“PEDAGOGS”
international research journal ISSN:
2181-4027
_SJIF:
4.995
https://scientific-jl.com/ped
Volume-79, Issue-1, April -2025
151
COMPARATIVE ANALYSIS OF LEGISLATION ON CITIZEN
PARTICIPATION IN PUBLIC ORDER PROTECTION AND PUBLIC
SAFETY: THE EXPERIENCE OF KAZAKHSTAN, RUSSIA,
BELARUS, AND TAJIKISTAN
Urazbaev Abatbay Askerbaevich
The Education Centre for Special Training, Department for the
Coordination of Special Operations of the Ministry of Internal Affairs
of the Republic of Uzbekistan, Tashkent, Uzbekistan
Abstract
This study provides a comparative analysis of legislative frameworks governing
citizen participation in public order protection and safety in Kazakhstan, Russia,
Belarus, and Tajikistan. Rooted in the Soviet tradition of voluntary people’s patrols, or
"druzhinas," these nations have adapted their systems to address modern challenges,
balancing state coordination with civic initiative. By examining Kazakhstan’s Law No.
590 of 2004, Russia’s Federal Law No. 44-FZ of 2014, Belarus’s Law No. 214-Z of
2003, and Tajikistan’s Law No. 1969 of 2023, this paper explores the general principles
guiding participation, the rights and duties of participants, the strengths and
weaknesses of each system, and their legislative similarities and differences. Drawing
on legal texts, official reports, and academic studies, the analysis highlights best
practices – such as Russia’s regional adaptability, Kazakhstan’s focus on prevention,
Belarus’s structured coordination, and Tajikistan’s culturally rooted councils – offering
insights for mutual learning and enhanced collaboration within the Eurasian Economic
Union (EAES) and Collective Security Treaty Organization (CSTO) frameworks.
Keywords
: citizen participation, public order, public safety, legislation,
Kazakhstan, Russia, Belarus, Tajikistan, comparative analysis, Soviet legacy, best
practices, CSTO.
Introduction
Over the past two decades, Kazakhstan, Russia, Belarus, and Tajikistan have
made remarkable progress in modernizing their public safety systems, creatively
adapting historical practices to meet contemporary demands. These countries,
inheritors of the Soviet tradition of voluntary people’s patrols – known as "druzhinas"
– have developed legislative frameworks that reflect both a shared heritage and distinct
national innovations. The Soviet model of citizen participation, formalized by the
Council of Ministers’ Decree No. 731 on March 2, 1959, was a pioneering effort to
engage communities in maintaining order, a practice that historian Yoram Gorlizki
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international research journal ISSN:
2181-4027
_SJIF:
4.995
https://scientific-jl.com/ped
Volume-79, Issue-1, April -2025
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describes as a unique blend of state oversight and grassroots mobilization [1]. By the
1960s, over 2.5 million Soviet citizens were involved in druzhinas, assisting the militia
with street patrols, petty crime prevention, and even anti-hooliganism campaigns,
forming a critical component of the social fabric of the time.
Following the dissolution of the USSR in 1991, these nations faced the complex
task of reimagining this system in the face of new realities: rapid urbanization,
economic transitions, and shifting security threats. Kazakhstan, Russia, Belarus, and
Tajikistan each responded with approaches that, while diverse, share a common goal –
ensuring the safety and stability of their citizens. Kazakhstan’s Law No. 590, enacted
on July 9, 2004, and published in
Ведомости Парламента Республики Казахстан
,
2004 г., № 18, ст. 104, and
Казахстанская правда
от 17 июля 2004 года № 161,
emphasizes prevention, a cautious approach shaped by the social and economic
turbulence of the 1990s [2]. Russia’s Federal Law No. 44-FZ, adopted on April 2, 2014,
and published in
Rossiyskaya Gazeta
No. 76, prioritizes flexibility, a necessity for a
country with vast territorial and demographic diversity [3]. Belarus’s Law No. 214-Z,
passed on June 26, 2003, and registered in the National Register of Legal Acts No.
2/964, integrates druzhinas into a state-led framework, ensuring systemic stability
through close coordination with the militia [4]. Tajikistan’s Law No. 1969, enacted on
June 22, 2023, and published in
Akhbori Majlisi Oli
No. 12, leverages traditions of
collective responsibility – rooted in pre-Soviet communal practices – to foster
innovative forms of participation through public councils [5].
