Pakistan’s Water Regulator

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Arshad Mahmood Awan

Pakistan’s water management system is entering a critical phase, and the body entrusted with managing it is already broken. The Indus River System Authority’s Advisory Committee was scheduled to meet on April 7 to determine water availability for the Kharif season. Farmers across the country, particularly in Sindh, were watching closely. The decisions made in that meeting would shape what flows into their fields for months. Yet before a single figure was placed on the table, the meeting was already compromised. The committee convened without its full legal membership, raising a question that no technical briefing or reservoir report can answer: how can a body lacking its own required composition be trusted to fairly distribute a resource over which wars have been fought?

The problem is not complicated to explain, even if it is complicated to fix. IRSA’s Advisory Committee is legally required to include a regular member from Sindh and a federal member who is domiciled in Sindh. At the time of the April meeting, neither seat was properly filled. Sindh’s nominee remained pending without any clear timeline or explanation from the provincial government. The federal government, meanwhile, had not appointed a Sindh-domiciled federal member. Both omissions are not clerical oversights. They represent a direct violation of the authority’s foundational legal requirements, the same requirements that give its decisions binding force.

When the law specifies how a regulatory body must be composed, that is not a suggestion. It is a condition. Regulatory decisions carry weight precisely because they are made through a defined process, by a defined body, operating within a defined legal framework. Strip away any of those elements and what remains is not regulation, it is improvisation dressed up in institutional clothing. Pakistan’s farmers, already navigating unpredictable rains, mounting debts, and rising input costs, deserve better than improvisation when it comes to the water they depend upon.

What makes this situation worse is that it is not new. The position of federal member from Sindh has, for all practical purposes, been unfilled for sixteen years. During that period, officers from other provinces were placed in that role, in open deviation from what the law requires. Sixteen years. That span covers multiple governments, multiple IRSA chairmanships, and multiple Kharif and Rabi seasons where the same gap persisted. At some point, what begins as an administrative lapse calcifies into institutional culture. Rules that are ignored consistently enough stop feeling like rules at all. And when that happens, the authority itself stops feeling legitimate to those it is supposed to serve.

Sindh has historically been the most sensitive province in Pakistan when it comes to water allocation. Its downstream position on the Indus system means it receives whatever is left after upstream demands are met. Its agriculture, economy, and rural livelihoods are overwhelmingly dependent on timely and adequate water releases. Any perception that Sindh is being marginalised, whether in the fields or in the boardroom, lands with political force. Holding an allocation meeting for a season critical to Sindh without a proper Sindh representative is not just a procedural failure. It is a political provocation, even if unintentional.

The current Kharif cycle adds further pressure. Early assessments suggest that reservoir carryover levels, particularly at Tarbela, are lower than needed to fully meet Sindh’s demand for early Kharif water. That means there will already be difficult conversations about who gets how much and when. In those conversations, every province will scrutinise the process just as much as the outcome. A Sindh representative’s absence from the table does not just affect the decision. It affects the willingness to accept the decision, and in a system already strained by decades of interprovincial water disputes, the difference between acceptance and rejection can translate very quickly into political crisis.

The complications do not stop there. The outgoing Sindh member, whose resignation had not been formally accepted at the time of the meeting, was expected to attend while simultaneously serving in the Sindh provincial government. This kind of dual role does not just create an appearance of conflict. It actively blurs the line between the regulatory and executive functions, between the body meant to arbitrate and the party with a direct stake in the outcome. Regulatory credibility depends on distance from the very interests being regulated. That distance has collapsed here.

There is also active litigation over previous appointments. Courts have already taken note of the structural irregularities in IRSA’s composition, and legal challenges have highlighted just how fragile the current arrangements are. Proceeding with a meeting of questionable composition, in the face of both judicial scrutiny and public concern, suggests an institutional indifference to procedural integrity that is difficult to justify at any level.

Pakistan’s infrastructure narrative around water has been relatively active. There is talk of better measurement systems, increased storage, and efficiency improvements. These are real needs and, where implemented, real improvements. But technical progress cannot substitute for institutional legitimacy. You can build a hundred new canals and install the most precise monitoring equipment available. If the body making allocation decisions is not trusted, those allocations will be contested. Data does not resolve disputes between provinces. Credible institutions do.

The broader picture is one of a system under compounding pressure. Climate change is altering river flows. Population growth is increasing demand. Agricultural inefficiency is deepening waste. Against these pressures, governance failures are not secondary concerns. They are multipliers. Every institutional weakness turns a manageable technical challenge into an unmanageable political one. Every unfilled seat at a regulatory table becomes a grievance. Every grievance becomes a dispute. Every dispute slows down the decisions that need to be made faster as conditions become more difficult.

The solution here is not complicated to describe. The Sindh nominee must be processed and confirmed without delay. The federal government must appoint a Sindh-domiciled member in accordance with the law. Dual roles that compromise institutional integrity must be ended. And any allocation decisions taken during this gap in legal composition must be understood for what they are: provisional at best, and vulnerable at worst.

Water scarcity in Pakistan is real. But governance failure is equally real, and in some ways more dangerous, because it is preventable. Fixing it requires nothing more than the political will to follow the law that already exists.

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