Open Access Research Article

GUARDIANS OF JUSTICE? EVALUATING THE INDIAN POLICE SYSTEM, IDENTIFYING CHALLENGES, AND PROPOSING REFORMS

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SAURABH SHUKLA
Journal IJLRA
ISSN 2582-6433
Published 2023/10/31
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Issue 7

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GUARDIANS OF JUSTICE?
EVALUATING THE INDIAN POLICE SYSTEM, IDENTIFYING CHALLENGES, AND PROPOSING REFORMS
 
AUTHORED BY - SAURABH SHUKLA

 

Abstract
The Term Police stands for the official organization that is responsible for protecting people and property, making people obey the law, finding out about and solving crime, and catching people who have committed a crime.[1] Police plays a vital role in maintaining internal peace and social justice. The Indian police have its establishment germ in the British India. British establish the police to suppress the voice of Bharat’s Freedom and put a sense of terror in the eyes of freedom fighter; the police went various changes after the independent but still many citizen are a sense of scared to approach the police. Neither the color nor public trust against police as been changed, people still see the police as sense of fear. This paper will provide a detailed overview of the police system in India, including a few real incident that highlights, which questions the effectiveness of police system, challenges, problem faced with Indian police system etc.
 
Keyword: Police Reform, Challenges, failure of Policing, Corruption
 

Hypothesis:

This research endeavors to delve into the multifaceted challenges confronting the Indian police system and their subsequent implications on societal perceptions and functioning. By examining historical foundations, current operational aspects, and challenges faced, we aim to outline the critical areas necessitating reform. Through an in-depth analysis of key incidents and policy recommendations, we seek to propose viable solutions that can enhance the effectiveness, transparency, and public trust in the Indian police system. Our objective is to advocate for a reformed police system that can address the existing deficiencies and contribute to a safer and more just society.
 
Introduction
The Police Act, 1861 interprets the Word Police shall include all persons who shall be enrolled under this Act; the word “person” shall include a company or corporation;” [2] In common parlance, the term "police" refers to the government agency responsible with maintaining public safety, enforcing the law, monitoring down criminal activity, investigating crimes, and apprehending offenders. An essential component of India's criminal justice system is the police force. The police are essential in the detection and prevention of crime. The primary duty of the police is to uphold law and order, prevent and identify crimes, and bring offenders to justice. Additionally, it is essential for preserving the peace; however, there has been discussion about the effectiveness of the Indian police system for many decades.
 
The Preamble of Police Act 1860 states that” Preamble: - WHEREAS it is expedient to re-organise the police and to make it a more efficient instrument for the prevention and detection of crime;”
 

History of Indian Police System:

India's prevailing police structure has its roots in the British colonial era. In Calcutta, the East India Company established the country's first police force in 1779. (Now Kolkata). This police force's main goals were to uphold law and order, safeguard British interests, and put an end to any uprising or demonstration against British rule. The Revolt of 1857 placed a major role in establishment of police system in India. The British government additionally introduced the Indian Police Act of 1861, which established the rules for the Indian police system. The Superintendent of Police (SP) is the highest-ranking officer in each district, according to the Act, which established a hierarchical structure for police forces.
 
The Indian Police Act of 1861 continued to control India's police force after the country attained independence in 1947. The state governments of those states however, significantly altered the structure and duties of the police forces in various states. Since the police are deemed to be a state subject under Article 246 of the Indian Constitution, state governments, with few exceptions, are responsible for establishing the laws and policies that govern each police force. In simple words, The Indian Constitution, which went into effect in 1950, gave state governments control over maintaining public order and enforcing the law. Because of this, each state in India has a separate police force that is in responsible of maintaining law and order within its borders.
 