The evolution of these systems has not been without challenges. In Kazakhstan,
early attempts to revive druzhinas in the 1990s were hampered by insufficient funding
and low citizen motivation, issues addressed only with the 2004 law [2]. For instance,
in Almaty during the mid-1990s, informal groups struggled to coordinate with police
due to a lack of legal clarity, leading to sporadic effectiveness until Law No. 590
formalized their role as preventive auxiliaries. In Russia, the transitional period saw
chaotic, localized initiatives – such as Moscow’s ad hoc patrols in the early 2000s –
until the 2014 federal law standardized their roles, introducing mandatory training and
unifying their efforts under a national framework [3]. Belarus maintained continuity
with the Soviet model, gradually enhancing it with social guarantees in the 2010s, such
as insurance and compensation for injuries, which boosted participation to over 15,000
druzhinniks by 2022 [6]. Tajikistan, emerging from a civil war (1992–1997), relied on
informal community structures – like village councils in Gorno-Badakhshan – to
maintain order until Law No. 1969 formalized them in 2023, marking a significant shift
toward institutionalization [5].
Today, these legislative efforts illustrate a dynamic balance between state
coordination and civic initiative, offering a rich field for mutual learning and
collaboration within regional frameworks like the EAES and CSTO. Kazakhstan’s
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focus on prevention has proven effective in rural areas, where citizens’ rapid
notifications have cut police response times, as seen in Aktobe’s 2022 data showing a
10% drop in rural petty crimes [7]. Russia’s flexibility allows druzhinniks to tailor their
efforts to local needs – urban patrols in St. Petersburg contrast with rural support in
Siberia – resulting in a nationwide force of 80,000 volunteers by 2023 [8]. Belarus’s
state-led approach ensures consistency, with joint militia-druzhina patrols during
Minsk’s 2022 Independence Day reducing violations by 30% [6]. Tajikistan’s council-
based model stabilizes remote regions, with Gorno-Badakhshan councils resolving
over 50 disputes in 2023, enhancing trust in local governance [9]. Comparative studies
suggest that such community engagement significantly enhances public trust in law
enforcement across post-Soviet states [14].
This comparative analysis examines these frameworks through multiple lenses:
the general principles guiding citizen involvement, the rights and duties of participants,
the strengths and weaknesses of each system, and the legislative similarities and
differences. Drawing on primary legal texts, official reports from ministries of internal
affairs, academic studies, and archival materials, the study aims not to critique but to
highlight best practices that enhance public security. The Soviet legacy provides a
common thread, yet each country’s adaptation reflects its unique socio-political context
– Kazakhstan’s post-independence stabilization, Russia’s regional diversity, Belarus’s
centralized governance, and Tajikistan’s post-conflict recovery. Examples such as
Russia’s 80,000 active druzhinniks and Tajikistan’s rural councils stabilizing remote
areas underscore the practical impact of these systems, making their experience a
valuable resource for regional and international study. This analysis not only celebrates
their achievements but also proposes pathways for collaboration, potentially elevating
their models as exemplars within the global discourse on civic engagement in public
safety.
General Principles of Citizen Participation
The principles of voluntariness, legality, and cooperation with state authorities
provide a unifying foundation for citizen participation in public order protection across
Kazakhstan, Russia, Belarus, and Tajikistan. These principles, inherited from the
Soviet tradition of voluntary people’s patrols, or "druzhinas," have been adapted to
align with contemporary legal and social standards, reflecting each country’s unique
historical and cultural context [1]. While rooted in a shared past, their evolution
demonstrates a commitment to balancing civic initiative with state oversight, ensuring
that participation enhances public safety without compromising order or rights.
In Russia, Federal Law No. 44-FZ, published in
Rossiyskaya Gazeta
No. 76 on
April 4, 2014, embodies these principles by integrating druzhina efforts with
professional policing while emphasizing respect for human rights [3]. The law’s
preamble underscores the voluntary nature of participation, granting citizens the right
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to opt into this role, while Article 9 mandates strict adherence to legal norms, reinforced
by compulsory training and coordination with law enforcement. Interior Minister
Vladimir Kolokoltsev highlighted their impact in 2023, stating, "The contribution of
people’s patrols to maintaining law and order is invaluable," with over 80,000
druzhinniks active nationwide – a testament to the principle of voluntariness driving
widespread engagement [8]. This framework evolved from the chaotic post-Soviet
1990s, when local initiatives lacked uniformity, to a standardized system post-2014,
ensuring legality through structured oversight [10].
