Discuss the principle of minimum force in policing unlawful assemblies in India. Critically examine recent instances where this principle was allegedly violated.

Minimum force means force that is proportionate, graduated and necessary — used only after warning, and withdrawn the moment the assembly disperses. It is a statutory command, not police discretion, and its breach converts crowd control into state excess.

The doctrine and its legal basis

• BNSS, 2023 (Sections 148–151) allows dispersal by civil force only after a command to disperse is defied; armed force is a magistrate-supervised last resort, using as little force and injury as possible [1].
• Model Police Act, 2006 (Sorabjee Committee) frames the police as a service bound by proportionality and public accountability [2].
• Prakash Singh (2006) directives — Police Complaints Authorities and insulation from political control — supply the accountability arm without which minimum force stays paper law [3].
• Doctrinal ladder: persuasion → lathi → water cannon/tear gas → firearms, each step justified in writing.

Recent instances — a critical view

• In the Siwan (Bihar) NEET-UG 2026 paper-leak protests, a constable fired four AK-47 rounds in the air; Bihar Police's own affidavit concedes the AK-47 is a "platoon-level weapon for special operations", not law-and-order duty — a weapon-allocation failure, prior to any question of intent [4].
• A second officer used a 9mm pistol; three protesters suffered minor firearm injuries, with ballistics ordered — the state's claim of "utmost restraint" thus remains untested [4].
• The Supreme Court's scrutiny of these pleas shows accountability is being triggered judicially, not departmentally [4].

The other side

• The constable was reportedly trapped in a violent crowd; forces often lack non-lethal kits and refresher crowd-control training.
• Yet the DGP's corrective AK-47 instructions came only after the incident — control that is reactive, not preventive [4].

Minimum force fails less from bad law than from weak weapon-issue protocols, thin non-lethal capacity and absent internal review. Standardised law-and-order armouries, body-worn cameras and functional Complaints Authorities can restore it — alongside addressing the trigger itself, exam integrity, under the Public Examinations (Prevention of Unfair Means) Act, 2024 [5]. Policing that is proportionate protects both public order and the Article 19(1)(b) right that summoned the crowd.