This case was written by Muhammad Ahsan Rana for the Lahore University of Management Sciences to

serve as a basis for class discussion rather than to illustrate either effective or ineffective handling of an
administrative situation. This material may not be reproduced in any form without the prior written consent
of the Lahore University of Management Sciences. Certain identifying information may have been disguised
to protect confidentiality. This research was funded by Canadian International Development Agency
(CIDA).

2006 Lahore University of Management Sciences


A NOTE ON THE NON-PROFIT SECTOR IN PAKISTAN:
AN OVERVIEW

THE NEW DEVELOPMENT PARADIGM

The recent expansion of the market sector in Pakistan has significant implications for the
other two sectors the state and the civil society. As the state abdicates more space in
favour of private enterprise and reduces its role in the provision of basic social services, it
requires new ways to meet its obligation to ensure fair access to public goods. The new
development paradigm that has emerged in Pakistan and elsewhere recognizes that
although private sector activity does meet some needs, a new form of social partnership
involving state, citizens and business is required to address the needs that have remained
unmet by the state or business.

The new development paradigm relies explicitly upon the civil society, also called the
third sector. It facilitates the citizens to voluntarily organize themselves to address the
challenges of poverty, social deprivation and ignorance. It is through their collective
action that the citizens express their beliefs, values and culture, and act as pressure groups
to safeguard their basic rights. At times, there is some overlap with the for-profit activity
of the private sector, but usually the operating sphere pertains to areas where there are
limited prospects for economic profits. With respect to the government, the civil society
acts as a partner in the delivery of social services (e.g., education, health, social safety nets
and community development) and as an independent auditor of public sector performance.

In contemporary development discourse and academic discussions, the term civil society
is used as an umbrella term for a range of non-state and non-market citizen organizations
and initiatives operating in a range of social, economic and cultural fields. These include
formal institutions such as political parties, trade unions, professional associations,
philanthropies, non-profit organizations (NPOs), academia, research institutions, pressure
groups, think tanks, and traditional formations such as faith-based organizations, shrines,
seminaries, neighbourhood associations, burial societies, panchayats, jirgas
1
and saving
groups (NGO Resource Centre 2004).

All these formal and informal institutions play an important role in complementing and
supplementing the activities of the other two sectors. In particular, the NPOs, an important
subset of civil society, have come to occupy a very important position because of a
phenomenal rise in their numbers and size in the recent past. The scope of their activities
now ranges from basic service delivery to lobbying for legal and fiscal reform. Their
influence results from their ability to generate additional resources and to use the media,

1
Panchayats and jirgas are indigenous institutions for collective action and dispute resolution


20-003-2006-2
information technology, the judicial system and professional research to mobilize public
opinion for social causes. The sections that follow take a closer look at the nature and
dimensions of the non-profit sector as it exists in Pakistan today.

HISTORY AND GROWTH OF NPOS

Since time immemorial, the charitable and associational activities in areas that today
comprise Pakistan were based on tradition and religion. In the second half of the
nineteenth century, the British started grafting western notions of organization and civic
development on this tradition of voluntary charitable action. The prime motive to
institutionalize voluntary charitable activity appears to be twofold: (1) to keep a check on
organized social activity so that it does not become a threat to the colonial rule; (2) to
encourage philanthropists to come forward and share the burden of the government in
providing basic social services (Iqbal et al, 2002). The British enacted The Societies
Registration Act in 1860 to improve the legal condition of societies set up for literary,
scientific or charitable purposes. The Trust Act, 1882 provided further legislative
endorsement and became a popular instrument for charitable activities.

The first notable stream of organized development activity came from the Christian
Missions that established schools and hospitals in various areas of Punjab, Sindh and the
North-Western Frontier Province (NWFP). Some of the earliest mission schools included:
Edwards Church Mission School, Peshawar (1855); Convent of J esus and Mary, Sialkot
(1858); and Saint J osephs Convent, Karachi (Iqbal et al, 2002).

In 1864, Sir Syed Ahmad Khan launched the first modern effort for civic reform of
Muslims from the platform of The Scientific Society, an NPO registered under the new
enabling legislation, The Societies Registration Act, 1860. In 1875, he established the
Mohammadan Anglo Oriental College at Aligarh in India. Taking the lead from Sir Syed,
several Muslim philanthropists established institutions in the late nineteenth and early
twentieth century for the educational and social uplift of Muslims. Collectively, these
efforts are known as the Aligarh Movement.

The first Muslim organization established in Punjab was Anjuman-i-Islamiyah. It was
founded in 1869 to take over and maintain the Badshahi mosque that had been used during
the Sikh period as a magazine for storage of gunpowder. The Anjuman-Himayat-i-Islam
was established in 1886 and represented a spontaneous desire on the part of middle class
Muslims of Lahore to cooperate with each other for the common good (Bhatti 2003). It
actively worked for the welfare of the Muslims by establishing many schools and
orphanages.

Karachi was another centre of charitable activity, where concerned citizens were engaging
in similar endeavours. Mr Hasan Ali Effendi established the Sind Madrasa-tul-Islam, an
educational institution of great eminence. The initiative was generously supported by
Muslim philanthropists. The Madrasa
2
started in a small building and quickly grew into a
top class public school. Apart from being an educational institution, it had a department of
handicrafts and industry. It played an important role in creating a Muslim middle class in
Sindh (Iqbal et al. 2002).

Other outstanding examples of this era include the Diyal Singh Majithia Trust (1895) that

2
Madrassa means school in Urdu
2
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furthered the cause of education and established libraries and colleges. Nadirshaw, Edulji
Dinshaw invested in education and established the NED college (1924) and Lady Dufferin
Hospital; and Sir Ganga Ram built schools and hospitals and supported destitute widows
(PCP 2002).

A slightly different stream of voluntary citizen action could be seen in the growth of
cooperative societies. In 1904, the British introduced the concept of cooperative societies
through the passage of The Credit Societies Act, 1904. The German model of rural
development inspired the British to introduce the cooperative societies. Credit and saving
components were important features of this movement. By 1929, there were 101,150
cooperative societies in India, of which 21,000 (with over 650,000 members) were in the
then Punjab (Darling 1947).

