الحصانة، الموظف العام، الفساد، القانون العراقي، القانون المصري، القانون الإيراني.

Abstract

This research offers a comparative analytical study of the consequences of public employee immunity in the face of anti-corruption efforts under Iraqi, Egyptian, and Iranian law. It aims to reveal the extent to which legal immunity impacts the effectiveness of integrity and accountability systems in these countries' administrative systems. The importance of the research lies in highlighting the critical balance between protecting employees in the performance of their duties and preventing immunity from becoming a means of impunity, especially in light of the escalating corruption cases in public institutions. The research adopts a comparative, descriptive, and analytical approach by examining national legal texts and analyzing relevant judicial applications, comparing similarities and differences in the legal regulation of immunity. The research reaches a number of conclusions, most notably that immunity in its current form may contribute to obstructing the accountability of corrupt individuals, delaying investigations, and perpetuating a culture of inequality before the law. Furthermore, the weakness of immunity-lifting mechanisms gives immunized employees the opportunity to influence the course of justice. Accordingly, the study recommended the need to review legislation related to immunity by codifying it and clearly defining its scope, activating mechanisms for lifting it within specific timeframes, enhancing the independence of oversight bodies, and emphasizing the need to spread legal awareness of the risks of excessive immunity, thus achieving a balance between protecting public office and ensuring accountability for those who misuse it.