Commentary on Article 24. Preparation for a Crime and Attempted Crime under the Criminal Code of the Republic of Kazakhstan
Preparation for a crime shall mean the deliberate seeking, making or adaptation of means or instruments of a crime, seeking accomplices to a crime, conspiracy to commit a crime, or any other deliberate creation of conditions for the commission of a crime, provided that the crime was not completed due to circumstances beyond the person's control.
Criminal liability shall arise for preparation for a serious or particularly serious crime, as well as for preparation for a terrorist crime.
An attempt to commit a crime shall mean actions (inaction) committed with direct intent and directly aimed at committing a crime, provided that the crime was not completed due to circumstances beyond the person's control.
Criminal liability shall arise for an attempt to commit a medium-gravity, serious or particularly serious crime, as well as for an attempt to commit a terrorist crime.
Liability for preparation for a crime and attempted crime shall arise under the same Article of this Code that provides for liability for the completed crime, with reference to the relevant part of that Article.
The basis for criminal liability is the commission of a criminal offence, that is, an act containing all the elements of the corpus delicti of a crime or a criminal misdemeanor provided for by the Criminal Code (Article 4 of the Criminal Code). At the same time, the criminal-law assessment of the criminal offence committed does not depend on its duration in time and space.
At the same time, in reality, it often happens that, when a crime is committed, a more or less significant period of time passes between the emergence of criminal intent and its practical implementation. During this period, the criminal objective formed in the consciousness of the perpetrator is achieved in stages. In such cases, the execution of the objective elements of the crime is usually preceded by a conscious and volitional process of modelling future criminal conduct, which is referred to as the formation of intent. This process encompasses setting a goal and determining the means of achieving it, choosing methods of committing and concealing the crime, considering the possibilities of involving accomplices in the crime, and so forth.
The formed criminal intention and determination to achieve the desired result are embodied in the creation of conditions that facilitate the implementation of the planned act. Thus, in order to steal a vehicle, such conditions may be created by selecting in advance tools for breaking the alarm system, collecting the necessary information, and so forth. These and other similar actions are followed by the stage of committing a specific crime (the execution of its objective elements), as a result of which harm is caused to social relations (interests) protected by criminal law.
In criminal law, the stages of criminal activity are referred to as the stages of committing a crime. The Criminal Code classifies preparation for a crime, attempted crime and completed crime as such stages.
The criminal law does not disclose the concept of the stages of committing a criminal offence. At the same time, the provisions of the current Criminal Code of the Republic of Kazakhstan define certain stages of committing a criminal offence through the legal characteristics of preparation for a crime and attempted crime, a completed criminal offence, and voluntary abandonment of a criminal offence.
According to the legislator's intention, within the system of distinguished stages of committing a criminal offence, the institutions of preparation for a crime and attempted crime are designed to address issues of liability only for intentional socially dangerous acts classified as crimes. The concepts of a completed criminal offence and voluntary abandonment of a criminal offence, however, apply to the characteristics of both crimes and criminal misdemeanors. Consequently, when analysing the stages of committing criminally punishable acts, it is necessary to take into account the specific nature of the regulation of these relations, which consists in differentiating the stages applicable to intentional crimes from those applicable to other criminal offences. The stages of committing a crime should be understood as the stages in the development of an intentional crime provided for by criminal law, which differ in the degree to which intent has been implemented and in the degree of public danger.
Regardless of the stage of development at which an act provided for by criminal law is situated, it falls within the concept of a crime. However, it is quite obvious that, from the perspective of public danger, the later stages in the development of criminal activity pose a greater danger.
It is important to note that the institution of preliminary criminal activity, as before, applies only to crimes. Criminal misdemeanors, due to their low degree of danger and the insignificance of their socially harmful consequences, do not constitute what is known as a criminal-law reproach at the early (preliminary) stages of their commission and, accordingly, do not entail criminal liability.
Whereas in a completed crime the perpetrator's intent is fully realised in the actions committed and their consequences, in preparation and attempted crime there is no such full realisation of intent.
The Criminal Code of the Republic of Kazakhstan has clearly distinguished preparation and attempted crime as two stages of criminal activity and provided a detailed definition of each of these stages (Parts 1 and 3 of Article 24 of the Criminal Code). Article 25 of the Criminal Code defines a completed crime.