After the creation of Pakistan in 1947, the nascent citizen sector focused on apolitical
service delivery until the late 1960s. The creation of a new country and the consequent
dislocation of millions of refugees prompted a focus on relief work and humanitarian
assistance. The sixties saw a major government sponsored push for community
mobilization. The Voluntary Social Welfare Agencies (Registration and Control)
Ordinance, 1961 was promulgated to create agents in the Non-Profit sector to work with
the government for a welfare state. The government funded hundreds of voluntary
agencies across the country to deliver social services to the underprivileged. These
decades also saw many business leaders actively engaged in philanthropic activities from
the platform of their family foundations.

The emerging Non-Profit sector received a considerable setback in the seventies when the
government nationalized large and medium industrial units and various service providers.
Educational institutions owned by voluntary organizations, including the well-managed
Sind Madrasa-tul-Islam and Anjuman-Himayat-i-Islam, were taken over. The state
acquisition of basic industries also diminished the funding sources for many charitable
organizations. The Islamic institution of zakat
3
, a great source of individual giving, was
also brought under state control thus harming a major source of philanthropic funding for
NPOs.

Fortunately, the setback suffered in the 1970s proved an aberration in the continuous
growth of the sector. The 1980s and the nineties witnessed a tremendous growth of the
Non-Profit sector. The reasons were many. The US and its client military regime in
Pakistan vigorously patronized religious parties, who set up thousands of religious
seminaries across the country, especially in the NWFP and Balochistan. The rapid growth
of madaris that provided free education, lodging and boarding to the poor had as much to
do with the failure of the state in providing these services as with the inflow of foreign aid
to religious organizations. Iran, Saudi Arabia and other Middle Eastern states also poured
in funds to various groups to wage their proxy war on Pakistani soil.

The Islamization policies of the military government led to apolitical (but organized)
resistance by human rights and women rights groups. Dozens of rights-based advocacy
organizations germinated in the protests led by, for example, the Womens Action Forum.
These organizations have since evolved from their role as the voice of the people (in the
absence of political parties in the 1980s) into community mobilizers and critics of the
government and various vested interests (Bhatti 2003).

3
An obligatory form of charity for well-to-do Muslims
3
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Furthermore, there was a paradigm shift in the international aid delivery model, which
increasingly emphasized delivery of services through NPOs. Funds poured in from
international development agencies to support the large influx of Afghan refugees and for
other social services. This contributed to the mushroom growth of citizen organizations in
the 1980s (Rehmatullah 2002). Where previously the impetus for their growth was the
absence of publicly available services, the NPOs had now been reinforced by a
reassessment by the donors (Khan and Bari 2005). The huge inflow of funds sent by
Pakistani communities proved another important source of funding for NPOs, and their
consequent growth.

More importantly, the state reversed the nationalization policies of the seventies. The state
realized that it could not go alone; it needed others to shoulder the burden of providing
basic social services. Especially significant was the opening up of the education sector to
private organizations.

Over the last 58 years of post-colonial existence, we have travelled a long way from the
patron-client relationship envisaged by The Social Welfare Agencies (Registration and
Control) Ordinance, 1961 to recent legislation like The Local Government Ordinance
(LGO), 2001 which creates and recognizes institutional mechanisms for direct interaction
between the state and NPOs through the latters statutory participation in numerous policy
and development processes.

ESTIMATING SIZE AND SCOPE OF ACTIVITIES OF NPOS

In contemporary development literature, NPOs have been variously called Private
Voluntary Organizations (PVOs), Social Welfare Agencies (SWAs), Community
Organizations (COs) and Non-government Organizations (NGOs). Despite the changing
nomenclature and the enormous diversity in their organizational structure and nature/scope
of activities, they share some common features (Ferraro 2001). In particular, they:

1. Have an institutional presence and structure
2. Are institutionally separate from the state
3. Do not distribute profits (more appropriately called surplus) to their members,
managers or directors
4. Are fundamentally in control of their own affairs
5. Attract some level of voluntary contribution (of time or money)
6. Do not require mandatory membership (i.e., membership is purely voluntary)

In 1968, a study undertaken by the University of Punjab showed that there were 159
national and provincial level organizations registered with the government (Rehmatullah
2002). Of these, 64 were based in Lahore and 66 in Karachi. Assuming an equal number
of local and district level organizations, one can safely assume that the total number of
NPOs in 1968 was not more than 300. Since then, the number of public-benefit, non-
government, non-profit organizations has grown exponentially, but reliable data is not
available about them. The only study that attempts a scientific estimation of the present
number of NPOs in Pakistan was conducted in 2000-2001 by the Center for Civil Society,
J ohns Hopkins University, USA (under its comparative non-profit sector research project)
in collaboration with the Social Policy and Development Centre (SPDC), Pakistan.

The study (Ghaus-Pasha et al, 2002a) estimates that there are about 65,000 registered
NPOs in Pakistan with more than six million members and a quarter of a million staff.
4
20-003-2006-2
Another 38 percent are unregistered
4
, taking the total number of registered and
unregistered organizations close to a hundred thousand. Although the study reports the
number of active organizations to be around 45,000, it is hard to estimate with any degree
of reliability the number of active organizations because of the definitional issues
involved. After all, what level of activity would qualify an organization to be active is a
matter of opinion more than anything else. Nevertheless, the study estimates that NPOs
mobilize large sums of money with operating cash revenue of Rs 16 billion per year (0.5
percent of GDP in that year), while 37 percent of the funding is from domestic
philanthropy. International development agencies contribute only seven percent of total
non-profit revenues; only six percent comes from the government (Ghaus-Pasha et al,
2002a).

The NPOs are mainly registered under four major registration laws
5
: The Societies
Registration Act, 1860; The Trust Act, 1882; The Voluntary Social Welfare Agencies
(Registration and Control) Ordinance, 1961; and The Companies Ordinance, 1984. The
following tables describe the registration status of NPOs:

Table 1: Registration Status of NPOs (2000)

Registration Law Percentage
The Societies Registration Act, 1860 40.5
The Voluntary Social Welfare Agencies Ordinance, 1961
6
15.2
The Trust Act, 1882 5.8
The Companies Ordinance, 1984 0.3
Registered under other Acts 0.1
Unregistered, applied for registration 4.0
Unregistered, not interested in registration 34.1
Total 100.0
Source: (Ghaus-Pasha et al, 2002a)

Table 2: Province-wise Estimated Number of NPOs Registered Under Major Laws
(Cumulative Numbers, June 2000)

Province Social Welfare
Agencies
Ordinance,
1961
Societies
Registration
Act, 1860
Companies
Ordinance,
1984
Total
Punjab 5,421 27,702 45 33,168
Sindh 4,572 11,877 442 16,891
NWFP 1,675 1,343 15 3,033
Balochistan 1,035 2,085 7 3,127
Pakistan 12,703 43,007 509 56,219
Source: (Ghaus-Pasha et al, 2002a)

