Walter Gellhorn, a pioneer in administrative law, proposed last night that three federal agencies be organized to handle citizens' complaints of abuses by the government.

In the second of three Oliver Wendell Holmes Lectures, Gellhorn, a professor of Law at Columbia University, said that congressmen now handle the bulk of citizens' grievances -- over 200,000 a year. But, he argued, they are not in a position to criticize the government quickly, impartially, and effectively.

What is needed, Gellhorn said, is a coordinated system of criticism. He advocated that three government offices be used:

The Administrative Counsel to Congress -- an official pointed by the Speaker of the House and the President pro tempore of the Senate. He would handle petty complaints of the constituents of congressmen.

* The Administrative Conference of the United States -- a council of major government agency chiefs and private lawyers and educators. It will deal with broader problems, mainly making government agencies more efficient within their present structure. The Conference, created by the legislation in 1964, will begin operations in mid-1966.

* The General Accounting Office and The Bureau of the Budget -- both these agencies have already transcended their simple accounting duties. They now deal with problems of efficiency among federal administrative bodies, such as preventing overlapping. Gellhorn wants the GAO and Budget Bureau to increase the scope of their work.

* The professor categorized the three facilities as dealing with grievances on the "retail, wholesale, and structural levels."

Combined with the work of Congress, they can put an effective check on federal abuses against citizens, such as the holding up of tax refunds, the sending of miscomputed welfare checks, or the im- proper taking of property to build federal roads.

But, Gellhorn said, each federal agency must also police itself. "Outsiders' denunciation of botched work can never be as significant as anti-botchery efforts inside administrative ranks.