The stages of preparation and attempted crime (unlike a completed crime) are generally grouped under the term preliminary criminal activity.
The criminal legislation of the Republic of Kazakhstan proceeds from the premise that, in cases where an unlawful act is in the process of being carried out, it is also substantially dangerous and criminal.
Before beginning intentional criminal activity, a person forms an idea of the nature and result of the crime. This determines the method and nature of their activity aimed at implementing criminal intent. However, the process of contemplating the forthcoming crime is an internal process taking place in the person's psyche. It remains unknown to others until it manifests itself externally through certain actions.
The formation of criminal intent cannot be regarded as a stage in the development of criminal activity. Such a position is not based on the current criminal legislation. Under the current criminal legislation, criminal thoughts, moods, and even an intention to commit a crime, even if expressed in one form or another and made known to outsiders (the so-called manifestation of intent), do not in themselves entail criminal liability.
The correct determination of the stages of committing an intentional crime is of great importance in the activities of law enforcement agencies for distinguishing a completed crime from an incomplete one and, consequently, for the proper legal classification of the act, as well as for determining the degree of public danger of the actions committed and the personality of the perpetrator, since a completed crime is usually more dangerous than an attempted crime, and an attempted crime is more dangerous than preparation. Furthermore, establishing the specific stage enables the court to individualise the punishment imposed on the perpetrator in accordance with the law.
In accordance with Part 1 of Article 24 of the Criminal Code, preparation for a crime shall mean the deliberate seeking, making or adaptation of means or instruments of a crime, seeking accomplices to a crime, conspiracy to commit a crime, or any other deliberate creation of conditions for the commission of a crime, provided that the crime was not completed due to circumstances beyond the person's control.
Preparation should be understood as any deliberate activity aimed at creating conditions for the commission of a crime. For example, acquiring a weapon for murder, examining a location where it is possible to enter a building in order to commit theft, seeking accomplices to a crime, making a printing plate for producing counterfeit money, and so forth.
Preparatory actions do not yet directly endanger social relations protected by law; they merely create conditions that make it possible to achieve a criminal result in the future. Preparation is the first stage in the implementation of a person's criminal intent.
Cases in which a person intends to commit not a specific crime, but a crime "in general", "sometime", or "some kind of crime", and undertakes preparatory actions, cannot be regarded as preparation for a crime. It should be borne in mind that the law does not prosecute abstract preparatory activity in general, but rather preparation for the commission of a specific serious or particularly serious crime, which is determined by the specific object of the infringement. Therefore, if there is no object of infringement, there can be no crime itself. It is precisely a person's desire to cause harm to a particular object that gives rise to a criminal act. Since this object is specially protected by law, preparation for the commission of a completed crime already constitutes a socially dangerous act.
An analysis of law enforcement practice shows that, in the course of an infringement during preparation, the perpetrator may immediately threaten two objects where the nature of such activity simultaneously constitutes another completed crime. For example, for the purpose of committing a robbery, a person illegally acquires a weapon. In this case, the act should be classified as a concurrence of offences: illegal acquisition, transfer, sale, possession, transportation or carrying of weapons, ammunition, explosives and explosive devices (Article 287 of the Criminal Code), or theft or extortion of weapons, ammunition, explosives and explosive devices (Article 291 of the Criminal Code), and preparation for the commission of robbery (Article 192 of the Criminal Code).
During preparation, there is no infringement upon the object itself; rather, conditions are merely created for such an infringement. When preparing for a crime, a person realises that these actions create conditions for committing the crime that they intend to commit. It should be borne in mind that, when carrying out preparatory actions, the perpetrator's intent encompasses awareness and desire to commit the crime they intend to commit by means of these preparatory instruments or tools. It is precisely the establishment of the direction of intent towards committing a crime that may be decisive in distinguishing criminal activity from non-criminal activity.
Preparation is characterised by intentional guilt, and the intent may only be direct, which follows directly from the content of Part 1 of Article 24 of the Criminal Code. Since preparatory activity is always aimed at creating conditions for a subsequent direct infringement, it is impossible in cases of indirect intent.
As follows from the content of Part 1 of Article 24 of the Criminal Code, from the objective standpoint, preparation is expressed in the commission of one of the following actions:
seeking, making or adaptation of means or instruments of a crime;
seeking accomplices to a crime;
conspiracy to commit a crime;
other creation of conditions for the commission of a crime.