4
Either not interested in registration (34 percent) or registration in progress (4 percent)
5
The Local Government Ordinance (LGO) 2001 had not been promulgated at the time, and data was being
collected. Hence, the report does not take into account the organizations registered under LGO, 2001. In any
case, since the Ordinance is recent, the number of organizations registered under it is not expected to be
large
6
Many organizations registered under The Societies Registration Act, 1860 or The Trust Act, 1882 are also
registered under The Voluntary Social Welfare Agencies (Registration and Control) Ordinance, 1961
5
20-003-2006-2
NPOs in Pakistan engage in a diverse set of activities. These range from religious
education to sports activities; from performing religious rites to lobbying for civic
amenities; and from running small vocational centres to nation-wide human rights
advocacy organizations. The size also varies from small informal neighbourhood
graveyard management committees to multi-billion rupee hospitals.

Table 3 shows that the single largest block of NPOs (29.5 percent of all active
organizations) is engaged in religious education while another 2,000 is dedicated to
organizing religious events. Religion is also the overwhelming reason for individual
charity. Although most of the giving is faith based, it goes to social causes (mainly
education and health). The following table illustrates the diverse range of activities NPOs
undertake. It also highlights the fact that most of the NPO activity is concentrated in urban
and peri-urban areas.

Table 3: Estimated Composition of the Non-profit Sector by Activities (2000)

Type of Activity Share of
Organizations
(%)
Urban
Share (%)
Religious education 29.5 68.6
Lobbying for civic amenities 14.6 81.0
Primary education 8.5 92.3
Religion 4.9 75.8
Secondary education 4.8 77.8
Resident welfare associations 4.8 81.8
Material assistance to the needy 4.5 79.8
Health treatment, primarily outpatient 4.4 90.0
Sports 4.2 83.5
Shopkeepers/traders associations 3.6 85.3
Vocational/technical/special education 2.5 63.0
Community and neighbourhood improvement 2.2 67.1
Civil rights promotion 2.1 84.1
Income support and maintenance 1.9 87.9
Hospital care inpatient 1.1 100.0
Burial and funeral services 1.1 95.2
Other organizations (less than 1% share) 5.3 76.3
Total 100.0 78.1

Source:(Ghaus-Pasha et al, 2002a)

NPOs have also emerged as a significant economic force. The study estimates that with an
estimated wage bill of Rs 13 billion, they employ about 260,000 persons. The full-time
equivalent paid employment is approximately 10 percent of the total public sector
employment.

6
20-003-2006-2
Table 4: The Non-profit Sector as an Economic Force (2000)

Full-time equivalent paid employment as a proportion of total non-
agricultural employment
2.3 %
Full-time equivalent paid employment as a percentage of public
sector employment
10 %
Full-time equivalent voluntarism as a proportion of non-agricultural
employment
1.9 %
Operating expenditure as a percentage of GDP 0.41 %
Cash revenue as a percentage of GDP 0.52 %

Source: (Ghaus-Pasha et al, 2002a)

Consequent to this phenomenal growth in size and scope of non-profit activity in Pakistan,
clear structural changes are happening in the sector. Significant umbrella bodies have
evolved to coordinate and represent elements of the sector according to the nature of the
work. Most significant have been the emergence and growth of various NPO networks,
e.g., Pakistan NGO Forum (PNF). Religious organizations had long organized themselves
into well-knit hierarchical bodies based on party or sectarian lines, but through these
networks non-religious organizations have also started to coordinate their actions to create
synergies, especially when it comes to lobbying for civil rights.

The growth of advocacy and rights-based organizations has significantly influenced the
dynamics of state-citizen sector relationship. These groups have impacted policy by
leading criticism against the government, political parties, and customary social practices.
On the other hand, the thousands of students trained in a large number of madaris are the
muscle behind the power wielded by the religious right. Electoral successes of religio-
political parties in the 2002 national elections can also be partly attributed to the cadres
trained in the seminaries.

Growing size and increased organization have meant increased recognition and influence.
Almost all official social sector planning documents emphasize the desire of the
government to partner with the non-profit sector for alleviating poverty and for providing
basic social services. The poverty reduction strategy paper (PRSP), for example,
comprehensively articulates the policy shift as under (para 5.190 and 191:

The non-profit voluntary sector in Pakistan has emerged as a significant
force in promoting social and human development. It complements the
government in many ways. The government appreciates the contribution
that the NGO sector can make in social development [and] providing help
to the vulnerable. This is reflected in the institutional support to NGOs
through a range of government ministries including the Ministry of Women
Development, Social Welfare and Special Education that is the focal point
for NGOs and various projects under execution in different provinces.
[The government] also provides financial support through the National
Council for Social Welfare and the National Zakat Foundation and similar
bodies in provincial governments. The poverty reduction strategy
recognizes the significant role that NGOs can play in social service
delivery, advocacy and empowerment (Government of Pakistan 2003).

7
20-003-2006-2
The resolve of PRSP, however, needs to be followed up through more inclusive
implementation frameworks. The policy enunciations need to be translated into planning
and execution of development projects at the national, provincial and local level. While
the commitment from higher echelons in the government as being more inclusive towards
local communities in general and NPOs in particular is unequivocal, the more functional
tiers remain ambivalent and reluctant to develop meaningful partnerships with NPOs. This
ambivalence is rooted in the long-standing distrust between the government and NPOs as
much as in the states reluctance to share its power of benevolence.

THE REGULATORY REGIME

The following list
7
contains all major laws (in chronological order) that regulate some
distinct aspect of the sector:

1. The Societies Registration Act, 1860
2. The Religious Societies Act, 1880
3. The Trust Act, 1882
4. The Charitable Endowments Act, 1890
5. The Code of Civil Procedure (Section 92), 1908
6. The Mussalman Wakf Validating Act, 1913
7. The Charitable and Religious Trust Act, 1920
8. The Mussalman Wakf Act, 1923
9. The Cooperative Societies Act, 1925
10. The Mussalman Wakf Validating Act, 1930
11. Charitable Funds (Regulation of Collections) Act, 1953
12. The Voluntary Social Welfare Agencies (Registration and Control) Ordinance,
1961
13. (Punjab, Sindh, NWFP, Balochistan) Wakf Properties Ordinance, 1979
14. The Companies Ordinance, 1984
15. (Punjab, Sindh, NWFP, Balochistan) Local Government Ordinance, 2001
16. Income Tax Ordinance, 2001
8


All laws listed above concern some aspect of non-profit work, but their relative
importance varies considerably. As can be calculated from Table 1, about 88 percent of all
registered NPOs function under The Societies Registration Act, 1860 or the Voluntary
Social Welfare Agencies (Registration and Control) Ordinance, 1961. Another 10 percent
are registered as public trusts under The Trust Act, 1882. Detailed examination has been,
therefore, limited to only these laws
9
. Although a mere 2 percent of all registered NPOs
are non-profit companies, and the number of organizations registered under the Local
Government Ordinance, 2001 (as Citizen Community Boards) is small, these have been
included in the analysis as being the most modern instruments of establishing and
managing an NPO.


