Evaluate the role of the judiciary in enforcing accountability in policing through continuing mandamus, citing recent Supreme Court proceedings on police modernisation.

Continuing mandamus is a remedy where the Court retains jurisdiction over a case and supervises execution through periodic compliance reports, instead of issuing a one-time direction. The Supreme Court's decade-long supervision of CCTV coverage in police stations — culminating in the Centre disclosing a ₹24,000-crore Police Modernisation Mission — shows this tool to be effective in agenda-setting but limited in delivery.

Where continuing mandamus has delivered

• Converts rights into enforceable standards: in Paramvir Singh Saini v. Baljit Singh (2020), the Court mandated CCTV with audio at lock-ups, corridors and officers' rooms, with footage retention up to 18 months — operationalising Article 21 against custodial violence [2].
• Sustained supervision: mandatory compliance reports from the Centre, States and UTs, plus State and District Level Oversight Committees, kept the issue alive beyond the judgment [2].
• Fresh cognisance on default: in 2025 a Bench of Justices Vikram Nath and Sandeep Mehta took suo motu notice of non-functional cameras in Udaipur police stations [1].
• Budgetary follow-through: under this scrutiny the Centre informed the Court (September 2026) that a ₹24,000-crore Mission for State Police and CAPFs, spread over five years, had begun implementation [1].

Limits of the judicial route

• Federal constraint: police is a State List subject; the Centre can only fund and the Court can only exhort, diffusing accountability across States [3].
• Money was never the sole gap: the MPF umbrella scheme already carried a ₹26,275-crore outlay for 2021-26, yet chronic under-utilisation persisted [4].
• Verification deficit: the Court relies on self-reported affidavits without independent audit — hence non-functional cameras years after the mandate [1].
• Equipment is not accountability: without statutory backing, directions dilute, as the Prakash Singh (2006) reforms show.

On balance, the judiciary has been an indispensable catalyst rather than a substitute for executive will. Codifying these directions in law, third-party audits of camera functionality, and empowered Police Complaints Authorities would convert judicially-prompted spending into durable, rights-respecting policing.