Examine the issue of accountability and transparency in state police investigations, with reference to recent High Court interventions ordering CBI probes.

Accountability means answerability for how an investigation is conducted; transparency means that the process is visible to the victim and to courts. The Bombay High Court's order of 2 September 2026 transferring the 2020 Disha Salian death case to the CBI [1] shows both remain contested in state policing.

Accountability deficits

• Selective FIR registration: Lalita Kumari (2013) made registration mandatory where information discloses a cognizable offence [2], yet the Salian death was closed as an Accidental Death Report for years without an FIR [1].
• Political influence over local police weakens impartiality, especially where the accused are influential — the very ground on which courts have transferred probes.
• Capacity constraints: high vacancies and multi-tasking by an overburdened force dilute investigative quality [5].

Transparency gaps

• Basic records — such as the post-mortem report — reached the family only after judicial intervention, years later [1].
• Closure decisions are often opaque; the victim's family learns of them without reasons, though a protest petition remains available [1].
• The 2nd ARC's 5th Report, "Public Order", therefore urged separating investigation from law-and-order duties through a specialised state crime investigation wing [6].

High Court intervention: corrective, with limits

• Under Article 226, a High Court may direct a CBI probe even without State consent, otherwise required under Section 6, DSPE Act, 1946 [3][4] — a constitutional check on police inaction.
• But it is an extraordinary remedy: six years elapsed between the death and the transfer [1], the CBI is itself understaffed, and high-profile transfers risk politicisation. Hence the Court directed that no person be treated as accused absent sufficient material [1].

Judicial transfer treats the symptom; the disease is institutional. Implementing the Prakash Singh directions — Police Complaints Authorities, fixed tenures and separation of investigation [5] — alongside the ARC's recommendations would make honest, visible investigation the norm, and CBI transfer a rare exception rather than the victim's only route to the fair-procedure guarantee of Article 21.