7
The Religious Endowments Act, 1863 was never made applicable to areas that constitute Pakistan today
and has, therefore, not been included in the list
8
Also, the Income Tax Rules, 2002 (211 220A), which specify the conditions and procedure for grant of
tax exempt status to an NPO
9
There are around 61,000 registered cooperatives in Pakistan, but few exist on ground. More importantly,
cooperatives established under The Cooperative Societies Act, 1925 are membership-based for-profit
organizations that allow distribution of profit, if any, amongst the members. As such cooperatives are not
NPOs as understood in this paper
8
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THE SOCIETIES REGISTRATION ACT, 1860

This is the oldest of the registration laws. It was created largely to promote professional,
scientific and fine arts activities and diffusion of useful knowledge and political
education
10
. It was extended later to encompass charitable and social organizations as
well. Registration under this law is also open to organizations for mutual benefit, such as
clubs and residents associations.

It has historically remained the most popular instrument of voluntary association for
charitable activities mainly because of the very lenient registration, auditing, accounting
and reporting requirements (Ismail 2002), and the very broad range of permissible
activities
11
. Under the Act, seven or more persons may establish a Society. At least three
of the members would comprise the Governing Body. To establish a Society, a
Memorandum of Rules and Regulations of Association must be printed. These documents
should contain clauses that state the objectives for which the society is being established
and set out the modus operandi. If an existing society or association, which may not be
registered already, wishes to register itself under this Act, an assent of its being so
registered has to be given by three-fifthof the members present at a General Body meeting
convened by the Governing Body for this purpose. No inquiry is provided for before
registration.

In addition to the Memorandum of Association, the Rules and Regulations for governing
the Society must be set out and filed with the Registrar of Societies
12
. The Rules and
Regulations, certified by not less than three members of the Governing Body, must contain
obligatory clauses relating to membership in the General Body and Governing Body;
meetings and quorums; meeting notices; election and removal of officers; and procedures
relating to accounting and audits (Ismail 2002).

Once the society receives its certificate of registration, its legal status is that of an artificial
juridical person
13
, which means it can enforce its rules against its members, sue and be
sued in its own name, own property and open/operate bank accounts in its own name. The
control of property, however, vests in the Governing Body and not the members. Further,
if a judgment is passed against a person acting on behalf of the society, the judgment can
only be enforced against the property of the society, and not against the person.

A society may be dissolved when at least three-fifth of the members in a general meeting
agree on and specify the time of dissolution. Any property remaining after satisfaction of
liabilities must be transferred to another society with similar aims and objectives. A
society, however, cannot be dissolved without the consent of the registering authority, if
the government is a member of, or a contributor to, or otherwise interested in such a
society.

10
Diffusion of political education was added as a legitimate purpose in 1927
11
It is interesting to note that organizations as divergent as the defunct Sipah-i-Sihaba on one end and the
Human Rights Commission of Pakistan (HRCP) on the other are registered under this Act
12
Until recently, the Registrar of Societies in the Industries Department of Provincial Governments used to
perform this function. The Local Government Ordinance, 2001 has, however, devolved this function to the
Executive District Officer, Finance and Planning in a district
13
Admittedly, there is some disagreement on this in the legal circles. For example, see Shah, S A H (2003).
Regulation of Civil Society Organizations: A Pakistan Case Study. Rome, International Development Law
Organization: 43. He has argued that the Act does not confer the status of an artificial juridical person on
the societies registered under it. But then there are numerous others (e.g., Bhatti 2003) who have opined that
it does.
9
20-003-2006-2
The Provincial Government may suspend (for a maximum period of one year) or dissolve
the Governing Body if the society is unable to or fails to discharge its duties, is unable to
administer its affairs or meet its financial obligations, or acts in a manner contrary to
public interest or the interests of the members. In case of suspension, the Governing Body
may again be reconstituted after the specified period according to the Memorandum of
Association and Rules of the Society. In case of dissolution, the government shall
reconstitute the Governing Body and assign it the management of the society.

Registration is voluntary under the Act. However, a recent amendment has made it
mandatory for all religious seminaries to be registered under the Act. The exact text is
reproduced below.

Registration of Deeni Madrassah

1. A Deeni Madrassah by whatsoever name called shall not be established or
operated without being registered as a society under this Act

2. The Deeni Madrassah shall, in addition to the other provisions of this Act, be
subject to the following conditions:

a) To submit annual reports of its activities and performance to the Registrar;
b) To maintain accounts of its expenses and receipts and annually submit the
report to the Registrar; and
c) To cause to be carried out audit of its accounts by an Auditor and annually
submit its audited accounts to the Registrar.

3. No Deeni Madrassah shall teach or publish any literature which promotes
militancy or spreads sectarian hatred and religious hostility.

Explanation: In this section, Deeni Madrassah means a religious institution
established or operated primarily for the purpose of imparting religious education
whether providing lodging and boarding facilities or not and includes a J amia,
Dar-ul-Uloom, School, College, University, or any other religious institution,
called by whatsoever name, set up for the aforesaid purpose.

This insertion (Section 21) has compromised the liberal and voluntary character of the
Act. The amendment is clearly discriminatory as it does not require mandatory registration
for organizations other than the seminaries, nor does it ask them to submit annual reports,
or audited financial statements. Setting aside the merits or the need for regular audits and
submission of periodic reports, the simple fact that a large segment of societies has been
exempted from doing so makes this a bad legislation, to say the least.