Kazakhstan’s Law No. 590, published in
Ведомости Парламента Республики
Казахстан
, 2004 г., № 18, ст. 104, and
Казахстанская правда
от 17 июля 2004
года № 161, prioritizes prevention as a core principle, articulated in Article 5, which
tasks citizens with "warning against offenses" [2]. This focus emerged as a response to
the 1990s, when informal vigilantism – such as spontaneous citizen groups in Almaty
addressing petty theft – risked escalating tensions, prompting a legislative shift toward
cooperation with police rather than independent action [11]. In practice, this means
citizens primarily notify authorities, as seen in Kostanay Region, where druzhinniks’
reports in 2022 reduced rural vandalism by 12% by enabling swift police responses [7].
The principle of legality is reinforced by Article 7, requiring participants to act within
the law, a cautious approach reflecting Kazakhstan’s emphasis on stability during its
post-independence transition.
Belarus’s Law No. 214-Z, registered in the National Register of Legal Acts No.
2/964 in 2003, highlights humanitarianism and transparency as guiding principles, with
Article 3 stating that druzhina activities should "strengthen public morality" [4].
Cooperation with state bodies is mandatory, reflecting Belarus’s centralized
governance model, and is supported by a robust framework of state oversight. This
principle has been enhanced since the 2010s with social guarantees – such as insurance
and injury compensation under Articles 20-21 – boosting participation to over 15,000
druzhinniks by 2022 [6]. In Minsk, this cooperation shone during the 2022
Independence Day celebrations, where joint patrols with militia reduced public
violations by 30%, illustrating how voluntariness paired with state support enhances
effectiveness [6]. Scholars note that such incentives align with broader trends in post-
Soviet governance [15].
Tajikistan’s Law No. 1969, published in
Akhbori Majlisi Oli
No. 12 on June 25,
2023, intertwines voluntariness with patriotism, a principle deeply rooted in national
traditions of collective responsibility that predate Soviet influence [5]. The 2023
Ministry of Internal Affairs report notes that public councils serve as "a bridge between
the state and the people," formalizing previously informal structures that emerged post-
civil war (1992–1997) [9]. In Gorno-Badakhshan, these councils resolved over 50
disputes in 2023, leveraging cultural motivations to stabilize remote areas where state
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presence is limited [9]. This shift from ad hoc efforts to a legislated system underscores
legality, with Article 4 requiring council actions to align with national laws, marking a
significant step toward institutionalization.
The evolution of these principles reflects each country’s response to its post-
Soviet challenges. In Russia, pre-2014 druzhinas operated under fragmented local
regulations – such as Moscow’s informal patrols in the 2000s – until Federal Law No.
44-FZ introduced mandatory training and unified powers, enhancing consistency [10].
Kazakhstan’s early legislation, like a 1993 Supreme Council decree, was vague, with
Law No. 590 clarifying roles as police auxiliaries, reducing risks of overreach seen in
the 1990s [11]. Belarus preserved Soviet continuity, modernizing it with incentives like
insurance in 2015 [12], while Tajikistan’s formalization in 2023 built on decades of
informal community efforts, such as village patrols in Sughd Region that curbed
livestock theft by 10% in the early 2000s [9]. These adaptations illustrate a shared
commitment to refining a Soviet legacy into a tool for modern governance, as
evidenced by regional security analyses [16].
Examples further illuminate these principles in action. Russia’s nationwide
coordination enabled druzhinniks to support urban policing in St. Petersburg, cutting
pickpocketing by 20% in 2023, and rural efforts in Yakutia, reducing alcohol-related
incidents by 12% [8]. Kazakhstan’s preventive focus in Aktobe shortened rural crime
response times by 15 minutes in 2022, enhancing safety [7]. Belarus’s mandatory
training improved druzhina efficacy in Gomel, where 50 mass events in 2022 saw a
25% drop in petty crimes [6]. Tajikistan’s councils in Rudaki prevented 30 livestock
thefts in 2023, fostering trust in local governance [9]. Together, these cases show how
voluntariness, legality, and cooperation adapt to diverse national needs, offering a
foundation for mutual learning.
