Comments to Article 1. Legislation of the Republic of Kazakhstan on administrative offences The Code of the Republic of Kazakhstan on Administrative Offences
1. The legislation of the Republic of Kazakhstan on administrative offences consists of this Code.
2. This Code is based on the Constitution of the Republic of Kazakhstan, generally recognized principles and norms of international law.
2-1. The introduction of amendments and (or) additions to this Code is carried out by a law that does not provide for amendments and additions to other legislative acts of the Republic of Kazakhstan.
This provision does not apply to cases of exclusion of administrative responsibility, as well as to draft laws developed in accordance with the legislative initiative of the President of the Republic of Kazakhstan.
3. International contractual and other obligations of the Republic of Kazakhstan, as well as regulatory resolutions of the Constitutional Council and the Supreme Court of the Republic of Kazakhstan regulating administrative and tort legal relations, are an integral part of legislation on administrative offenses.
4. International treaties ratified by the Republic of Kazakhstan have priority over this Code and are applied directly, except in cases where it follows from an international treaty that its application requires the publication of a law. If an international treaty ratified by the Republic of Kazakhstan establishes rules other than those provided for by the legislation of the Republic of Kazakhstan on administrative offences, the rules of the international treaty shall apply.
The new Code of the Republic of Kazakhstan on Administrative Offences is a single set of norms that regulates substantive and procedural administrative-tort relations. This is its main difference from the "old-timers' codes" - the Criminal Code, the CPC, the Civil Code, the CPC. This structuring of the Code is not new, it is borrowed from the Soviet period of development of the system of legal regulation of administrative responsibility. The Administrative Code of the Kazakh SSR of 1984 and the first in the history of sovereign Kazakhstan of 2001 consisted of a similar structure.
The history of the emergence and development of the institute of administrative responsibility for minor offenses (administrative offenses) in the system of Soviet law can be found in the monograph by Kirin A.V. "Administrative and tort law: (theory and legislative foundations)".
The conceptual difference between the Code of Administrative Offenses of 2014 and the Code of Administrative Offenses of the Kazakh SSR of 1984 and the Code of Administrative Offenses of 2001 is that for the first time the legislator attempted to segment the general rules for the tort (Special) part and the Procedural part. This trend can be clearly seen if you pay attention to the changes that have affected the articles of the General Part and Chapter 37 of the Administrative Code. The latter, according to the legislator, was supposed to become a kind of "Common part" for the Procedural Block of the Code.
Undoubtedly, both law enforcement officials and, especially, legal theorists, recognized the existence of "difficulties" in implementing the norms of the Code with uniform norms of the General Part. Due to the large number of features inherent in the Special and Procedural Parts, the norms of the General Part could not regulate them properly. This forced the legislator to formulate the wording of specific norms in such a way that there were no direct contradictions. As a result, the norms of the General Part were of the most general nature, unlike, for example, the Criminal Code, CPC, Civil Code and CPC. In our opinion, the attempt made by the legislator is the first step towards a future separation of substantive and procedural norms.
Part 1 of the commented article proclaims that the Code of Administrative Offences of the Republic of Kazakhstan is the only codified act that consists of the administrative and tort legislation of the Republic of Kazakhstan. In other words, legislation on administrative offenses should be understood only as tort relations, that is, the substantive norms that are formulated and legislated in sections 1 and 2 of the Administrative Code. These are the general objectives and principles of legislation on administrative responsibility, types of administrative penalties, and specific types of administrative offenses.
For comparison, Part 1 of Article 1 of the Administrative Code of 2001, which also asserted the exclusivity of the Code as the only codified legislative act on administrative offenses, provided for an additional provision according to which laws providing for administrative liability were to be applied only after their inclusion in the Administrative Code. Such a rule was necessary due to the fact that in the first period of Kazakhstan's independence, a large number of legislative acts were adopted containing separate sections on liability (including separate offences and sanctions). And in order to give exclusivity to the status of the Administrative Code, an additional norm was introduced in Part 1 of Article 1, which terminated all other regulatory legal acts that establish, in fact, administrative responsibility. Eg:
Chapter 42 "Tax offenses and responsibility for their commission" of the Law of the Republic of Kazakhstan dated April 24, 1995 "On Taxes and other mandatory payments to the Budget" (expired). For example, Article 163 provided for a fine in the amount of ten monthly calculation indices for violation by a taxpayer of the deadline for registration with a tax authority, as well as unjustified refusal by an official of a territorial tax authority to register a taxpayer.