The Police Act, 1861:
The British Government passed the Police Act, 1861 on March 22, 1861, prior to India's independence, in an effort to reorganize the police and make it a more effective tool for crime detection and prevention. 47 Sections comprise this Act. Various Sections of the Act enumerate the constitution of the forces under the supervision of the State Government. the powers of the Inspector-General, the appointment, disciplinary action on officers, the power of the Inspector- General to make rules, additional police-officers employed at the cost (sic) of individuals, the appointment of additional force in the vicinity of railway and other works. the quartering of additional police in disturbed or dangerous districts, the awarding of commissions, and the power of the Inspector-General to make The Act also defines the powers of special police officers, fine on refusal to serve as special police officers, authority to be exercised by police officers, village police officers, and police-chaukidars in the Presidency of Fort William. It also provides for police officers to be always on duty and may be employed in any part of the district and to take charge of unclaimed property and be subject to Magistrate's orders as to disposal (sic). A provision that Magistrate may detain property and issue proclamation, confiscation of property if no claimant appears, penalties for neglect of duty, etc. have also been mentioned. The Act also has a provision for the regulation of public assemblies and processions and licensing of the same, powers with regard to assemblies and processions violating conditions of license; provision of punishment for certain offenses like causing a nuisance on roads or cruelty to animals etc.; recovery of penalties and fines imposed by Magistrates; limitation of actions; and other provisions. It also mandates police officers to keep a diary and prescribes the authority of the District Superintendent of Police over village police. The principal Act has been amended from time to time as per the functional requirements.

Functions and Basic working of the Indian Police System:
Functions:
The police system in India has several functions, including maintaining law and order, preventing and detecting crimes, protecting life and property, and bringing offenders to justice. The primary duties of the police are to prevent crime and maintain the peace. According to the 1861 Act, police are responsible for gathering information, bringing offenders to justice, and preventing the commission of crimes and public nuisances harming the public's peace; and maintain order in all public areas while taking into account the evolving political and social climate. Section 57 of the model Police Act states the function of Police.
 
Basic Working of Police System:
1.      The police system in India is responsible for maintaining law and order, preventing crime, and investigating criminal cases. It is a complex system that operates at various levels, including the central, state, and local levels.
 
2.      At the central level, the Ministry of Home Affairs is responsible for formulating policies and providing guidance to the state police departments. The Central Bureau of Investigation (CBI) is also a key agency that investigates high-profile cases and cases involving multiple states.
 
3.      At the state level, the police system is headed by a Director General of Police (DGP) and consists of various units, such as the Crime Branch, Special Branch, and Traffic Police. Each state has its own police force, which is responsible for maintaining law and order within the state.
 
4.      At the local level, police stations are responsible for investigating and preventing crime within their jurisdiction. Each police station is headed by a Station House Officer (SHO) and has several subordinate officers and staff.
 
5.      The police system in India also includes specialized agencies, such as the National Crime Records Bureau (NCRB), which collects and analyzes crime data, and the Rapid Action Force (RAF), which is been deployed in situations such as communal riots or natural disasters.

Hierarchy of state police:

 

 

 
 
 
 
(Sources: Bureau of Police Research and Development; Commonwealth Human Rights Initiative; PRS.)
 

Challenges faced by Indian Police System:

The police system in India faces several challenges; some of the problem and real incident that highlighted the same problems are been enlisted below:
 
Lack of Training:
In Towards Modern and Digital evolving world, one of the most significant challenges faced by the Indian police system is a lack of training with respect to modern Digital crimes. Many police officers are not been adequately trained to handle modern policing challenges, such as cybercrime, terrorism, and forensic investigation. As a result, they may not be able to effectively prevent and detect crimes. There are many initiatives taken by the government to improve the same but this initiative are giving success at a slow rate. However, whereas Crime related to Cybercrimes such as online stacking, identity thief, online fraud etc. are significantly increase every passing days. Due to which a modern training relating to working in today’s digital working is lacking.
 
Inadequate Resources:
Another significant challenge faced by the police system in India is a lack of resources. Many police stations in India are been underfunded and understaffed, which can lead to a lack of basic amenities such as equipment and vehicles. The CAG audits had reported a shortage in several states of weapons with state police forces. Police vehicles are also in short supply. Many Police officers are trying their best to manage with inadequate resources but this can hinder their ability to effectively perform their duties. This Issue is also been the Highlighted issue in two hundred and seven report about police-training, modernization and reforms by Parliamentary Committee report. Government need to increase the spending on Police system for its development in modern world and for its smooth functioning to provide justice.
 
Corruption:
Corruption is a pervasive problem in the police system in India. Many police officers are known to take bribes and engage in other forms of corrupt behavior. This can undermine public trust in the police and hinder their ability to effectively prevent and detect crimes.
 
Overburden Police:
The police force in India is severely understaffed and underfunded, with working conditions for the personnel with long working hours and an enormous workload, which also affects their mental health a lot. This leads to overburdened and overworked police officers who often lack the necessary resources and equipment to carry out their duties effectively. As of January 2016, the state forces had 24% vacancies (5.5 lakh) and the central forces had 7% vacancies. India has 137 police personnel per lakh of the population while the sanctioned strength is 181 and this is very inadequate when compared to the United Nations recommended standard of 222 personnel per lakh people.
 
