Police reforms in India remain hostage to Centre-State jurisdictional divisions despite repeated judicial intervention. Examine with reference to the Paramvir Singh Saini judgment and subsequent Central schemes.

Police and public order are State List subjects under the Seventh Schedule, leaving the Union with only a funding and technology-support role. This division explains why judicial mandates and central outlays repeatedly stop short of durable reform on the ground.

Judicial intervention: the Paramvir Singh Saini mandate

• In Paramvir Singh Saini v. Baljit Singh (2021) the Supreme Court made CCTV installation mandatory in police stations — including lock-ups and rooms of Inspectors/Sub-Inspectors — grounding it in Article 21 and the prevention of custodial violence [1].
• The Court adopted continuing mandamus, seeking periodic compliance reports from the Centre, States and UTs rather than issuing a one-time direction [1].
• Yet in 2025 the Court took suo motu cognisance after reports of non-functional cameras in Udaipur police stations, showing that enforcement depends on State executive will [2].

Central schemes: money without command

• The MHA's umbrella Modernisation of Police Forces (MPF) scheme carries a central outlay of ₹26,275 crore for 2021-26, including ₹4,846 crore for direct State assistance and ₹2,080.50 crore for forensic capacity [3].
• Responding to the Court, the Centre in September 2026 informed the Bench that a ₹24,000-crore Police Modernisation Mission over five years had begun implementation for State police and CAPFs [2].
• Being cost-shared and State-implemented, such schemes historically face fund underutilisation and uneven adoption; the Centre can finance cameras and forensics, but cannot direct thana-level compliance.

A qualified verdict The constraint is real but not absolute — technology-linked funding has expanded forensic and surveillance infrastructure even where structural reform stalled.

Thus jurisdictional division limits, rather than defeats, reform. Cooperative federalism — conditional release of MPF tranches on verified CCTV compliance, State Security Commissions as envisaged in Prakash Singh (2006), and third-party audits — can convert central outlays into accountable policing, realising the Article 21 promise the Court sought to secure.