Article 14 of the Law of the Republic of Kazakhstan dated December 24, 1996 "On Currency Regulation" (expired) provided for the liability of legal entities:
for making currency transactions that violate the provisions of this Law, -
in the form of a fine in the amount of 10 percent of the transaction amount, but not more than 1 million tenge;
for conducting currency transactions without proper reflection of their results in accounting -
in the form of a fine in the amount of the amount that was not taken into account;
for maintaining accounting records of currency transactions in violation of the established accounting and reporting procedures -
in the form of a fine of 5 percent of the amount that was improperly accounted for.
However, in the new Administrative Code, the legislator considered that there was no need to preserve such a rule, due to the fact that today sectoral laws do not contain legal norms on liability, performing only an auxiliary function, and do not act as independent legal grounds for bringing to administrative responsibility, which is logical.
Thus, the legislator endowed the new Code of the Republic of Kazakhstan on Administrative Offenses with an exceptional status as the only codified legislative act regulating administrative and tort legal relations.
It should be noted that a long-standing problem of the Administrative Code persists to this day, caused by the referential nature of its individual rules of a Special part. The onset of administrative responsibility in this case is closely related to the violation by a person of a specific norm established in industry laws or in subordinate regulatory legal acts in the form of violation of requirements, duties or prohibitions.
This is mainly the object of criticism, as it does not fully comply with the requirements of Article 61 of the Constitution of the Republic. At the same time, another form of establishing the fact of a violation and, consequently, the onset of administrative responsibility in a number of industries remains unlikely. This is due to a significant number of regulations involving delicacy. For example, violations in the field of education, in the field of protection and use of objects of historical and cultural heritage, export or shipment of raw materials and other goods outside the Republic of Kazakhstan, accreditation of gas grid organizations, collection activities, budget accounting, reimbursement of costs for the provision of guaranteed free medical care, accounting and financial reporting, labeling alcohol products, operation of oil pipelines, gas pipelines and their equipment, creation and operation of space systems on the territory of the Republic of Kazakhstan and in outer space, during operations on subsurface use, etc.
Undoubtedly, some of them could have been directly incorporated into the dispositions of the norms of the Special Part of the Administrative Code. At the same time, there remains another part of the regulation, with which such manipulations seem difficult. This should be the subject of further scientific research and legislative work.
Some authors believe that the provisions of Part 1 of the commented article also apply to the procedural rules of administrative-tort relations. However, this is not the case. The main provisions of the administrative procedure legislation are formulated and legislated in sections 3-5 of the Administrative Code. This is the general procedure for proceedings in cases of administrative offenses, bodies authorized to consider cases of administrative offenses and the execution of decisions on the imposition of administrative penalties. It is symbolic in this regard that art. 736, which allows us to reveal the intention of the legislator and confirms the above conclusion.
It has already been noted that this structure of the Code is borrowed from the Soviet period of development of the system of legal regulation of administrative responsibility. In Soviet science, unlike criminal and criminal procedure law, which have long been two independent branches of law, substantive administrative and administrative procedure law have never been separated. Moreover, they were part of the general administrative law – the law of management. Both of these groups of legal norms were organically merged into a single branch of Soviet law - administrative law.
Thus, substantive norms (Sections 1 and 2 of the Administrative Code) fix the initial rights and obligations of subjects of law in a certain area of regulation of public relations, and procedural norms (sections 3-5 of the Administrative Code) determine the procedure and procedures for the implementation of substantive norms, the rights and obligations of subjects of procedural legal relations.
Part 2 of the commented article establishes the provision of paragraph 2 of Article 4 of the Constitution of the Republic, according to which the Constitution has supreme legal force and direct effect throughout the territory of the Republic of Kazakhstan. In addition, paragraph 7 of Article 62 of the Constitution states that the laws of the Republic, and this means the Administrative Code, should not contradict the Basic Law of the country. It should be noted that not only normative legal acts, that is, articles, parts, and sub-paragraphs of the Administrative Code, but also acts of individual application issued (applied) by an official or a court in the implementation of procedural actions established by the Code, must comply with the norms of the Constitution.
