Nearly two decades after *Prakash Singh*, police reform remains a contest between judicial directives and State autonomy. Critically examine.

Police is a State subject under the Constitution [2]. In Prakash Singh v. Union of India (2006), the Supreme Court issued binding directions to keep the police free of political control [3]. These directions still apply, as the Centre's recent challenge to Jharkhand's 2025 DGP Regulation shows [1]. The contest is real, but it hides a deeper failure: neither side has turned reform into statute-backed practice.

Why judicial directives were needed

• Legislative vacuum: the Second ARC found that ministers "misused" control over the police "for personal and political reasons" [2].
• Insulating leadership: the DGP must be chosen from the three senior-most UPSC-empanelled officers and serve a minimum two-year tenure [3].
• Institutional buffers: the Court ordered a State Security Commission, a Police Establishment Board and Police Complaints Authorities [3].

Why the State-autonomy argument has force

• Federal design: States write their own rules. Jharkhand's Regulation, under which its first woman DGP was appointed, is one example [1].
• Selective enforcement: Jharkhand argued that the Centre showed it "special affection" while Bihar's "worse" law went unchallenged [1]. Uneven scrutiny makes reform look like a political weapon.

Limits of both routes

• Court orders lack day-to-day enforcement: compliance is tested only when someone files a case, as in this dispute [1].
• States keep executive control: the ARC said this power "must be limited under law" [2]. Many State rules do not do this.
• Narrow focus on the top post: State forces had 24% vacancies in 2016. Actual strength was 137 police per lakh people, against 181 sanctioned and a UN norm of 222 [2]. A neutral DGP cannot fix a force that is short of staff.

Assessment The "Court vs States" framing is only partly true. States can legislate freely, but they cannot dilute the minimum standards the Court has set. Another State's breach does not excuse their own.

The way forward combines the two. The Supreme Court should test every State's DGP law against one common checklist (UPSC panel, two-year tenure, no acting DGPs), as its plan for wider scrutiny suggests [1]. State legislatures should give statutory powers to the bodies the ARC envisaged [2]. Together, these would make police reform a matter of cooperative federalism and the rule of law, in line with SDG 16 (accountable institutions).