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.

Q. 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. (15 marks, 250-350 words)

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.

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Sources: 1. Prakash Singh & Ors vs Union of India (22 September 2006) — seven police-reform directives; SSC, PEB, Police Complaints Authority, DGP tenure 2. Paramvir Singh Saini vs Baljit Singh (2 December 2020) — CCTV mandate in police stations and central agencies; Oversight Committees; Article 21 basis 3. "Police modernisation scheme awaits Finance Ministry's nod", The Hindu, 6 August 2026 — 2025 suo motu case on Udaipur CCTVs; proposal sent to Department of Expenditure on 8 July 2026 4. PIB, "Government of India approves continuation of umbrella scheme of Modernisation of Police Forces (MPF)" — MPF continuation 2021-22 to 2025-26; ₹26,275 crore outlay 5. Ministry of Home Affairs, "Modernisation of State Police Forces (MPF) Scheme" — ASUMP ₹4,846 crore outlay; 90:10 and 60:40 Centre-State sharing