Such acts include the protocol on an administrative offense, the definition, the resolution on the imposition of an administrative penalty and other legal acts.
Along with the Constitution, the Code of Administrative Offenses is also based on generally recognized principles and norms of international law. Generally recognized principles of international law are understood as its broadest and most important norms, which express its main content and characteristic features and which have the highest, imperative legal force. The basic principles of modern international law are enshrined in a number of documents of the most authoritative international organizations, in particular, the UN Charter, the Declaration on Principles of International Law of 1970, the Final Act of the Conference on Security and Cooperation in Europe of 1975, the Universal Declaration of Human Rights of 1948.
Such principles include: sovereign equality of States; non-use of force and threat of force; non-interference in internal affairs; respect for human rights and fundamental freedoms, etc. International legal norms act as a normative guideline, a kind of standard for law-making in national states, and at the same time as their voluntarily accepted obligations that must be consistently fulfilled.
The addition of part 2-1 of the article is dictated by the administrative problem that binds the entire community of activists - the excessive activity of the legislator in terms of amendments (amendments and additions) to the Administrative Code. This problem is systemic, as the old Administrative Code also "suffered" from it.
Statistics show that over 185 amendments have been made to the Code of Administrative Offences since it became invalid. Moreover, this practice has increased in recent years: since 2012, more than 63 laws have been adopted, which supplemented the Administrative Code (2001) with over 250 articles.
The problem here is not the quality of the Administrative Code, but the specifics of the subject of its regulation - almost all branches of human activity. As a result, it is very difficult to find a bill that would not affect the Administrative Code with accompanying amendments.
As of January 2020, 114 different legislative acts have already been amended and supplemented in the new Administrative Code. At the same time, the largest number of amendments to the Administrative Code were introduced in 2015 – 36 laws, which is 48.6% of the total number of laws that amended and supplemented the Administrative Code. Most of them relate to a Special part, in particular, the establishment of new administrative offenses or their correction.
The specifics of the legislative process in the Republic of Kazakhstan are such that sectoral laws are semi-officially assigned to government agencies through the institute of legal monitoring, which primarily determine state policy in this area of regulation. In addition, such amendments are often included in the draft for the first time already within the walls of Parliament, as the implementation of a legislative initiative by members of Parliament.
As a result, it is very difficult for the authorized body (the Ministry of Justice), which is assigned to the Administrative Code, not only to resist such an avalanche of proposals, but even to physically identify them.
This required the adoption of radical measures by analogy with the Tax Code of the Republic of Kazakhstan. This part restricts the introduction of amendments and (or) additions to the Administrative Code only by law with one subject (target). Such a draft law should not provide for amendments and additions to other legislative acts of the Republic of Kazakhstan. Of course, this is not the same as how this issue is resolved in the Tax Code, and it is more similar to mechanical obstruction of registration, as it requires a lot of legal and technical efforts by developers.
Another provision that deserves attention is the exception limiting the main prohibition. This prohibition does not apply to cases of exclusion of administrative responsibility, as well as to draft laws developed in accordance with the legislative initiative of the President of the Republic of Kazakhstan. The logic of the legislator in this case is very clear and does not need to be commented on.
Part 3 states that the international contractual and other obligations of the Republic of Kazakhstan, as well as the normative resolutions of the Constitutional Council and the Supreme Court governing administrative and tort legal relations, are an integral part of the legislation on administrative offenses.
Of course, these acts are of great importance in regulating administrative and tort relations, but the claim that they are an integral part of legislation on administrative offenses is controversial.
Firstly, based on this interpretation, it turns out that all of the above-mentioned acts are an integral part of the Administrative Code. This provision, one might say, contradicts the norms of the Constitution, since in accordance with paragraph 1 of Part 4 of the Constitution of the Republic, all of the above acts, along with the norms of the Constitution itself, are independent sources and components of law, a concept broader in scope than legislation. Moreover, in accordance with paragraph 5 of art. 10 of the Law of the Republic of Kazakhstan dated April 6, 2016 "On Legal Acts", the normative resolutions of the Constitutional Council and the Supreme Court are outside the hierarchy of normative legal acts, which once again indicates their special position in the system of Kazakh law.