Rights and Duties of Citizens
The rights and duties of citizens in Kazakhstan, Russia, Belarus, and Tajikistan
under their respective legislative frameworks not only define their roles in public order
protection but also reflect national priorities in balancing civic engagement with state
authority. In Russia, Article 17 of Federal Law No. 44-FZ grants druzhinniks
significant rights: they can demand compliance with public order, secure crime scenes,
and use limited physical force, provided actions align with legal limits [3]. Their duties
include undergoing training, adhering strictly to laws, and assisting those in distress.
In Krasnodar Krai, druzhinniks prevented over 50 thefts at agricultural fairs in 2022 by
securing perimeters and alerting police [8]. However, training inconsistencies
undermine preparedness, as seen in Omsk, where poorly trained druzhinniks struggled
to manage a 2022 crowd disturbance [8].
Kazakhstan’s Law No. 590 empowers citizens to prevent offenses and notify
police, with rights focused on observation and reporting rather than direct intervention
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[2]. In Turkestan Region, druzhinniks stopped 80 illegal forest cuttings in 2022 by
reporting suspicious activities [7]. Yet, their limited powers hindered action in
Kyzylorda in 2021, where they couldn’t stop violators, prompting calls for expanded
authority [7]. Belarus’s Article 17 of Law No. 214-Z allows druzhinniks to detain
offenders under strict state guidance, with duties including regular training and detailed
reporting [4]. In Mogilev, they bolstered industrial security in 2022, cutting equipment
thefts by 25% [6]. However, over-reliance on militia instructions delayed action in
Grodno in 2021 [6]. Tajikistan’s Law No. 1969 frames participation as a patriotic duty,
granting citizens rights to join public councils and report violations [5]. In Rudaki
District, councils prevented 30 livestock thefts in 2023 [9], though informal structures
limit consistency in mountainous areas [9].
Strengths and Weaknesses
Russia’s model excels in adaptability, with St. Petersburg patrols reducing
pickpocketing by 20% in 2023, but uneven training and funding weaken its impact in
regions like Kalmykia [8]. Kazakhstan’s preventive orientation shines in Pavlodar,
preventing 90 illegal hunts in 2023, yet its cautious approach falters in urban settings
like Uralsk [7]. Belarus’s systematic coordination secures Vitebsk cargo by 22% in
2023, but heavy reliance on militia limits initiative, as in Borisov [6]. Tajikistan’s
cultural foundation stabilizes Isfara with a 15% accident drop in 2023, but lack of
formalization hampers consistency in Gorno-Badakhshan [9]. These strengths and
weaknesses suggest refinement opportunities: Russia needs uniform training,
Kazakhstan broader powers, Belarus more autonomy, and Tajikistan consistent
structures, as supported by regional policy reviews [17].
Similarities and Differences
A primary similarity lies in their Soviet origin, emphasizing voluntariness,
legality, and cooperation [1]. Russia’s 80,000 druzhinniks, Kazakhstan’s rural
informants, Belarus’s 15,000 volunteers, and Tajikistan’s councils operate under state
oversight [8, 7, 6, 9]. Differences emerge in autonomy: Russia and Kazakhstan
prioritize efficacy, while Belarus and Tajikistan emphasize cohesion [3, 2, 4, 5].
Russia’s flexibility suits Moscow’s 18% metro violation cut, Kazakhstan’s prevention
excels in Aktobe’s 10% drop, Belarus’s coordination shines in Gomel’s 25% reduction,
and Tajikistan’s councils thrive in Sughd’s 25 dispute resolutions [8, 7, 6, 9]. These
contrasts offer mutual learning potential within EAES and CSTO frameworks, as noted
in integration studies [18].
Conclusion
The legislative frameworks of Kazakhstan, Russia, Belarus, and Tajikistan blend
Soviet tradition with modern innovation, yielding tangible safety gains: Russia’s 20%
urban reductions, Kazakhstan’s 10% rural drops, Belarus’s 22% cargo security, and
Tajikistan’s 15% accident declines [8, 7, 6, 9]. Weaknesses – training gaps, limited
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powers, rigidity, and informality – invite collaboration. A regional platform could
harness Russia’s flexibility, Kazakhstan’s caution, Belarus’s structure, and Tajikistan’s
tradition, enhancing stability and offering a global model for civic safety integration.
The positive experience of Belarus in engaging citizens, as highlighted by Urazbaev,
underscores the value of structured coordination and social incentives, providing a
benchmark for others [13]. Historical analyses further affirm that such systems
strengthen societal resilience across diverse contexts [14, 15, 16, 17, 18].
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