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Policing By Police: A Shift From The Traditional Approaches To Meet The Requirements Of New India (By-Amar Pandey & Sonu Agarwal)
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Policing By Police: A Shift From
The Traditional Approaches To Meet The Requirements Of New India
1. Introduction To Indian Police
System:
“Police” is one of the
main organs in a country, because they are the ones who get to know the
problems of the public at the first instance. Police is responsible for
maintaining law and order in a society. The dictionary meaning of Police is “A
civil force of a state, responsible for the prevention and detection of the
crime and maintenance of public order.” Police in India has been present in the
Vedic, Medieval and during the Mughal rule. It has seen some good phrase during
the Gupta Period and the Ashoka Period and also it was in a confused state of
condition during the Mughal Period. The Police System was revolutionized first
in India during the British Rule, where they brought a central police act named
as “The Police Act, 1861” when they established there rule in India after they
converted from being an East India Company to body that will rule whole of
India. The revolts of 1857 made them feel the importance of well set up system
of Police to control and rule such a vast country. Thus a committee was appointed
in 1860 to setting up of a Police system with the objectives to have a look at
the business or trade matters and to follow orders and to live up to the
imperialistic and racist views of the British authority. This all led to the
establishment of the Indian Police act 1861.
This legislation got amended in 1902 by the setting up and
recommendations of the All India Police Commission in which the setup of the
police was further extended and the chairman of that particular committee,
A.H.L Fraser said in his statement that ‘The police force is far from efficient, it is defective in
training and organization, it is inadequately supervised, it is generally
regarded as corrupt and oppressive, and it has utterly failed to secure the
confidence and cordial cooperation of the people’. By a committee
named as Islinton Commission in 1912, the Indians got accommodated at the
senior levels of the Police force and with the recommendations of Lee Committee
in 1924, the quota for including Indians in the police force which was reserved
as 33 percent in 1919 got up to 50 percent. After framing the Indian
Constitution which was
the largest constitution, the constituent assembly adopted the same police act
along with several other things namely the Codes such as Indian Penal Code, the
Code for Criminal Procedure and the Indian Evidence Act.
2. Constitutional Provisions
According to the Indian
Constitution, Article 246 and the Section 3rd of Indian Police act
(IPA) Police force is a state subject which means that it is going to be dealt
by the state government of each and every state and not from the central
government. But this does not minimize the role of the central government; the
central government may intervene in some situations that are through the words
of Article 355 of the Indian Constitution it is center’s duty to protect the
state from internal disturbance, Schedule 7th of the Indian
Constitution empowers the central government to make laws relating to armed
forces of the union that are the departments of CBI ( Central Bureau of
Investigation), Institutions of training of Police Officers, All India Service
& many more. All these departments or organization come under the direct
control of Ministry of Home Affairs. The Central Government appoints the IPS officers
according to Section 3 of All India Service Act after consultations with the
state government.
3. The Structural Makeup Of The
Police:
The head of Police Force
in the State is the Director General of Police (DGP) who is responsible for
administration of police in the concerned state and for advising the government
in matters related to police. The state is further divided into Zones, Ranges
and Districts. The Superintendent of Police (SP) is the head of the district
police force. A group of Districts forms a range and the head of the range is
Deputy Inspector General of Police and his job is to assist the SP and have
regular visits to the districts. States have setup zones if they have multiple
ranges. The head of the zone is the Inspector General of Police (IGP). The
districts are divided into sub-divisions, circles and police stations. The head
of sub-division is Additional or Deputy Superintendent of Police (ASP). On the
basis of population the sub-divisions are further divided into police stations
and a police station is headed by Inspector or Sub- Inspector. Head Constables
and Constables form the lower level of the police force. Between Police
Stations and Sub Divisions there are Circles in some states which is headed by
Inspector of Police. The District Police is divided into Armed Police and Civil
Police, where the civil police job is to control crime and the armed police
look after the law and order. These are reserved police for
district kept to meet
emergency requirements. There are other kinds of Police departments also that
are Detective Police, Traffic Police, Revenue Police, Mounted Police, Fire
Police and technical branches such as Prosecution Branch, Radio Branch and
Intelligence Branch.
