countries. Request even in cases where bilateral treaties are in place has to be transmitted through embassies, and this introduces bureaucratic overlay21. Second, the countries on which the requests are assigned often get too 17 Peter Cullen & William C. Gilmore, International Developments in Money Laundering and Terrorist Financing,

8 J. Money Laundering Control 141 (2005).

18 Alessandro Cadoppi & Cristina De Maglie, Comparative Models of Transnational Criminal Law, 23 Eur. J. Crime, Crim. L. & Crim. Just. 5 (2015) (discussing challenges in cross-border harmonization). 19 Nele Neumann & Christoph Schott, Temporal Dimensions of Cross-Border Investigation: Comparative Study,

22 Int’l J. Comp. Criminology 178 (2022)

20 Charlotte Oxford & Michael R. Williams, at 12 (2022)

21 Philip B. Heymann, The Limits of Law Enforcement Cooperation, in International Law and Criminal

Practice (Am. Soc’y Int’l L. 1990). many MLAT22 requests at once but are not able to execute them quickly. An examination in

2024 identified that an average of 180 days was spent handling MLATs in the United States

and complex requests were common with a time of more than one year. Third, nonstandardization adds to futher delay in investigation. Most importantly, such delays deter effectiveness and delivery of justice in investigations23. Memories of witnesses are lost, online infrastructures are altered by offenders, and criminal organizations adjust to investigative methods. Privacy, Data Protection, and Confidentiality Limitations. A lot of jurisdictions have heavy limitations on cross-border exchange of investigative information, which pose distinct barriers as opposed to jurisdictional or procedural barriers. Germany is a transnational investigation case study of limitations on protection of data24: Germany has refused to sign MLATs with India, claiming India has capital punishment which is incompatible with German constitutional mandates and data protection values.

Although there is an extradition treaty between Germany and India25, the lack of an MLAT is a policy decision limiting the exchange of evidence because of the fear of ultimate use of shared information. The limitation of privacy and confidentiality is not restricted to data protection systems. The laws of the national security of many countries forbid the disclosure of investigation data to other governments, especially in cases where investigations are based on classified intelligence. In other countries, evidence gained in some methods of investigation. A more pointed review would indicate that the privacy and data protection models have now overreacted in limiting the collaboration of law enforcement. Although the privacy protections26 are still relevant, the existing frameworks fail to balance the interests of privacy with the legitimate law enforcement requirements.

22 U.S. Dep’t of State, MLAT Processing Report (Office of Legal Affairs 2024).

23 U.N. Off. on Drugs & Crime, Manual on Mutual Legal Assistance 45 (2018).

24 William A. Schabas, Germany’s Death Penalty Prohibition and International Law, 1 German L.J. 15 (2000).

25 Ministry of Home Affairs, India, Guidelines on Mutual Legal Assistance 23 (2022).

26 Simon Chesterman, Intelligence and National Security, in The Oxford Handbook of Comparative Foreign Relations Law (Oxford Univ. Press 2011).

Evidence and Admissibility Issues in Digital Evidence. There are unique challenges to digital evidence in transnational investigation. Electronic evidence such as email communications, cloud services, telecommunications records and transaction records often cuts across several jurisdictions. The email providers (usually situated in the United States), recipients (who may be situated in other countries) and communications infrastructure providers (spread across the world) can be needed to conduct a single email investigation. Digital evidence has significant differing chain-of-custody requirements depending on jurisdiction27. There are countries where the verified originals are needed and those where the certified copies are not allowed; there are also countries where the digital authentication is accepted, but the original production is not required.

Such differences impose significant barriers when the digital evidence moves across nations. These barriers are worsened by the lack of harmonised standards of classifying digital evidence. Digital evidence is treated differently by different countries some countries consider metadata to be primary evidence, others consider it to be a derivative one; some countries consider digital records existing in digital form to be inherently trustworthy, others require authentication despite digital creation and storage28. These differences in classification imply that the digital evidence that is admissible in its native state might not be used during prosecution in the jurisdiction states, which makes the collection of transnational evidence pointless. Recommendations Recommendation 1: Standardise and bring cross-border frameworks to understanding. India should.

Assign specialised taskforce on this that focuses on shortcomings of the international investigating tactics and suggests the new reforms. There will be a specialised task force that would assist in the negotiations with other sovereigns as well. Such a task force will possess the knowledge and expertise of the legal framework in all jurisdictions with the sole aim of extraditing and prosecuting international criminals. Recommendation 2: Settle Presumptive Rapid-Response Procedures. India needs to shift to presumptive speedy structures of MLAT rather than discretionary processes of the same in relation to distinct types of transnational crime (human trafficking, terrorism, drug trafficking). Such procedures ought to provide presumptive 60-day execution schedules, which can only be extended through written explanation to the petitioning state.

Such presumptive timelines on given categories of crimes, which are high priorities in India, need to be incorporated in its bilateral MLATs. Recommendation 3: Devise Digital Evidence Protocols. International organizations are expected to come to an agreement on common protocols of authentication of digital evidence, chain-of-custody, and cross-border transmission. These protocols must acknowledge that digital evidence is not similar to physical evidence and must set up digital-specific authentication measures. Budapest Convention on Cybercrime (since

2004) ought to be improved with additional protocols dealing with digital evidence standards.

Recommendation 4: Use Harmonized Privacy Standards. Instead of individual jurisdictions having their own privacy systems, states ought to incorporate convergent privacy benchmarks of transnational investigation due to the fact that the present fragmentation can not allow the collaboration without compromising the protection of legitimate privacy. The suggested solution would create minimal privacy protection that would be equally applied among cooperating states and no state will be allowed to create a higher privacy restriction that can be used to thwart co-operation. The privacy protection would be aimed at ensuring that the information obtained during the investigation is not used in areas other than the area given a criminal investigation, and not preventing the sharing thereof. Recommendation 5: Harness Transnational Investigation Units in the National Law Enforcement.

Large law enforcement agencies ought to have specially designed transnational investigation units that have members who are working on international issues on a permanent basis. Such units would have a continuation of the relationship with similar agencies in major jurisdictions and therefore delays as a result of ad hoc cooperations would be minimized. The CBI in India needs to increase its transnational investigation by establishing specialized units that specialize in cybercrime, money laundering, and financing of terrorism. Conclusion The investigating agencies play a very crucial role in criminal justice system. It is their mandate to make sure that the rule of law is upheld. This discussion has shown that transnational investigation refers to a system that is both full in its scope and disjointed in its delivery.

Several international tools impose on cross-border cooperation but these tools are not sufficiently protective of the effectiveness of investigation because of substantial impediments: jurisdictional fracturing, time latencies, privacy limitations, and evidentiary heterogeneity. The current framework is based on a premise of collaboration that is weak in dealing with conflicts of jurisdictural legal requirements. The recent EIO and EPPO (European Public Prosecutor Office) architecture by the European Union shows that transnational investigation efficacy can be significantly enhanced with the help of harmonization and institutional trust. The execution time scales have reduced 12-18 months (in the traditional MLAT processes) to 90 days (in the EIO processes) and the conviction rates of the transnational organized crime cases have also improved respectively.

But these gains are conditional upon institutional integration and harmonization of the laws that would have been impossible between different jurisdictions of the world. This contribution indicates the urgency of the necessity to reform to make sure that people investigative bodies are not pressurized. The cooperation, mutual support, exchange of data and better funding can help to restore public trust. The problem of enhancing autonomy is not an administrative issue solving but one of the keys to preserving the federal balance in India and values of democracy.

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