THE TRUST ACT, 1882

The Trust Act was enacted in the late nineteenth century to define and amend the law
relating to private trusts and trustees. As such, it was primarily designed to govern the
establishment and operation of private trusts. A private trust is a trust established to benefit
a certain group of people, which is not a changing population. Whereas, a public trust is a
trust that is established for the benefit of society at large or a section of society or a group
of people, which is a changing population. But since there are no particular laws relating
to public trusts, the rules and principles enunciated in The Trust Act, 1882 are also applied
10
20-003-2006-2
to public trusts
14
. A number of laws implicitly recognize the phenomenon for example,
that registration under The Societies Registration Act, 1860 vests the property of the
Society in its governing body as de facto trustees (implicitly equivalent to a public trust).
The fact that registration under the Act of 1860 allows for what is in effect a public trust
regulated by statute is a valuable benefit resulting from the act of registration.

For a trust, the existence of a creator (author of the trust), and specification of trustee(s)
and beneficiaries are essential requirements. For establishing a public trust, there must be
some property (whether in cash or in kind and whatever its value may be) to be vested in
trust, and the objectives of the trust must be charitable or for the benefit of society. A
trust may be created for any lawful purpose. The author, having once created the trust, has
no privileged position, in any manner whatsoever, in respect to other trustee(s).
The procedure for the creation of a trust is simple. A public and charitable trust can be
created merely through a declaration to that effect on a non-judicial stamp paper of a value
(different across provinces) stated in the Stamp Act. Registration is optional. The legal
status of a trust is that of a property pledged for the benefit of its specified beneficiaries.
A trust is brought to an end when: its purpose is fulfilled; when the trust becomes
unlawful; when the fulfilment of its purposes becomes impossible due to the destruction of
trust property; or when a revocable trust is expressly revoked. However, a change of
trustee, which is a lengthy and time-consuming process, is the prerogative of the civil
court. Section 92 of the Civil Procedure Code, 1908 requires institution of a suit in the
civil court of competent jurisdiction by the Advocate General (or an officer to whom the
authority is delegated by the provincial government) or two or more persons having an
interest in the trust for removing a trustee, appointing a new trustee, vesting any property
in a trustee, or authorizing the whole or any part of the trust property to be let, sold,
mortgaged or exchanged.

Table 5: Provincial Fee Structure for Registration (2000)

Province Societies Registration Act Trust Act
Punjab Rs 500 1.0 % ad valorem
Sindh Rs 15,000 4.5 % ad valorem
NWFP Rs 7,500 2.5 % ad valorem
Balochistan Rs 200 1.0 % ad valorem

Source: (Baig, Q and Ismail, Z H, 2004)

The Trust Act provides legal cover for private acts of public charity
15
, and allows its
creators tremendous flexibility in their operations. There are no reporting or auditing
requirements at all, except for maintaining proper records and making these available for

14
Courts have also tended to apply The Trust Act, 1882 in adjudicating matters relating to public trusts
(Ismail 2002)
15
Trusts take two forms, the commonly understood trust and the waqf in the Muslim law. For the creation of
a trust, as defined in secular law, no religious motive is necessary. However, a waqf under the Muslim law is
generally made with a pious, charitable or religious purpose. While the secular trust has no restriction as to
its intent and purpose, except that it be for lawful purpose, the waqf is created for the ultimate benefit of
mankind. A trust property vests in trustees, but a waqf property vests in God. The trustees have wider powers
than the mutawalli (manager or superintendent) of a waqf. A trust need not be perpetual and irrevocable. A
waqf once created, cannot be altered or rescinded (Ismail 2002)
11
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inspection by the beneficiaries.

THE VOLUNTARY SOCIAL WELFARE AGENCIES (REGISTRATION AND
CONTROL) ORDINANCE, 1961

The Ordinance is an important addition to the non-profit law in Pakistan. The then military
Government seems to have had two objectives: a welfare state, responsible for delivery of
all social services, and agents needed to mobilize the local communities to deliver social
services. The scope of activities that the Ordinance enumerates underlines this focus on
provision of basic social services, formalization and development of social safety nets, and
on promotion of certain state sponsored programs. The Government also wanted to bring
all organizations that were active in social welfare and dependent on public subscriptions,
donations or government aid under one umbrella law. These could, then be supported
through grants, aid and training. For this patronage, the government would regulate them
rigorously and also perhaps keep them on a tight leash (Bhatti 2003).

Though a Federal Statute, the Ordinance is administered independently by the provincial
governments through the Directorates of Social Welfare. Under the new local government
set up, registration under the Ordinance is carried out at the district level by the Executive
District Officer, Community Development, (EDO, CD). The application for registration
must be accompanied by the Constitution of the Agency. The registration authority may
make enquiries, as deemed proper, before deciding the application. Amendment in the
Constitution can be effected only after the approval of the registration authority.

The Ordinance requires that all organizations engaged in charitable work must be
registered with the Social Welfare Department. Registration is mandatory for
organizations working in one of the twelve specified areas and seeking funds from the
public or the government. Registration, however, does not confer the status of an artificial
juridical person
16
. Even though it can sue and be sued in its own name and institute other
legal proceedings, it cannot own property. Further, it is protected from litigation and
prosecution for anything done in good faith.

The Ministry and Departments of Social Welfare can provide funding to the Social
Welfare Councils, autonomous government institutions at the Federal and Provincial
levels, for making grants to Agencies. Without registration, access to this body of funds is
denied. Every Agency registered under the Ordinance must submit its annual report to the
registration authority and maintain audited accounts, which must be made public. The
Ordinance empowers the registration authority to inspect the books of accounts and other
records of securities, cash and properties held by the Agency. The minimum operating
requirements are that it should make public its annual reports and audited accounts, and
pay all funds received into a separate account with a scheduled bank.

The main role of the registration authority vis--vis registered NPOs is that it can act as
arbitrator in case of disputes or winding up. The government has the discretionary right to
dissolve an agency through due process or replace the governing body arbitrarily. If the
registration authority believes that a registered Agency is acting against its constitution or
rules, or in a manner that is contrary to the interests of its members, it may, after giving the

16
Many organizations, however, are simultaneously registered under The Societies Registration Act, 1860
and the Voluntary Social Welfare Agencies (Registration and Control) Ordinance, 1961. This subjects them
to dual regulation. A Society, which is also an Agency, would be an artificial juridical person by virtue of its
registration as a Society
12
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Agency an opportunity to defend itself, make a report to the provincial government for
dissolution. The governing body or members cannot dissolve a registered Agency.
However, if more than three-fifth of the members of the Agency make a dissolution
application, it may be considered by the authority. Property and assets of the Agency
which are held in the name of the Governing Body, upon dissolution, are transferable only
to another Agency with similar objectives with prior approval of the registration authority.
While in its own terms, the scope of the Ordinance is restricted to organizations working
under one or more of the twelve fields listed in the schedule to the Ordinance, section 16
empowers the government to include or exclude any field of social service from the
schedule by issuing a notification. Given the vast area of its applicability and the
mandatory registration stipulated, the Ordinance is a serious negation of fundamental
rights to associate guaranteed by Article 17 of the Constitution of Pakistan. In practice,
however, the Ordinance has rarely been implemented with any degree of vigour. This
underscores the impossibility of implementing laws that seek intrusive degrees of
control
17
. It is this lack of implementation that has, in all probability, saved the Ordinance
from constitutional challenge (Bhatti 2003).