4. Challenges Before The Police
Department
·
Modernization of the Police:
The main purpose for which the Police are required in a society is to
maintain law and order. The crimes that have taken place from time to time have
easily founded many different or the developed ways to commit what is against
the law, whether it be the use of weapons or using better techniques to fulfill
their particular motive. With the development of crimes in the society the
question that needs to be answered is that the equipment’s or the resources
available or given to police are sufficient or not. Is police capable enough to
handle such an increasing and developed crime rate? The resources includes the
availability of modern weapons, the expenditure put on the training of police
officers, available funds to each police station for carrying out daily
activities. The reports of CAG have suggested and come out with a report
stating that the weapons that are right now used by the police officers are
outdated and are not sufficient to deal with the modern weapons that are with
the criminals. Basic digital instruments used by police are also not available
in sufficient numbers. Camera/ CCTV used by the Police for investigation are
12930, where Bihar and Jharkhand police do not take use of the Police camera or
the CCTV[3].
Another link to this problem is the lack of availability of funds for the use
of police stations, here it is important to note that police being a state
subject where the state plays a majority role in controlling it, but the funds
are received from central also and then is always a political factor that
decide in the allotment of the funds to a specific state from the Center and
many a times state government also doesn’t release funds for the police station
giving the reason that the union government has not given the funds. Also the
corruption in police leads to a very minimum amount left which can be actually
spend on the Police Station. Here expenditure of police station includes there
daily routine work of patrolling, investigation, keeping records. Also another
important issue is the training of the police officers, in Indian police there
are multiple doors by which an individual can enter,
training of IPS officers is done in Hyderabad under the supervision of
central government but the training expenditure and facilities on the lower
ranks of police is very alarming. The lower ranks of the police i.e. the
constables are ones who are more attached to the public and the training of
these constables on how to deal with the particular situation is very
necessary. The modernization grants for the police in the year 2015-16 was
1581.47 cr. by central government and by state government 7621.99 cr. and the
funds out of these which were utilized are 1330.28 cr.
·
Police to Population Ratio:
Police during British India was the most efficient and effective. The
Reason for that was the Police to Population Ratio that made the British police
have an upper hand over any Indian protest for such a long time period. It was
only the nonviolent methods of Mahatma Gandhi that were able to make an impact
on such an effective British administration. The Indian Police in the present
times is facing such an issue. The population of the country is ever increasing
and the police personnel available or joining the police force is very low as
compared. To have an effective control over the people, to look into the
matters where there is a conflict in the laws the numbers that are required in
the police departments need to be higher; this will lead to both efficiency and
effectiveness in the police department. According to the report in 2005 the
population of the country was 110.71 cr. and then the total strength of police
personnel was 15.79 lakhs which is 701 persons per policemen and in 2015, the
population of the country was 126.29 cr. and the numbers of policemen we have
were 22.80 lakhs which is 554 people per one policeman[4].
As compared to other countries, United States has one officer on 436 people,
Spain has one officer for 198 & South Africa has one officer for 398
people, the United Nation standards states that their needs to be one police
officer on 454 people[5].
·
Working hours for the policemen:
The working hours for the policemen are also an issue to be looked at.
The Police force is the only unit which works for the society 24 hours and 7
days in the week. The working hours for a policemen is never specified, he has
to be on alert anytime and at anyplace to face any emergency situation whether
it be a terrorist attack, any natural calamity, any public festival or any VIP’s
rally. This creates an adverse effect on the lifestyle of those particular
police men, many psychological problems emerge, and much dangerous disease also
develops during this
time span. Also the facilities provided by the government whether it be
of housing or of increment. It is not sufficient enough for police personnel to
lead a happy life. Also this very condition in the police sector makes distrust
towards the youth to join the police department. To talk about the workload of
the police department, a police officer has to maintain law and order, also do
the investigation of the case or a situation and an important thing in
investigation is the “Evidence”, and especially the evidences that are
available on the spot of the crime, these evidence when proved through forensic
science act as a strong and substantial proof before the court of law. But in
our country, there is lesser stress given on the forensic department and that
is the reason that investigation takes such a long time, also the police
officer are not properly trained to deal with the techniques of dealing with on
the spot evidences and this leads to many evidences and proofs gets destroyed.
In many countries there is a separate department for Investigation in which the
officers are well trained in dealing with the evidences. Up to 90% of Indian
police officials work more than 8 hours a day, in which 68 percent works 11
hours a day and 28 percent works 14 hours a day[6].