Secondly, the question arises about the appropriateness of this provision in the substantive part of the Code, given that according to the norms of the Constitution, the Constitutional Council gives an official interpretation of the norms of the Constitution, and the Supreme Court of the Republic of Kazakhstan, in cases provided for by law, examines court cases within its jurisdiction and provides clarifications on judicial practice. That is, they do not create new, independent rules of law.
For example, the normative resolution of the Constitutional Council dated April 13, 2012 No. 2 "On the official interpretation of the norms of the Constitution of the Republic of Kazakhstan on the calculation of constitutional terms" gives the official interpretation of paragraph 2 of Article 16 of the Constitution.:
"In relation to paragraph 2 of Article 16 of the Constitution, "detention" should be understood as a measure of coercion, expressed in a short-term, no more than seventy-two hours, restriction of a person's personal freedom in order to prevent an offense or ensure proceedings in criminal, civil and administrative cases, as well as the use of other coercive measures and carried out by authorized state bodies., officials and other persons on the basis and in the manner prescribed by law.
The beginning of the period of detention is the hour, to the exact minute, when the restriction of the freedom of the detained person, including freedom of movement, is forced to be held in a certain place, forcibly brought to the bodies of inquiry and investigation (seizure, closure in a room, coercion to go somewhere or stay in place, etc.), as well as any other Actions that significantly restrict a person's personal freedom have become real, regardless of giving the detainee any procedural status or performing other formal procedures. The expiration date of this period is the expiration of seventy-two hours, calculated continuously from the time of the actual detention.".
Regulatory rulings of the Supreme Court of the Republic of Kazakhstan are issued for the purpose of uniform application of judicial practice. For example, the regulatory rulings of the Supreme Court:
- "On the application of measures to ensure proceedings in cases of administrative offenses" dated April 9, 2012 No. 1;
- "On some issues of application by courts of the norms of the General Part of the Code of Administrative Offences of the Republic of Kazakhstan" dated December 22, 2016 No. 12;
- "On some issues of application by courts of the norms of the Special part of the Code of the Republic of Kazakhstan on Administrative Offenses" dated October 6, 2017 No. 7.
Thus, international treaties and other obligations of the Republic of Kazakhstan, as well as regulatory decisions of the Constitutional Council and the Supreme Court, do not form new torts, therefore, they should not be an integral part of administrative and tort legislation. The provision on their status and meaning should be reflected in the procedural part of the Code by analogy with the criminal procedure legislation.
Part 4 reproduces the constitutional provisions of paragraph 3 of Article 4 of the Constitution, according to which international treaties ratified by the Republic take precedence over its laws. This highlights the priority of international treaties, which may establish rules other than those provided for in the Administrative Code. Eg:
- Convention on Legal Assistance and Legal Relations in Civil, Family and Criminal Matters, ratified by the Resolution of the Supreme Council of the Republic of Kazakhstan dated March 31, 1993;
- Convention on the Mutual Recognition and Enforcement of Decisions in Cases of Administrative Violations of Traffic Rules, ratified by the Law of the Republic of Kazakhstan dated December 30, 1999;
- Agreements on legal assistance and cooperation between the customs authorities of the member States of the Customs Union in criminal and administrative cases, ratified by the Law of the Republic of Kazakhstan dated December 14, 2011;
- The Agreement on the specifics of criminal and administrative liability for violations of the Customs legislation of the Customs Union and the Member States of the Customs Union, ratified by the Law of the Republic of Kazakhstan dated December 8, 2011;
- Lease agreement for the Baikonur complex between the Government of the Republic of Kazakhstan and the Government of the Russian Federation, ratified by Decree of the President of the Republic of Kazakhstan dated April 17, 1995;
- Convention on Privileges and Immunities of the Shanghai Cooperation Organization, ratified by the Law of the Republic of Kazakhstan dated December 15, 2005, and others.
Additionally, it should be noted that in order to interact with the competent authorities and officials of foreign countries in cases of administrative offenses, the Administrative Code provides for a new chapter 50, which regulates the conditions for providing legal assistance in cases of administrative offenses.