Public Perception:
According to the Second ARC, people's perceptions of the police are that they are unresponsive, ineffective, corrupt, and politically partisan. Furthermore, the public fears dealing with the police or visiting a police station. In society, there is a negative prospective in eyes of public, which is not correct at certain points. Police officers are required to interact with the public while carrying out their Duties. Additionally, they require public assistance in carrying out their responsibilities, such as resolving crimes and upholding peace and order. It was also one was the Highlighted issue by Parliamentary Committee report, several reforms were also recommended to boot the Public- Police relation.
 
In addition to the aforementioned problems, the police system in India also faces challenges related to modernization and technology adoption. Many police departments across the country still rely on outdated methods of record keeping and investigation, which can lead to inefficiencies and errors in the criminal justice process. There is a need for greater investment in technology and modernization of police departments, including the adoption of digital records management systems and advanced crime analysis tools.
 
In conclusion, the police system in India faces a multitude of challenges, ranging from lack of resources and training to corruption and abuse of power. Issues related to modernization and technology adoption, politicization of the police force, and a crisis of trust further compound these problems. To address these issues, there is a need for significant reforms in the police system in India. This includes increasing funding and resources for the police force, improving training and education for police officers, strengthening anti-corruption measures and enforcement, reducing political interference, and increasing accountability for police officers. Nevertheless, more such reforms are need to improve the police system.
 
Few of Incident that Highlighted Problems in Police system are been mentioned below:
1.      One of the most infamous incidents that highlights the challenges faced by the police system in India is the Nirbhaya case, which occurred in Delhi in December 2012. Nirbhaya, a 23-year-old physiotherapy student, was gang-raped and brutally assaulted by six men on a moving bus in Delhi. She later succumbed to her injuries in a Singapore hospital.The Nirbhaya case received widespread attention in India and around the world, and it led to a massive public outcry against sexual violence against women. The incident also highlighted several shortcomings in the police system in India, including a lack of training, problem related to registration case etc. But, Police System Improved its defect by introduction of Nirbhaya squad, increase in awareness, immediate registration of F.I.R on receiving complain etc.[3] let there is much more improvement needed in police system.
2.      In another incident, the 2019 Hyderabad rape and murder case highlighted similar challenges faced by the police system in India. In November 2019, a 27-year-old veterinarian was raped and murdered in Hyderabad. The police were criticized for their delayed response to the victim's family's complaints, and for their failure to adequately protect the victim, who had parked her scooter near a toll plaza before being abducted. The national Commission accused cops for delayed in response [4]
The incident sparked widespread protests and calls for police reform, with many demanding increased accountability and training for police officers. The government responded by launching several initiatives aimed at improving the effectiveness of the police, including the creation of special units to investigate crimes against women, the introduction of mobile apps to report crimes, and the use of CCTV cameras to monitor public spaces.
However, the incident once again highlighted the challenges faced by the police system in India and the need for continued reform and improvement. The lack of accountability and sensitivity towards victims, coupled with a lack of adequate resources and training, continues to be a major problem, and incidents of sexual violence against women remain a major concern in India.
3.      Another incident that highlights the challenges faced by the police system in India is the 2018 Kathua rape and murder case. In January 2018, an 8-year-old girl from the Muslim nomadic community was abducted, raped, and murdered in the Kathua district of Jammu and Kashmir. The case received widespread media attention and sparked outrage across the country.
The police were criticized for their handling of the case, with many alleging that the investigation was biased due to the victim's community and religion. Constable testifies in court that sub inspector forced him to make backdated entries to mislead probe and that sub inspector didn't deposit victim's clothes in malkhana.[5]. The victim's family had also reported facing threats and intimidation from members of the majority community, and there were reports of police officers trying to destroy evidence and protect the perpetrators. The case also highlighted the challenges of investigating crimes in conflict zones, where there is often a lack of trust between the community and law enforcement agencies. The case was eventually transferred to the Central Bureau of Investigation (CBI), which led to the arrest and conviction of several individuals involved in the crime.The incident led to calls for police reform and the need for improved training and sensitivity towards marginalized communities. However, the challenges of addressing communal tensions and ensuring impartial investigations continue to be a major challenge for the police system in India.
 