·
Relationship with the local
inhabitants:
The police departments in the country do face external challenges like
mentioned above but there are some loopholes in the internal structure also.
The most important aspect for a police department in a country is how policemen
of the police station share the relationship with the citizens of their
particular area. This will always help a police officer by some or the other
way. People reporting there problems to the police and have believe among
themselves that the police is the protector of the rights which the constitution
of the country has given to them. The concern to be looked at is how much of
the cases go unreported, the same issue has been debated in cases of rape, we
all noticed how much grievous was the Delhi gang rape and that instance was not
for the first time, many of such cases go unreported and one of the main
reasons for that is people have a negative image of the police in their minds,
they feel that the police is irresponsive to the problems which they register.
Also the behavior by which the police officials treat the person who has come
to them to make a report, they will ask them unreasonable questions, behave in
a rude manner and many a times refuse to register their reports. People in our
country are not very much aware about the rights available with them, one such
right is given to the women for filing a report in case of any act committed
against them in any of the nearest police stations, this is commonly known as
the zero report system
whereby no policemen can give a reasoning that this case or event
doesn’t come under the jurisdiction of his police station otherwise the
situation was that police officers refused to accept the complaints of the
victims stating the reason that the case doesn’t fall under their jurisdiction.
·
Judicial relation and Impact:
Another important
point is the relationship of the police and the judiciary. To understand this
aspect the point which needs to be looked at is Section 167 of Cr. P.C which
states that when the accused remains in the custody of Police, Police has
physical control over accused. Police custody is given in non-bailable
offences, depending upon the circumstances of the case and to facilitate
investigation. Police custody cannot be given in bailable offences. Whereas
judicial custody means that the accused is technically in the custody of
the Magistrate. Police cannot interrogate a person in judicial custody without
permission of the concerned Magistrate/court. Many cases of torture have come
up during the police custody where the person who is in the custody is made to
admit a fact or to sign a statement of the basis of a termed called as “Danda
Investigation”.
·
Political Intervention:
Moreover, police
who was established with the purpose of serving the public today are serving
the ruling political party. Political interference in the police system has
only made the condition to worse. I think it is the base of all the problems
our political system is facing today. The lack of political will in developing
the police mechanism is an alarming challenge that our country is facing today.
The lack of trust among the people is because of the political pressure on the
police. The ruling party makes full use of the Police to initiate investigation
against the opposite party, the role and use of CBI has been a very famous
example for this. Also the ruling person of a particular area wants that the
police officers of his choice to appointed in his area so that he can use them
for having slow investigation in cases related to him or his supporters and
also the police will work in that area taking in mind the supporters of that
particular area because these supporters only turn out to be the vote bank for
that particular MLA. Police officers also have to follow or get used to such
interference and the one who doesn’t follow such instructions gets suspended or
gets a transfer to some other place. This situation has been the people in the
department working with restrictions and with corruption and also for some
specific set of people and also there is very less window left for a person who
wants to do his job seriously and honestly as either his seniors are corrupt or
the juniors do not respond to his orders.
·
Multiple Entry System:
The colonial
police system which we are following is full of loopholes, the officials of
that time also accepted this and this is a well-established universal fact that
we have to change according to the changing time because staying constant will
invite your end only. Our Police System which we are following is having multiple
entry system in it which means that a person can enter into the police system
through many ways. There are many exams held for major post in the police
administration, your recruitment to that specific post is done on the basis of
how better you perform in that exam. But the problem to conduct such an exam
for any of the post of the department is that a police officer does not come to
know what are the difficulties faced at the lower level both by the people and
by the police. Also he looks at his juniors with a lot of hate and treats him
as a person of low caliber and this very situation effects the integrity of the
department where the senior doesn’t believe on the junior and the same
vice-versa. There is just an opposite system that is followed in the Britain;
there the Police officer who is of highest rank has at one stage worked at the
lowest stage that is the constable post. This definitely adds to his experience
of working and assessing the situation in a better way and also in that kind of
system a lower rank officer has full chance on the basis of his performance to
go to the highest rank of the department. This motivates the officer to do well
in the cases which issued to him but the situation in our country is very
different, here the constable is not treated well by the seniors and also
chances of his promotions are up to a level of Assistant Inspector only and
that too after a lot of struggle, this demotivates him and ultimately it
reflects in the performance of that individual.