Seeking should be understood as any method of acquiring instruments or means of committing a crime. The method of acquisition may be either lawful or unlawful (for example, purchasing, temporarily obtaining or acquiring weapons and other instruments and means of committing a crime through theft, and so forth). Seeking also includes finding and appropriating an item for such purposes. Seeking also includes preparing household items owned by the perpetrator for such use.
Instruments of committing a crime include firearms or bladed weapons, as well as objects that may be used for the intended crime.
Means of committing a crime may include various objects and devices used to facilitate the commission of a crime (forged documents, seals, poisonous substances, sleeping agents, and so forth).
The main difference between means and instruments is that an instrument is used in the process of directly committing a crime, whereas a means is used at the stage of creating conditions for committing a crime in order to facilitate its implementation.
In different situations, the same object may serve as both an instrument and a means of committing a crime. For example, a rope may serve as an instrument of murder, but it may also serve as a means of suppressing a victim's resistance during kidnapping. This provides grounds for the conclusion that the principal distinction between an instrument and a means of committing a crime lies in their intended purpose. An instrument of committing a crime is an object used to directly perform the objective elements of the crime. A means of committing a crime is intended to facilitate its commission and assist in carrying out the criminal act.
Making means any actions as a result of which ready-to-use instruments and means of committing a crime are obtained. Unlike adaptation, in this case these means and instruments are created anew.
Adaptation of instruments and means of committing a crime should be understood as bringing them into such a form and condition that they can be used to commit a crime (for example, sharpening metal objects for the purpose of committing murder, preparing keys, and so forth).
Seeking accomplices to a crime consists of any actions related to selecting and searching for other persons to commit a crime. Seeking minors as accomplices to a crime constitutes both preparation for the intended crime and a completed crime — involving a minor in the commission of a criminal offence (Article 132 of the Criminal Code).
Conspiracy to commit a crime is characterised by a prior arrangement or agreement to commit a crime jointly.
Conspiracy differs from seeking accomplices in that it involves a mutual agreement between persons to commit a specific crime. In certain cases, conspiracy may constitute not preparation for the commission of a crime, but the elements of an independent completed crime, for example, an armed rebellion, as well as the seizure and retention of power (Part 1 of Article 181 of the Criminal Code).
Other creation of conditions for the commission of a crime should be understood as various actions that are not covered by the above-mentioned types of preparatory actions but create the possibility of subsequently committing a crime.
For example, the creation of conditions includes examining the location of the intended crime (inspecting the approach or entrance to a guarded facility targeted for theft, studying the guard rotation system, and so forth), removing obstacles that may prevent the commission of the crime (killing a dog, damaging electrical appliances), and so forth.
Although preparatory actions may be very diverse, they all have common features, in particular, they all precede the commission of a crime.
Since preparation for a crime consists only in creating conditions for its subsequent commission, this stage of the crime represents the lowest degree of public danger compared with other stages. In some cases, this degree is so low that the act does not reach the level characteristic of a crime. Therefore, criminal liability arises only for preparation for a serious or particularly serious crime, as well as for preparation for a terrorist crime (Part 2 of Article 24 of the Criminal Code). The inclusion of terrorist crimes in this list is a new development introduced by the Criminal Code of 2014. Although most terrorist crimes fall into the categories of serious and particularly serious crimes, the legislator nevertheless singled them out as a separate group. This is primarily due to the high relevance of the problem of combating terrorism and the recognition of terrorism as one of the principal threats of our time.
The same actions may, under different circumstances, be regarded either as preparation or as attempted crime. For example, a thief's entry into a victim's apartment should be regarded as an attempt to commit theft (Part 3 of Article 24, paragraph 3) of Part 2 of Article 188 of the Criminal Code), whereas a criminal's entry into an apartment for the purpose of committing murder should be classified as preparation for murder (Part 1 of Article 24, Part 1 of Article 99 of the Criminal Code).
At the same time, actions constituting the objective elements of preparation may also fall under the characteristics of an independent crime. Thus, if a person forged an official document but, due to circumstances beyond their control, did not actually use that document, the act should be classified under Part 1 of Article 385 of the Criminal Code. The act should be classified in accordance with Part 1 of Article 24 of the Criminal Code as preparation for fraud if the circumstances of the case indicate that the person's intent encompassed the use of a forged document to commit crimes provided for by Parts 3 or 4 of Article 190 of the Criminal Code.