THE COMPANIES ORDINANCE, 1984

At the other end of the scale in terms of both choice and complexity is The Companies
Ordinance, 1984. Registration through this instrument requires a substantial amount of
documentation. The documentation includes information on the antecedents of sponsors,
memorandum and articles of association, and then after registration, the filing of annual
returns and other reports including an audit report, audited accounts and an activity report
by the directors every year.

A non-profit company is registered under Section 42 of The Companies Ordinance, 1984
as a public
18
company with limited liability, provided it directs or intends to direct its
profits (if any) or any other form of income, toward advancing its objectives, prohibits
payment of any return to its members and does not distribute its assets among its members
on dissolution. The liability of the directors is limited by guarantee, though organizations
registered under Section 42 cannot write Ltd with their titles.

The biggest advantage of registration under the Ordinance is the conferment of the status
of an artificial juridical person. A non-profit company can sue and be sued in its own name
and can acquire/hold property in its name. Registration is achieved through an application
for a license to the Securities and Exchange Commission (SECP) of Pakistan, which is
based in Islamabad. At the provincial level, the applications for registration are processed
by the SECP provincial offices and by the Registrar J oint Stock Companies, Department
of Industries. Registration can also be done at the district level by Executive Development
Officer (F&P), if the company is situated and operates wholly within a district. No appeal
is provided if an application for registration is rejected. The license specifies the terms
under which the company may be registered. Once the license has been granted, the
memorandum and articles of association cannot be changed without prior permission from

17
A case in point is the continued existence and operation of a large number of organizations not registered
under the Ordinance, though the same have been established for purposes enumerated in the schedule to the
Ordinance and raise funds from the public or receive government donations
18
Some confusion has been created in this regard by the recent amendments in The Companies Ordinance,
1984 introducing the concept of single member companies. The amendment, read with Section 42, implies
that an NPO can also be established under the Ordinance with only one director, and can, therefore,
practically become a private NPO. The confusion will be clarified in due course through judicial process
13
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the SECP or the registration authority at the provincial/district level.

NPOs registered as a non-profit company function in a regulatory environment that is
primarily meant to protect the investment expectations of corporate shareholders. This
results in a degree of regulation and compliance with regulatory procedures that is not
feasible for most charitable organizations. Hence, not many NPOs have opted to register
under The Companies Ordinance, 1984 during the last two decades of intense non-profit
activity in Pakistan. On the other hand, the high level of regulatory control to which
charitable companies are subjected to enhances the credibility of such organizations. This
signalling effect is of value to the best-organized and funded NPOs that can afford
compliance costs of the Ordinance.

THE LOCAL GOVERNMENT ORDINANCE, 2001

The provincial Local Government Ordinances (LGOs) of 2001 envisage a new kind of
non-profit organization, the Citizen Community Board (CCB) for mobilizing participation
of local communities in the development process. The mechanism specified for
registration of CCBs is simple. A group of citizens may set up a CCB in a local area and
get it registered with the Executive District Officer (Community Development). There can
be more CCBs than one in the same area and existing NPOs can also register themselves
as CCBs.

The Ordinance requires all CCBs to have a general body of members who shall elect a
Chairperson, Executive Committee (EC) and a Secretary to carry out its functions. The
term of office of the Chairperson, EC Members and Secretary is two years. Re-election is
permissible for any number of terms. It is mandatory for the EC members to hold at least
one meeting in each quarter, minutes of which are to be kept by the Secretary. The CCBs
are required to get their accounts audited and present a statement of accounts before the
registration authority annually. The registration authority can appoint an administrator,
take over the assets and dissolve a CCB if it is not functioning in accordance with the
Ordinance.

The Ordinance envisions a wide range of permissible activities for the CCBs. These
include: organizing the community for development; improving service delivery by a
public facility; developing and managing a new public facility; welfare of the
handicapped, widows and destitute families; establishing farming, marketing and
consumer cooperatives; and forming stakeholders associations for community
involvement in improving and maintaining specific facilities.

Despite this very broad range of permissible activities and the ease of registration, LGO
has not so far become a popular instrument for registration of citizen organizations having
long-term commitment and programs. For the most part local community-based initiatives,
limited to a couple of specific projects, have generally been the activities that have
attracted citizen groups to organize themselves as CCBs. Although the scope of activities
as enumerated in Section 98 of the Ordinance is vast and the Ordinance declares CCBs as
non-profit organizations (Section 101), the local dimension of the initiatives and
approval mechanisms render the Ordinance unattractive as a medium of registration for
NPOs aiming to work at a national/provincial level or on national/provincial issues. Since
most policy making continues to remain with the provincial/federal government, it
requires provincial/national level NPOs to articulate public interest at these forums. For
this reason, apparently no NPO with a long-term mission has opted to register as a CCB;
14
20-003-2006-2
neither has a CCB grown into such an NPO.

Even in the case of small physical infrastructure projects, lack of awareness about the
functions and responsibilities of CCBs has led to the capture of these institutions by the
political elite, most notably the elected Nazims. Many people in the elected councils feel
that they, being elected representatives of the people, alone have the right to articulate
peoples interest in development schemes and elsewhere.

The overall tone and tenor of the Ordinance, however, envisages grassroots public
participation by individuals as well as organized groups at every level and in all
development and policy initiatives. In this sense, it is a loud enunciation of the recognition
by the government of the important role citizen groups can play as a partner for social
development. It opens many vistas for government-community dialogue and cooperation.
The greatest contribution of the Ordinance, perhaps, is the creation of statutory space for
direct institutional interaction between citizens and the state.

RECENT REFORM EFFORTS

The regulatory regime is perhaps the most important of the public governance elements in
the non-profit sector. The laws and institutions governing non-profits have clearly failed to
do the job in Pakistan. The legal framework is both archaic and confusing (Ismail 2002).