5. Recommendations and
various programmes organized:
The judgment of the court in this case
was termed as historic in the field of police reforms. It gave 7 principles
that need to be implemented by the states and the respective union territories.
These principles were:
§ Constitute a State Security Commission (SSC) to:
(i) Ensure that the state government does not exercise unwarranted influence or pressure on the police
(ii) Lay down broad policy guideline and
(iii) Evaluate the performance of the state police.
(i) Ensure that the state government does not exercise unwarranted influence or pressure on the police
(ii) Lay down broad policy guideline and
(iii) Evaluate the performance of the state police.
§ Ensure that the DGP is appointed through merit based transparent process
and secure a minimum tenure of two years.
§ Ensure that other police officers on operational duties (including
Superintendents of Police in-charge of a district and Station House Officers
in-charge of a police station) are also provided a minimum tenure of two years.
§ Separate the investigation and law and order functions of the police.
§ Set up a Police Establishment Board (PEB) to decide transfers, postings,
promotions and other service related matters of police officers of and below
the rank of Deputy Superintendent of Police and make recommendations on
postings and transfers above the rank of Deputy Superintendent of Police.
§ Set up a Police Complaints Authority (PCA) at state level to inquire
into public complaints against police officers of and above the rank of Deputy
Superintendent of Police in cases of serious misconduct, including custodial
death, grievous hurt, or rape in police custody and at district levels to
inquire into public complaints against the police personnel below the rank of
Deputy Superintendent of Police in cases of serious misconduct.
§ Set up a National Security Commission (NSC) at the union level to
prepare a panel for selection and placement of Chiefs of the Central Police
Organizations (CPO) with a minimum tenure of two years. As regarding the
implementation of this directive, Home ministry of central Government has taken
some significant steps, but more or less they are as ineffective as it is with
the situations of other 6 directives.
·
Police Act Drafting Committee:
The
chairman of this commission was Shri. Soli Sorabjee. This commission was made
to replace the existing police act with a new police act that can satisfy and
do justice to the motives for which it was setup. Features/ Recommendations of
this committee were:
§
Giving the power to control the
police organization in the hands of state government and ensuring that police
performs his acts in a professional manner.
§
Appointment of DGP to be done
by the State Government among the three senior most officers & empanelment
to be done by the state police force.
§
Tenure of Minimum two years for
the DGP
§
Security of tenure for key
police functionaries.
§
District Magistrate to have a
coordinating role
§
Initial appointment at Civil
Police Officer Grade-II and Sub-Inspector levels
§
Constitution of a State Police
Board, headed by the Home Minister. The State Police Board to frame broad
policy guidelines for promoting efficient, effective, responsive and
accountable policing, in accordance with law; prepare panels for appointment of
the Director General of Police; identify performance parameters to evaluate the
functioning of the police services and review and evaluate organizational
performance of the police service in the state.
§
Constitution of Police
Establishment Committee.
§
Definition of the role,
functions, duties and social responsibilities of the police.
§
Constitution of a village
police system. • Creation of Special Security Zones.
§
Constitution of a State Police
Accountability Commission to inquire into public complaints against police.
§
Constitution of a District
Accountability Authority[8]
·
Second Administrative Committee:
This
committee was headed by Shri Veerapa Moily and its recommendations were:
§
Separation of Investigation
Police from Law and Order police
§
An Independent Crime
Investigation Department
§
Accountability of State Police
and performance commission to frame policy guidelines to appoint DGP of police
and review performance of the Police.
§
Transfer of non-essential
functions of the police to other departments.
§
Fair & Professional
recruitment of police.
§
Setting up of District and
State Police Complaint Authority to take note of abuse of power by the police
officers.
§
Independent committee to investigate
in matters relating to police officers like rape, bribery and fake encounters.
·
Janamaithri
Suraksha Project (Community Policing[9]):
Janamaithri
Suraksha Project seeks the responsible participation of the citizens in crime
prevention at the level of the local community, conserving the resources, both
of the community and of the police, in fighting against crimes which threaten
the security of the community. Experience shows that by seeking the active
co-operation of the public in performance of police duties, the process of Law
Enforcement becomes far more effective. Appropriate training is being given to the Beat
Officers, Assistant Beat Officers, and Community Liaison Groups etc.