Reforms in Police System:
Not every system is perfect, with the course of time; Police System needs several reforms for smooth functioning. In recent years, there have been several efforts made in form of reform aimed at addressing the challenges faced by the police system in India, Here are some of the key Report of various Committee about police reforms that have been implemented or proposed by the government:
 
1.      Reports of the National Police Commission
The National Police Commission (NPC) was established in 1977 to investigate police problems and conduct a thorough assessment of the country's police infrastructure. The NPC dealt with a variety of aspects of how the police functioned. In the National Between February 1979 and May 1981, the Police Commission submitted eight reports. On 1.2.1980, the Lok Sabha received the first report. The central government specifically instructed all state governments and UT administrations to examine the remaining seven reports quickly and take the necessary action before releasing them in March 1983. The National Police Commission's recommendations were implemented by the Central Government by enlisting the help of the State Governments and UTs.At the Chief Minister's Conference on the Administration of the Criminal Justice System, held on November 13, 1992, the major recommendations of the NPC to amend the 1973 Code of Criminal Procedure were taken into consideration. These suggestions were included, among other things, in the Code of Criminal Procedure (Amendment) Bill 1994 that was been presented in the Rajya Sabha. This Bill was approved on April 4, 2005, in the Rajya Sabha, and on September 9, 2005, in the Lok Sabha. A new Bill for the regulation of private security agencies has been since, passed by the Parliament and become an Act. Other significant NPC recommendations for the revision of the curriculum for IPS probationer’s trainees and the expansion of DCPW have already been implemented.
 
2.      Reports of the Ribero Committee
The Government had established a Committee on May 25, 1998, under the leadership of Shri J.F. Ribeiro, IPS, in response to the Supreme Court of India's directives in the case of Prakash Singh
v.        Union of India and others regarding implementation of the National Police Commission's recommendations (Retd.). Two reports from the Ribeiro Committee were filed with the Supreme Court in 1998 and 1999, respectively.The Rebeiro Committee approved the NPC's recommendations with a few changes. On Tuesday, February 10, 2005, the case was heard by the Hon'ble Court, which ordered the Union of India and the relevant State Governments, as well as the NHRC, to submit their responses in response to the directive issued in the Vineet Narain case and the implementation of Rebeiro's Committee recommendations.
3.      Paramvir Singh Saini v. Baljit Singh, Special Leave Petition (Criminal) No. 3542 of 2020:
·         In order for protection of Human Rights of Citizens, Hon'ble Supreme court issued directed to Central & State Government for Installed CCTV system at all police stations, with night vision and audio and video footage.Every police station in the state should have CCTV cameras installed, according to legislators. To make sure that no area of the police headquarters is left exposed, CCTV cameras should be installed at all entry and exit points, the police headquarters main door, lock-ups, all passageways, meeting rooms, Inspector's room, Sub Inspector's room, areas outside the lock-up room, and the station corridor. According to their judgement, a bench ordered the Centre to "install CCTV cameras and recording equipment in the offices of" the CBI, NIA, and NCB. The recording should be set up so that the data is kept for at least 18 months.
·         Large posters should be made outside and inside the police stations, which has to be in English, Hindi and vernacular language stating that they are under CCTV surveillancee
 
4.      DEPARTMENT-RELATED PARLIAMENTARY STANDING COMMITTEE ON HOME AFFAIRS , Submitted its report about "Police - Training, Modernization, and Reforms on February 10, 2022." Several commissions have been established over the past 40 years to look into police reforms. Among them are the National Police Commission (1977), which was presided over by Mr. Dharma Vira, the Committee on Reforms of the Criminal Justice System (2003), which was presided over by Dr. V.S. Malimath, and the Committee on Restructuring of Police (2000, Chair: Mr. K. Padmanabhaiah). Additionally, the Bureau of Police Research and Development (BPR&D) has previously offered a number of suggestions for enhancing the policing system. The Committee's principal observations and suggestions are as follows:
 
A. Police Training
Chapter II states Police Training, the committee noted that anguish that the public image of police throughout the country is more on a negative side. The Committee found that training police officers in the comprehension and application of new technology is necessary in order to alter their behaviour and develop soft skills. The Committee also recommends that the MHA may advise States to sensitize the investigating officers to use relevant provisions under the penal laws while registering a case and precautions be taken during trial to secure conviction. It suggested changing a number of aspects of existing training programs, including adding courses on robotics, drone technology, forensic sciences, and ballistics, emphasising arrest procedures and detainee rights, including updates to laws, and developing training manuals on regional customs of tribal people and other vulnerable groups. MHA may allocate adequate funds and extend necessary resources for the establishment of cyber training labs and strengthening/upgrading of existing cyber training infrastructure in all the States/UTs.It also Recommended the national and State police academies should collaborate and share best practices with each other through online interactions.
 