There are too many laws that invariably cause duplication and confusion. There are
considerable variations in the prescribed governance standards and reporting and audit
requirements. Multiplicity of registration authorities not only creates confusion, it also
makes data collection difficult. The practice of laws also radically differs from what is
stated in the statute. To complicate matters further, compliance with the existing laws is
extremely poor. A survey of documents filed by organizations registered in Islamabad
under The Societies Registration Act, 1860 and The Voluntary Social Welfare Agencies
(Registration and Control) Ordinance, 1961 conducted by Pakistan Centre for
Philanthropy (PCP)
19
in 2003 revealed that less than 5 percent organizations comply with
their legally mandated reporting requirements (PCP 2003). Compliance is likely to be far
lower in other districts.

The diversity in laws has also been a contributory factor in creating an environment of
friction and hostility between the government and NPOs. The government alleges that
non-profits are following a donor agenda; are largely opaque and non-accountable; and
that a large number have the sole agenda of siphoning off charitable contributions,
government grants and foreign assistance. At the other end of the spectrum, NPOs have
been alleging that the government is bent upon destroying the sector because it considers
the sector a threat to government agencies (Yamamoto 2003). There is merit to both sides.

Dissatisfaction with the situation, has resulted in numerous attempts to rationalize and
consolidate the regulatory regime concerning NPOs. The following paragraphs discuss
two such initiatives from the government and two from the sector itself.

The first initiative was in 1994, when the government tabled The Social Welfare Agencies
(Registration and Regulation) Act in the parliament. The government had two main

19
PCP is an NPO registered under Section 42 of The Companies Ordinance, 1984. It is the first government
authorized NPO Evaluation and Certification Agency
15
20-003-2006-2
objectives. It wanted to liquidate inactive and fraudulent NPOs to ensure transparency in
the sector. Second, it wanted to monitor foreign funding to NPOs for security reasons.
Clearly the proposed enactment was control oriented. Quite expectedly, it met fierce
resistance from NPOs at home, and from international aid agencies, which by that time
had developed significant partnerships in the sector. The bill was not pursued.

The second attempt was made in 1996 through a much more stringent law, which was
presented before the Senate. It proposed to repeal the 1961 Ordinance and to bring in its
purview all social welfare organizations using public funds, regardless of the law they
were registered under. It also proposed to give the government discretionary powers to
dissolve an NPO and take over its assets (Ghaus-Pasha et al, 2002b). Once again, the civil
society put up a strong (and this time coordinated
20
) reaction and succeeded in thwarting
the control effort.

The criticism from the NPOs of the government bills mentioned above has put the sector
under immense pressure to come up with an alternate version that is facilitative in nature
and yet rationalizes the existing legislation. The first response to this challenge came from
the Pakistan NGO Forum in the form of a draft enactment, commonly known as the PNF
bill. The bill was placed before the Senate in 1999. The draft encapsulates the liberal civil
society view of regulation, accountability and transparency. Registration was proposed to
be voluntary for all organizations irrespective of the source or amount of funding. An NPO
could dissolve itself, amalgamate with another organization and amend its charter on its
own without seeking permission or approval from the government. In the same vein, no
minimum standards for internal governance were prescribed. The bill envisaged minimum
government intervention or oversight in the non-profit activity. The government was not to
start any investigation against any organization on its own on any grounds, whatsoever.
Only defined donors, members and governing bodies had a right to lodge a complaint
against an organization and demand investigation/inquiry. The bill aimed to replace the
Ordinance of 1961, without disturbing in any manner the existence or operation of The
Societies Registration Act, 1860.

While the government-sponsored draft enactments of 1994 and 1996 were too control
oriented, the PNF sponsored bill went to the other extreme. It envisioned an enabling
regime without proposing a solution to the issues of multiplicity of laws, harmonizing the
reporting and auditing requirements or ensuring more transparency and improved
governance in the sector. It contained nothing that could attract greater confidence and
trust for the sector from the public at large.

Having oscillated between the two extremes, both the government and the non-profit
sector started to think of a via media. The Enabling Environment Initiative of 2001
launched by the Federal Government envisaged the development of a set of proposals for
legal reform through a participatory process involving all major stakeholders, most
notably the government and the NPOs. The task of coordinating and spearheading the
dialogue was assigned to PCP. The then Minister of Social Welfare and Women
Development, Government of Pakistan, Dr Attiya Inayatullah enunciated the vision by
saying that the government was seeking to build confidence and understanding between
government and civil society organizations and hoping to put the unnecessary battle
between civil society and government to rest (PCP 2002).

20
In fact, the Pakistan NGO Forum (PNF), the largest NGO network in Pakistan, came into being to put up a
concerted response to the 1996 bill
16
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PCP submitted its draft recommendations to the government in 2002. It was proposed to
consolidate The Societies Registration Act, 1860 and The Voluntary Social Welfare
Agencies (Registration and Control) Ordinance, 1961 into one law, the Non-profit Public
Benefit Organizations (Governance and Support) Act of 2002. The new law would ease
registration standards, reduce official discretion, increase judicial oversight and remove
wasteful duplication. It also proposed setting up of autonomous national and provincial
non-profit commissions that could take over administration of the new law from the
government.

The proposed law
21
was essentially facilitative in content and aimed at creating an
enabling legal and regulatory framework. At the same time, it provided for judicial
oversight and superintendence by independent commissions. It also called for regular
audits and presentation of major financial statements. These were important
recommendations to inspire confidence from the general public in the working of the non-
profit sector. Most importantly, despite continued differences on some provisions, both
major stakeholders (i.e., the government and NPOs) agreed on the broad framework being
proposed.

This effort too, however, did not succeed and the bill is still pending with the Ministry of
Social Welfare. With the change of government and rise to power of right wing parties in
two provinces, it became increasingly difficult to push forward any reform effort that
could potentially effect the organizations registered under The Societies Registration Act,
1860 under which most of the religious seminaries are registered. Also, there was a lot of
power play between PCP on one hand and the government and the PNF on the other. Each
of them considered that it was their sole and legitimate right to formulate
recommendations concerning the regulatory regime for the non-profit sector. PCP draft
recommendations might ultimately die in the government files, but the need to consolidate
and rationalize the regulatory framework persists and will eventually provide the
necessary impetus for a new enabling law to appear in the statute book.