Concluding the examination of the stage of preparation for the commission of a crime, I would like to draw attention to the following.
In Russian criminal-law literature of the nineteenth century, preparation for the commission of a crime was classified sometimes as the manifestation of intent and sometimes as an attempt.
There was no unity of views among scholars regarding the punishability of preparation during the theoretical development of the Fundamentals of Criminal Legislation of the USSR and the Union Republics of 1958. Some argued that liability should be imposed for preparation for any crime (A.N. Trainin). Others insisted that preparation should be excluded from the General Part of the Criminal Code, deprived of its status as an independent stage of committing a crime, and that the punishability of preliminary criminal activity should instead be provided for in the articles of the Special Part of the Criminal Code containing provisions on liability for particularly serious crimes (M.A. Cheltsov). A third group advocated retaining the criminal-law significance of preparation as an independent stage of an incomplete crime and regulating it in the provisions of the General Part of the Criminal Code; however, they considered it necessary to restrict liability for preparation by establishing, through legislation, a list of crimes for which preparation would be punishable (N.D. Durmanov, A.A. Piontkovsky). The first of the above-mentioned scientific positions was implemented in the Fundamentals of Criminal Legislation of 1958 and subsequently in the Criminal Code of the Kazakh SSR of 1959. However, this did not mean that scientific discussions had ceased. Scholars continued to raise the issue of abolishing liability for preparation due to its low degree of public danger and limited practical significance (T.D. Ustinova, I.S. Tishkevich).
And finally, in the science of criminal law, preparation is divided into completed and incomplete preparation. In completed preparation, the subject performs the actions that, in their opinion, are necessary to create conditions for direct infringement, which, if used, are capable of leading to the commission of a completed crime; however, due to circumstances beyond the perpetrator's control, their activity does not develop further. Upon completing the preparation, the person realises that they have performed the entire scope of activity necessary for the subsequent commission of a completed crime.
Incomplete preparation represents activity that does not contain the conditions necessary for committing a completed crime, either in the person's opinion or in reality. Having begun to perform the intended actions (inaction) aimed at creating conditions for direct infringement, the person, under the influence of both external and internal circumstances beyond their will and desire, fails or is unable to carry out the entire scope of preparatory activity (for example, the perpetrator is detained while preparing).
Completed preparation poses a greater degree of public danger than incomplete preparation.
According to Part 3 of Article 24 of the Criminal Code, an attempt to commit a crime shall mean actions (inaction) committed with direct intent and directly aimed at committing a crime, provided that the crime was not completed due to circumstances beyond the person's control.
Criminal liability arises for an attempt to commit a medium-gravity, serious or particularly serious crime, as well as for an attempt to commit a terrorist crime (Part 4 of Article 24 of the Criminal Code). The legislator expanded the list of types of crimes for which an attempt entails criminal liability by including terrorist crimes. As indicated above, a similar amendment was also extended to the provisions concerning preparation for a crime (Part 2 of Article 24 of the Criminal Code).
An attempt is characterised by the fact that, in this case, the perpetrator's actions are directly aimed at committing a crime. This is what distinguishes an attempt from preparation, during which conditions for committing a crime are merely created, while the action itself is not yet directly aimed at committing the crime.
A case in which the perpetrator fires a shot at a victim with the intention of killing them but misses, or attempts to fire but is prevented by someone, should be regarded as an attempt. Breaking the lock on a shop door for the purpose of committing theft, raising a knife above a person's head with the intention of killing them, and so forth, should also be considered attempts. However, in all these cases, the crime is not completed for reasons beyond the perpetrator's control (the criminal gives the victim poison with the intention of killing them, but the substance turns out to be insufficiently poisonous or the dose is too small, and death does not occur).
An attempt is possible in the commission of all crimes with material elements, that is, in cases where the completed corpus delicti requires the occurrence of specific consequences. In most cases, an attempt to commit such crimes is made through action, but inaction is also possible (for example, a mother does not feed an infant so that the child dies; a citizen who is obliged by virtue of their official duties to switch off the electricity fails to do so in order to cause a fire).
An attempt is also possible in certain crimes with formal elements. A feature of an attempt in formal-element crimes is that an attempt is possible here only through action (for example, giving a bribe — Article 367 of the Criminal Code, rape — Article 120 of the Criminal Code, and so forth).