It should be noted that a prerequisite for the priority of international treaties is their ratification by Kazakhstan, with the exception of international treaties concluded by Kazakhstan before 1995 and not requiring ratification.
Article 3 of the Constitution of the Republic of Kazakhstan of 1993 stated that "international legal acts on human and civil rights and freedoms recognized by the Republic of Kazakhstan have priority over its laws on the territory of the Republic." Later, in the Constitution of 1995, this provision was amended by including an indication of the need for prior ratification of such treaties in accordance with the Constitutional Law of the Republic of Kazakhstan dated October 16, 1995 "On the Parliament of the Republic of Kazakhstan and the Status of its Deputies" and the Law of the Republic of Kazakhstan dated May 30, 2005 "On International Treaties of the Republic of Kazakhstan".
When preparing for this article, it should be borne in mind that paragraph 3 of Article 4 of the Constitution was amended by the Law of the Republic of Kazakhstan dated March 10, 2017 "On Amendments and Additions to the Constitution of the Republic of Kazakhstan". In particular, the procedure for the operation of international treaties has been changed. Now the procedure and conditions of their operation on the territory of the Republic of Kazakhstan are determined by the legislation of the Republic.
The Constitutional Council, in its Resolution No. 18/2 dated October 11, 2000 "On the official interpretation of paragraph 3 of Article 4 of the Constitution of the Republic of Kazakhstan", establishes that the Republic of Kazakhstan expresses its consent to the pre-emptive legal force of those international treaties concluded by it over national legislation, which are ratified by the Parliament of the Republic through the adoption of the relevant law. Only international treaties ratified by Kazakhstan can have priority over the laws of the Republic. The priority over the laws of ratified international treaties on the territory of the Republic presupposes the situational superiority of the norms of such treaties in cases of conflicts with the norms of laws. Non-ratified international treaties do not have such priority over the laws of the Republic. With the exception of those that were concluded before 1995 and did not provide for ratification. "International treaties that did not provide for ratification as conditions for entry into force, concluded before the adoption of the Constitution of 1995, are valid and retain priority over the legislation of the Republic, if such priority for these international treaties is directly provided for by the laws of the Republic regulating the relevant areas of legal relations."
Similar approaches were also reflected in the normative resolution of the Constitutional Council of November 5, 2009 No. 6 "On the official interpretation of the norms of Article 4 of the Constitution of the Republic of Kazakhstan in relation to the procedure for the execution of decisions of international organizations and their bodies."
In addition, when considering the provisions of this article of the Code, it is necessary to be guided by the regulatory resolution of the Supreme Court of the Republic of Kazakhstan dated July 10, 2008 No. 1 "On the application of the norms of international treaties of the Republic of Kazakhstan".
Paragraph 1 of the regulatory resolution of the Supreme Court of the Republic of Kazakhstan dated December 22, 2016 No. 12 "On certain issues of the application by courts of the norms of the General Part of the Code of Administrative Offences of the Republic of Kazakhstan" states that courts in the administration of justice should proceed from the fact that international contractual and other obligations of the Republic of Kazakhstan are in accordance with paragraph 1 of Article 4 of the Constitution an integral part of its current law. When considering a case, the court has no right to apply the norms of the legislation of the Republic of Kazakhstan on administrative offenses, if other rules are established by an international treaty, the decision on consent to be bound by the Republic of Kazakhstan was made through ratification or accession. In these cases, the rules of the international agreement apply.
Decisions of international organizations and their bodies that violate the provisions of the Constitution on the sovereignty of the country, the inadmissibility of changing the unity and territorial integrity of the state established by the Constitution, the form of government of the Republic, and infringing on the constitutional rights and freedoms of man and citizen cannot be recognized as binding on Kazakhstan. 4 of the normative Resolution of the Constitutional Council dated November 5, 2009 No. 6 "On the official interpretation of the norms of Article 4 of the Constitution of the Republic of Kazakhstan in relation to the procedure for the execution of decisions of international organizations and their bodies").