Janamaithri Suraksha Samithi members have an important role in implementing the
project. Selected persons have to be effectively trained. 1361 persons got
training in Police Training College for Janamaithri Suraksha Project. In order
to popularize the concept of Janamaithri Project, Janamaithri Kendra’s were
opened in District and Battalion Headquarters. These centers help people to
come and interact with police. These centers have become extremely popular with
the public. The information regarding the Police initiatives has to be
disseminated to the public. To give publicity about the Janamaithri Suraksha
Project and to attract more and more people into the ambit of the Scheme,
various activities are being undertaken. Pamphlets, booklets and other
materials are provided to them. The printed materials are supplied to houses in
the Beats which also provide them with information such as Beat Officer’s phone
number, and other Police telephone numbers and various services available with
the Police. A docu-drama is also being staged for the purpose of spreading the
message and mission of the project among the general public. To give publicity
about the Janamaithri Suraksha Project and to attract more and more people into
the ambit of the Scheme, various audio visual publicity activities are
undertaken. Short films and sponsored programmes have been telecast through the
visual media and radio programmes like radio jingles and skit have been
broadcast through radio[10]. The result of this was that there was a
significant rise in the registration of the crimes in the area, often the
registration of crimes in a particular area denotes that there is a higher
crime rate but if we look it with a different prospective we may conclude that
people of that very particular area believe in the police system and that is
why the registration of the crimes is done on such a higher scale because the
concern or the limitation in this situation is that unless and until the case
is been reported the police force or the laws cannot come into force. The
reports of this initiative in Kerala in tribal areas states that there has been
sufficient reduction in alcoholism in the area, 23%
regards as higher impact and 72% regards as medium impact[11], reduction in
crimes was reported as 49 % being medium and 45% as high[12]
& impact on improvement in registration of crimes was noted as 53% with
medium impact and 35% stated as high impact[13].
·
Saad Samvaad, 2012 (Goa):
This was a
weekly initiative launched by the police of Goa. In this five crucial
objectives were being focused: To bridge the communication gap between police
and public, to break anonymity of law breakers, to make law abiding citizens as
stakeholders in community policing, to improve police image and to make police
accountable and transparent. Police
spokesperson
said that an appeal will be made to the public to assist police in curbing
these menaces and be a partner in the prevention and detection of crime[14]. The initiative was inaugurated by the then chief
minister Manohar Parrikar. The initiative will see police meeting the public,
NGOs and other institutions on a regular basis and seeking their inputs on
various policing aspects. Police hope to improve intelligence gathering through
this initiative[15].
6.
Conclusion
“Police is a uniformed gang of criminals.
There is not a single lawless group in whole of the country whose records of
that organized unit which is known as the Indian Police and no self-respected
person would willingly associate with police whether as a witness, complainant
or defendant” By Justice A.N Mulla,
Allahabad High Court. This is the current situation of our police in
the country. The condition needs to be changed, and a change only can bring a
change. The current mechanism has shown signs of his inefficiency to cope up
with the present needs. Both external and internal conditions need to be
revolutionized and examples are there from within the department.
India
today is poised to emerge as a global economic power with all its high growth
rate of economy and all-round economic development. For realizing our
legitimate aspirations of economic development, it is essential that the
problems of peace and order are managed efficiently in the country. No
developmental activity is possible in an environment of insecurity and
disorder. Failure to manage the multifarious problems arising out of violent
conflicts based on religious, caste, ethnic, regional or any other disputes,
can lead to unstable and chaotic conditions. Such conditions not only militate
against realization of our economic dream, but also would jeopardize our
survival as a vibrant democracy. We have to look at the problem of public order
management and the role of law enforcement in that regard, in this perspective.
We should not forget that it is the weaker sections which suffer the most in any
public disorder. There is also a need for greater transparency in the law
enforcement agencies. Despite our efforts and more than five decades of
planning, regional imbalances and economic disparities between rural and urban
regions have grown, leading to disaffection and dislocation. The expectations
and aspirations of the people have also risen with globalization and
liberalization. While the new economic policies have contributed to growth on
the whole, conflicts stem from disparity in patterns of development, giving
rise to perpetual tensions.
Many
sections of the society, such as the laborers and the poorer sections, living
in villages and largely dependent on agriculture, have felt neglected.
