Judicial intervention has often driven police reform in India more than legislative or executive initiative. Discuss with reference to the *Paramvir Singh Saini* case and its aftermath.

Police being a State subject (Entry 2, List II), reform has depended on political will that has rarely materialised. Consequently, the Supreme Court — invoking Article 21 — has repeatedly become the prime mover, as the CCTV mandate in Paramvir Singh Saini vs Baljit Singh (2020) illustrates.

Judiciary as the driver of reform

• Prakash Singh vs Union of India (2006) laid down seven binding directives — State Security Commission, Police Establishment Board, Police Complaints Authority, fixed DGP tenure via UPSC empanelment — after the executive shelved decades of commission reports [1].
• Paramvir Singh Saini (2020) mandated CCTV cameras with night-vision and audio-video recording at entry/exit points, lock-ups and interrogation rooms of every police station, extended it to the CBI, NIA, ED and NCB, and created State-level Oversight Committees to review footage — a custodial-torture safeguard no legislature had enacted [2].
• Continuing mandamus: the Court's 2025 suo motu proceeding, triggered by non-functional CCTVs in Udaipur, shows judicial follow-up sustaining reform where the executive stalls [3].

Limits of judicial primacy

• Courts can direct, not fund. Implementation rests on the executive: the Centre told the Court in August 2026 that its new umbrella police-modernisation proposal, sent to the Department of Expenditure on 8 July 2026, still awaits approval [3].
• Substantive capacity-building is executive-led — the MPF umbrella scheme (2021-22 to 2025-26) with ₹26,275 crore outlay, and ASUMP (₹4,846 crore; 90:10 for Category 'A' States, 60:40 for others) fund weaponry, technology and infrastructure [4][5].
• Judicial directions falter without legislative uptake: the Model Police Act, 2006 remains unadopted by many States, and Udaipur-type maintenance failures persist.

Judicial intervention has therefore set the normative agenda for police reform, but delivery depends on budgetary and legislative follow-through. The way forward lies in States enacting Model Police Act provisions, timely Finance Ministry clearance of modernisation outlays, and a centralised compliance dashboard — converting court-mandated rights into everyday administrative practice.