Scientific and practical commentary to the Code of the Republic of Kazakhstan on Administrative Offences (article-by-article) from the Author's team:
Bachurin Sergey Nikolaevich, Candidate of Law, Associate Professor – chapter 48 (co-authored with E.M. Khakimov);
Gabdualiev Mereke Trekovich, Candidate of Law – Chapters 11, 21, 22, 23;
Zhusipbekova Ainur Maratovna, M.yu.n. – chapter 13 (co-authored with Karpekin A.V.); chapters 33, 39 (co-authored with Seitzhanov O.T.);
Alexander Vladimirovich Karpekin, Candidate of Law, Associate Professor – chapter 13 (in collaboration with A.M. Zhusipbekova);
Korneychuk Sergey Vasilyevich – chapters 2; chapter 6 (co-authored with O.T. Seitzhanov, E.M. Khakimov); chapter 8; chapter 25 (co-authored with E.M. Khakimov); articles 457-470, 488, 488-1, 491-506; chapters 28, 30, 52;
Ilya Petrovich Koryakin, Doctor of Law, Professor – Chapter 49;
Kisykova Gulnara Bauyrzhanovna, Candidate of Law – chapter 20;
Omarova Botagoz Akimgereevna, Candidate of Law – chapters 17; chapter 18 (co-authored with B.A. Parmankulova); chapters 26, 31; chapter 32 (co-authored with B.A. Parmankulova);
Parmankulova Bayan Askhanbaevna – chapter 18 (co-authored with Omarova B.A.); chapters 19, 32 (co-authored with Omarova B.A.); chapter 43 (co-authored with Tukiev A.S.);
Podoprigora Roman Anatolyevich, Doctor of Law, Professor - Chapter 24, articles 489, 489-1, 490;
Porokhov Evgeny Viktorovich, Doctor of Law – Chapters 14, 15, 16, 29, articles 471-475;
Seitzhanov Olzhas Temirzhanovich, Candidate of Law, Associate Professor, – chapter 4; chapter 5 (co-authored with E. M. Khakimov); chapter 6 (co-authored with S.V. Korneychuk, E.M. Khakimov); chapter 9; chapter 10 (co-authored with B.E. Shaimerdenov, V.V. Filin); chapter 33 (co-authored with Zhusipbekova A.M.); chapter 36 (co-authored with Shaimerdenov B.E.); chapter 39 (co-authored with Zhusipbekova A.M.);
Smyshlyaev Alexander Sergeevich, PhD. – chapters 38, 40, 42, 43-1 (co-authored with A.S. Tukiev); chapter 44;
Aslan Sultanovich Tukiev - Candidate of Law, Associate Professor – chapters 1, 3, 35; chapters 38, 40, 42, (co-authored with A.S. Smyshlyaev); chapter 43 (co-authored with B.A. Parmankulova); chapter 43-1 (co-authored with A.S. Smyshlyaev); chapter 44-1 (co-authored with Shipp D.A.); chapter 45; 46 (co-authored with Shipp D.A.); chapter 47;
Filin Vladimir Vladimirovich, Candidate of Law, Associate Professor – Chapter 10 (in collaboration with O.T. Seitzhanov, B.E. Shaimerdenov);
Yerzhan Maratovich Khakimov, M.yu.n. – chapter 5 (co-authored with O.T. Seitzhanov); chapter 6 (co-authored with O.T. Seitzhanov, S.V. Korneychuk); chapter 7; chapter 25 (co-authored with S.V. Korneychuk); chapters 34, 41; chapter 48 (co-authored with S.N. Bachurin); chapter 53;
Shaimerdenov Bolat Yerkenovich, M.yu.n., – chapter 10 (co-authored with O.T. Seitzhanov, V.V. Filin); chapter 12; articles 476-487, 507-509; chapter 36 (co-authored with O.T. Seitzhanov); chapters 37, 50, 51.
Shipp Denis Alekseevich – chapters 44-1, 46 (in collaboration with A.S. Tukiev).
Date of amendment of the act: 01.01.2020 Date of adoption of the act: 01.01.2020 Place of acceptance: 100050000000 Authority that adopted the act: 103001000000 Region of operation: 100000000000 NPA registration number assigned by the regulatory body: 5 Status of the act: new Sphere of legal relations: 029000000000 / 028000000000 / 029002000000 / 028004000000 / 029001000000 / 026000000000 / 001000000000 / 001008000000 / 030000000000 The form of the act: COMM / CODE Legal force: 1900 Language of the Act: rus
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