An attempt to commit a crime is impossible in formal-element crimes committed through inaction (evasion of conscription upon mobilisation — Article 388 of the Criminal Code, and so forth). An attempt is also impossible in formal-element crimes in which the very first act of criminal activity constitutes a completed crime. For example, robbery (Article 192 of the Criminal Code) is recognised as a completed crime from the moment of the attack, regardless of whether the purpose of the crime — the theft of another person's property — has been achieved.
In an attempt, either the criminal result is absent or the actions have not been fully performed (for example, an attempt to commit theft — Part 3 of Article 24, Part 1 of Article 188 of the Criminal Code; an attempt to commit murder — Part 3 of Article 24, Part 1 of Article 99 of the Criminal Code, and so forth). In such cases, the perpetrator has done everything, but the criminal result has not occurred, or not all actions necessary to achieve the criminal result have been performed, unlike a completed crime, in which the objective elements always possess all the necessary features.
When we speak of the absence of consequences in an attempt involving material-element crimes, this does not mean that there are no consequences whatsoever. Consequences may occur, but they are not the consequences sought by the criminal. For example, the perpetrator fires a shot with the intention of taking a person's life but causes only bodily harm. In this case, there is an attempt to commit murder (Part 3 of Article 24, Part 1 of Article 99 of the Criminal Code), that is, an attempt to commit the crime that the person sought to commit.
In formal-element crimes, an attempt is also manifested in the fact that the actions specified in the law have not been fully performed. Thus, if an offered bribe is not accepted, the actions of the bribe-giver should be classified as an attempt to give a bribe (Part 3 of Article 24, Article 367), and the actions of the intermediary as an attempt at mediation in bribery (Part 3 of Article 24, Article 368 of the Criminal Code). If a bribe previously agreed upon is not received due to circumstances beyond the will of the bribe recipient, the act committed by that person should be classified as an attempt to receive a bribe (Part 3 of Article 24, Article 366 of the Criminal Code).
When considering an attempt to commit a particular crime, it is always important to establish that the actions committed were specifically aimed at implementing the perpetrator's intent. If the person's actions served another purpose, their commission cannot be regarded as an attempt to commit a crime.
From the subjective standpoint, an attempt to commit a crime is characterised exclusively by direct intent. This is explained by the fact that an attempt always presupposes the perpetrator's conscious and purposeful activity.
In cases of so-called indefinite intent (when the criminal result has not been specifically determined in the perpetrator's consciousness), the issue of an attempt plays an important role in the legal classification of the perpetrator's actions. Thus, for example, when attempting to cause bodily harm to a victim, the perpetrator may not have specifically determined in their consciousness whether they would cause serious or medium-gravity bodily harm.
In this case, the issue of liability is resolved as follows:
- If bodily harm of a particular degree of severity is caused in the presence of indefinite intent, the person must be held liable for the harm actually caused as a completed crime. For example, R., firing a hunting rifle in the direction of M., who was walking, foresees the occurrence of socially dangerous consequences but does not specify them or precisely imagine what those consequences will be. As a result, M. sustained bodily harm of medium gravity, for which R. was held liable;
- If, in the presence of indefinite intent, no harm occurs, although an attempt to cause it was made, the perpetrator must be held liable for an attempt to cause less serious bodily harm (in the example considered, R. would be subject to criminal liability for an attempt to intentionally cause bodily harm of medium gravity).
The issue is resolved somewhat differently when determining liability for an attempt committed with alternative intent. With alternative intent, the perpetrator allows for the possibility of one or another of the criminal results they have foreseen, while equally desiring the occurrence of either result.
If, in such circumstances, the less dangerous of the anticipated consequences occurs, the person is not exempt from liability for an attempt to cause the other, more serious consequence, even though it did not occur, because the subject also desired its occurrence. For example, if a person intended to kill another person or, at the very least, injure them, but in reality only inflicted an injury, that person is subject to liability for attempted murder (Part 3 of Article 24, Part 1 of Article 99 of the Criminal Code).
Thus, the actions of the perpetrator may be recognised as an attempt if they:
- are directly aimed at committing a crime, that is, the perpetrator has already directly carried out or begun to carry out an infringement upon the object;
- do not contain all the elements of the objective side of the crime that the perpetrator intended to commit, that is, the perpetrator has not completed the crime;
- the perpetrator did not complete the crime for reasons beyond their control;
- are intentional in nature.