Politically motivated groups often exploit their sense of grievance – real or
perceived. This is already leading to major conflicts and often confrontations
in different parts of the country, adversely affecting public order. While
violent manifestations of all such problems will have to be inevitably tackled
by the law enforcement agencies, given their socio-economic and political
roots, these problems, most of the times demand a concerted response from
different wings of the civil administration – both regulatory &
developmental - for resolution in the long run. Indeed, the response of the
police as the main law enforcement agency, is of crucial importance not only as
a bulwark against eruption or escalation of violence but also in resolution of
conflicts at the nascent stage itself, to prevent minor discords from turning
into public order situations. All the other concerned wings of the civil
administration too must be enabled and empowered to play their role in
consonance with an efficient police response. Lack of a coordinated approach
among different agencies, for instance, often proves to be a bane and this
calls for institutionalized mechanisms of formal and informal coordination
between all concerned agencies. There is need for national consensus among all
the agencies apart from the political parties. Unless there is clarity and
commitment on these issues, there would not be a convergence of national
purpose. What is also required is a holistic approach towards managing such
issues. For example, communal riots must be accepted as a failure of governance.
We have to uncover the chemistry of these riots and suggest long-term measures.
Also the recommendations of the National Police commission which were very much
deeply analyzed and researched need to be implemented in the coming years if we
have to put a honest step for the betterment of our police system, the
implementation is still a problem as was recommended in the report of Justice
Thomas Committee[16]. Committee recommended that The Supreme Court, to
begin with, may, therefore, initiate action as deemed appropriate, against
these States. It recommended, as for the
remaining States, it is for the Supreme Court to decide on the course and
modalities of such verification, to assess the exact level of compliance of the
directives by them, before deciding on the action to be taken in respect of
them. Committee stated that “Proper functioning of police forces is crucial for
the rule of law to prevail in any society. It is also a critical requisite for
ensuring the Fundamental Rights of the people enshrined and guaranteed under
our
Constitution. The indifference of the State
Governments to the issue of police reforms and non-compliance of the Directives
of the Supreme Court in this regard, despite the tenacious efforts made by the
Committee within the boundaries of its limited mandate, has to be viewed in
that perspective.”
The
programmes which are organized by various state police must be exercised on a
regular basis so that there is a development of confidence in the eyes of
people for the police. Also there is a need for change in the internal system
of the police where the seniors needs to respect both there juniors and seniors
so that the sense of unity is maintained in the department. Also corruption in
police need to be taken on strict note, policemen or the cases on which there
is a complaint against police officer of bribing or any type of corruption an
independent committee should properly investigate it and proper charges must be
put on the concerned police officers, this very step will ensure that there is
no more corruption in the department. The problems in the police department are
inter linked, if there is a problem of police to population ratio then this is
because of the vulnerable condition in which the policemen works and also
internal corruption in the department plays a role in it. If the problem is of
modernization of weapons in the field then the problem is due to lack of
political will. Political interference has made a sense of disbelieve in the
eyes of people for the police. This major problem can only be solved when
people will feel that police officers are just like their friends, they are the
protectors of their fundamental rights and examples of these are from Bhiwandi
in Maharashtra where the IPS officer Suresh Khopde implemented a “Mohalla
Committee” programme and the result of that programme was that the area of
Bhiwandi which was famous for riots was the district which was at peace during
the Ayodhya issue in the early 1990’s, this scheme had a lot of success and got
positive reviews by the Maharashtra CM and the Governor, later on the chief
minister said that the programme will be implemented in whole of the state. So
these programmes are an inspiration for the other department on what scale and
to what effectiveness the goals can be achieved and can be continued as the
same was done by the successors of Mr. Suresh[17].
It is imperative that more needs to be done than
mere structural changes within the system. It is essential to now look at the
police as a service organization meeting those needs of the society that are
essential for safety, security, quality of life and peace. Community
involvement, problem oriented policing and proactive policing strategies need
to be adopted in the changing scenario of society.
Article Information
Policing By Police: A Shift From The Traditional Approaches To Meet The Requirements Of New India (By-Amar Pandey & Sonu Agarwal)
Author Name: Amar Pandey & Sonu Agarwal
Title: Policing By Police: A Shift From The Traditional Approaches To Meet The Requirements Of New India
Email Id: Amar Pandey-amarpandey9713@gmail.com & Sonu Agarwal-sonu.aggarwal@jaipur.manipal.edu
- Journal IJLRA
- ISSN 2582-6433
- Published 2022/07/07
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International Journal for Legal Research and Analysis
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