ISSUES AND CHALLENGES

There are a number of governance and transparency issues that the non-profit sector must
respond to. Perhaps the fundamental issue the sector faces is the lack of a uniform,
authentic and verifiable source of information on its size and scope. Without adequately
refined and updated empirical data about the sector, it is not possible to assess its outreach
and potential as a social development partner.

Second, governance is a major issue in the non-profit sector. Internal governance
structures are weak and personalized. Too often, the governing body is either nonexistent
or fails to perform its policy-setting and supervisory role. The governing bodies (Boards)
are often ceremonial at best, and in most cases ineffective or uninterested in playing their
due role as the custodian of public trust and as a bridge between the organizations and the
community at large. Policy decisions are left to the chief executive officers, who then
work without clear accountability to the governing body (Rehmatullah 2002). This leads to
erosion of credibility and wastage of scarce development funds. The sectors ability to
deliver services innovatively and to sustain development advocacy is also hampered.

21
Non-profit Public Benefit Organizations (Governance and Support) Act, 2003 is available in PCP
publication Creating an Enabling Legal Framework for Non-profit Organizations in Pakistan as well as on
PCP website (www.pcp.org.pk)
17
20-003-2006-2
An important challenge, therefore, for the non-profit sector in Pakistan is to ensure
democratic internal governance and self-regulation. One key actor in this regard can be the
governing bodies, which should establish a competent and accountable structure of
internal self-governance, and above all exercise fiduciary responsibility to ensure
transparent use of organizational resources in accordance with its mission (Ferraro 2001).

Third, the sector does not enjoy the legitimacy that it deserves. This is due to several
reasons, the primary one being the lack of transparency in making and documenting
financial transactions. The sector must realize that legitimacy is not a function of being
registered under law; rather it emanates from public recognition of the service being
provided.

The fourth issue is that of information sharing and disclosure. To ensure credibility, NPOs
have to improve the practice of informing their constituencies and other members of the
public fully and accurately about their work, especially program outcomes, benefits to
communities and most importantly matters of finance and accounts. Most NPOs are
extremely tight lipped about their sources of funding and executive expense (including
salaries). NPOs need to move beyond simply publishing annual reports consisting mostly
anecdotal evidence to try new and non-conventional methods and instruments of
communication, such as the internet for public disclosure of important organizational,
program and financial information.

Fifth, a major challenge for the non-profit sector is to build a public image commensurate
with the work it is doing. It is a question of positively marketing itself and its
contributions. The layperson is by and large unaware of the positive role being played by
scores of NPOs, small and large, across the country. An example is the content analysis of
two major English and one Urdu newspapers conducted by the NGO Resource Centre
(NGORC) in 2003. The research found a sharp dichotomy between the English and Urdu
press with the latter being generally negative towards CSOs (NGO Resource Centre
2004). The challenge lies not only in wider dissemination of the voluntary activity, but
also in taking the development concerns to the common citizens. One way to do this is to
involve them in the development process. This would automatically ensure greater
responsiveness and accountability of organizations within the sector. Greater reliance on
local resource generation will also increase public accountability and local participation in
the work of NPOs (Rana 2004a).

Finally, as the role of the sector in social development increases, its capacities must be
augmented to increase its efficiency and effectiveness. Several capacity-building
organizations are working towards this end. However, there are no clear standards and
benchmarks for performance. Because the sector is semiformal, the NPOs do not adhere to
sector-wide standards in governance, financial management and program delivery. There
is a clear need to develop such benchmarks, and to incentivize adoption of and adherence
to these standards by linking it with a range of benefits
22
(Rana 2004b).

22
PCPs Certification program is an interesting and valuable initiative towards developing such sector-wide
standards. The incentives offered through tax exemptions and increased access to national and international
donors effectively incentivize voluntary adoption of these standards of governance, transparency and
effectiveness. Further details of certification experience can be seen on PCP web site (www.pcp.org.pk)
18
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REFERENCES

Baig, Q. and Ismail, Z. H. (2004). Pakistan, Philanthropy and Law in South Asia, Manila, Asia
Pacific Philanthropy Consortium

Bhatti, Z. K. (2003). Pakistan Case Study, Governance, Organizational Effectiveness and the
Nonprofit Sector, Manila, Asia Pacific Philanthropy Consortium

Darling, S. M. (1947). The Punjab Peasant Lahore, Vanguard Books Ltd

Ferraro, P. (2001). Legal and Organizational Practices in Non-profit Management, The Hague,
Kluwer Law International

Ghaus-Pasha, A., H. J amal, et al. (2002a). Dimensions of the Nonprofit Sector in Pakistan.
Karachi, Social Policy and Development Centre: 26

Ghaus-Pasha, A., H. A. Pasha, et al. (2002b). Nonprofit Sector in Pakistan: Government Policy
and Future Issues. Karachi, Social Policy and Development Centre: 46

Government of Pakistan (2003). Poverty Reduction Strategy Paper. Islamabad, Government of
Pakistan; Ministry of Finance

Iqbal, M. A., H. Khan, et al. (2002). Nonprofit Sector in Pakistan: Historical Background.
Karachi, Social Policy and Development Centre: 47

Ismail, Z. H. (2002). Law and the Nonprofit Sector in Pakistan. Karachi, Social Policy and
Development Centre: 45

Khan, B. A. and F. Bari (2005). Introduction. Managing NGOs in Developing Countries:
Concepts, Frameworks and Cases. Z. I. Qureshi. Karachi, Oxford University Press. 1: 271

NGO Resource Centre (2004). Civil Society in Pakistan. Karachi, NGO Resource Centre: 53

PCP (2002). Creating an Enabling Legal Framework for Nonprofit Organizations in Pakistan.
Islamabad, Pakistan Centre for Philanthropy: 156

PCP (2003). Resources. 2005

Rana, M. A. (2004a). The Resource Generation Challenge: Can Accountability Help? Alliance
9(4)

Rana, M. A. (2004b). Setting Standards in the Nonprofit Sector: The Certification Experience in
Pakistan. International Journal for Civil Society Law II(IV): 5

Rehmatullah, S. (2002). Social Welfare in Pakistan. Karachi, Oxford University Press

Shah, S. A. H. (2003). Regulation of Civil Society Organizations: A Pakistan Case Study. Rome,
International Development Law Organization: 43

Yamamoto, T. (2003). Overview of 11 Country/Region Studies. Governance, Organizational
Effectiveness and the Nonprofit Sector, Manila, Asia Pacific Philanthropy Consortium


19