The law does not provide for a division of attempts into types. However, criminal law theory distinguishes two main types of attempts: incomplete and complete.
An incomplete attempt is one in which the person has not yet performed everything that they considered necessary to carry out their intention. For example, a thief, intending to commit a burglary, places a ladder against a window but is detained while attempting to climb over the windowsill (Part 3 of Article 24, paragraph 3) of Part 3 of Article 188 of the Criminal Code).
A complete attempt is one in which the person has performed everything that they considered necessary to carry out their intention, but the result does not occur for some reason. For example, a thief, intending to steal money, enters an office, breaks open a safe, but finds no money inside.
Thus, the differences between a complete and an incomplete attempt are as follows:
— in a complete attempt, the perpetrator does everything they consider necessary for the criminal result to occur, but the result does not occur due to circumstances beyond their control;
— in an incomplete attempt, the perpetrator has not yet performed all the actions they consider necessary to achieve the criminal result.
The division of attempts into complete and incomplete has both theoretical and practical significance. A complete attempt generally poses a greater degree of public danger than an incomplete attempt. This circumstance is taken into account by the court when determining the measure of punishment for the perpetrator.
The division of attempts into complete and incomplete is also important for correctly resolving the issue of voluntary abandonment of the commission of a crime: voluntary abandonment is possible in the case of an incomplete attempt, but impossible in the case of a complete attempt.
Attempts using unsuitable means are understood as cases in which the perpetrator uses means that are objectively incapable of bringing the crime to completion and producing the criminal result. However, subjectively, when using certain means of committing a crime, the perpetrator believes that their actions will cause the specified consequences. Since criminal law applies the principle of subjective attribution of liability, the perpetrator will also be held liable for an attempt to commit a crime in this case. Liability here arises under the rules governing factual error, that is, the legal classification is based on the direction of intent and is classified as an attempt to commit a crime, since the consequences expected by the perpetrator do not occur. Examples of attempts using unsuitable means include firing an inoperative firearm, mistakenly using another chemical substance instead of poison, and so forth.
However, it should be taken into account that where the unsuitability of the means used is obvious to everyone (for example, the use of spells, witchcraft and other superstitious means due to ignorance), the actions of the perpetrator cannot be regarded as socially dangerous and do not entail criminal liability.
An attempt against an unsuitable object is an attempt in which the subject's actions are directed either against an object that is absent at the time of the attempt or against an object that, although present, possesses properties that make it impossible for the result desired by the perpetrator to occur. For example, firing at a corpse mistakenly believed to be a living person (Part 3 of Article 24, Part 1 of Article 99 of the Criminal Code), attempting to steal something from an empty pocket (Part 3 of Article 24, Part 1 of Article 188 of the Criminal Code), and so forth.
An attempt against an unsuitable object, just like an attempt using unsuitable means, generally entails criminal liability.
In conclusion, the following should be noted:
— the legal classification of an incomplete crime must reflect the stage at which the crime was interrupted, that is, it must contain a reference to the specific part of Article 24 of the Criminal Code;
— if direct intent has not been established, there can be no question of preparation for a crime or attempted crime;
— where the desired result is not achieved in the presence of definite intent, the acts are classified as an attempt to commit a crime depending on the direction of the intent;
— where consequences occur in a crime committed with indefinite intent, the act is classified as an attempt to commit a crime with the least dangerous of all the desired consequences;
— the commission of at least one of the actions alternatively specified in the disposition of an Article excludes the criminal-law assessment as an attempt to commit another of those actions where only part of that other action has been performed.
Commentary dated 2021 on the Criminal Code of the Republic of Kazakhstan by Isidor Shamilovich Borchashvili, Honoured Figure of Kazakhstan, Doctor of Law, Professor, Academician of the National Academy of Natural Sciences of Kazakhstan, member of the Scientific Advisory Councils under the Constitutional Council of the Republic of Kazakhstan and the Supreme Court of the Republic of Kazakhstan, member of the working group on reform of the law enforcement system under the Security Council of the Republic of Kazakhstan, and Honoured Employee of the Ministry of Internal Affairs of the Republic of Kazakhstan.
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