According to the Committee, effective communication, cutting-edge equipment, and high levels of mobility are essential for effective modern policing. The Committee laments the fact that 143 police stations lack wireless or mobile service, 638 police stations lack telephones, and 257 police stations lack vehicles in the nation. Insensitive states like Arunachal Pradesh, Odisha, and Punjab have police stations without telephones or proper wireless connectivity in the 21st century, which is particularly concerning given that some of these States were rewarded with better performance incentives in the 2018–19 fiscal year. Additionally, a significant number of police posts in Jammu and Kashmir, a Union Territory on a very sensitive border, lack phones and wireless sets.The Committee therefore suggests that the MHA counsel such States to outfit their police stations with adequate vehicles and communication tools right away, lest it result in the Center's unwillingness to provide modernization grants.MHA may make sure that the necessary is done as soon as possible for the UTs.
 
Other Recommendation:
According to the Committee, there are roughly 21% fewer open positions than the 26.2 lakh sanctioned positions in state police forces. Personnel are forced to work longer hours in difficult circumstances, which reduces the effectiveness of the force. It was suggested that the MHA counsel states and UTs to organise police recruitment campaigns as a focused mission and get rid of the administrative bottlenecks for hiring police officers at various levels. Additionally, MHA may assign BPR&D to perform research to identify police duties that can be delegated with the right training. The Committee noted that 31 states and the UT have established Police Complaints Authorities (PCA) to investigate complaints against police officers at the state and district levels. According to the Committee, the PCA should be established independently of the police department. In order to ensure that the PCA has an independent composition, it was advised that the MHA work with the Ministry of Law and Justice and states. Retired senior civil servants, eminent jurists, retired High Court judges, and women should all be represented on the PCA. The Committee also suggested that the MHA give states advice about the need for the internal grievance redressal cell of police to operate in a time-bound manner in order to guarantee that the grievances of wronged police personnel are promptly addressed.
 
Few of Essential Reforms in Indian Police system in are following:
Modernization of the Police: There has been a push in India for increased technological investment and modernization of the police forces. This includes implementing cutting-edge crime analysis tools, digital records management systems, and contemporary communication technologies to enhance police operations and investigations.
 
Promotion of Police Reforms: There is a need for greater promotion of police reforms at all levels of government and society in India. This includes raising public awareness about the importance of police reform, providing training and support for police officers, and creating incentives to encourage police departments to adopt best practices and innovative approaches.
 
Smart Policing: To increase the efficiency of the police, the Indian government has also started a number of projects. Smart Policing is one such effort that aims to use technology to enhance policing. This effort makes use of CCTV cameras to monitor public locations as well as smartphone apps for reporting crimes.Although these reform initiatives are a step in the right direction, much more needs to be done to solve the issues the Indian police department is now facing.
 
Police Recruitment and Training: The Indian government has acknowledged the need for improved police recruitment and training procedures. This includes giving police officers specialized training in disciplines like forensic investigations, human rights, and community policing. To increase diversity within the police force, there is also a focus on hiring more women and candidates from underrepresented groups.
 
Others: There is need of other such essential reforms, which are been recommended by the various committee by time to time such as a specialized system for complaining against police, increasing awareness about police, increasing in the ratio of police per lakhs people etc. The Government need to address such recommendation and work in respect to making such recommendation as reforms in current Police System as soon as possible.
 
Punishment for police when the abuse the power:
1.                  Excessive use of force: If a police officer uses excessive force while carrying out their duties, they can face disciplinary action or even criminal charges under Section 161 of the Indian Penal Code, which prohibits the use of undue influence or threats.
2.                  Custodial violence: If a police officer engages in violence or torture while a suspect is in their custody, they can face criminal charges under Section 330 (voluntarily causing hurt to extort confession) and Section 331 (voluntarily causing grievous hurt to extort confession) of the Indian Penal Code.
3.                  Corruption: If a police officer is found guilty of corruption, they can face disciplinary action, fines, and imprisonment under the Prevention of Corruption Act, 1988.
4.                  Misuse of power: If a police officer misuses their power or authority, they can face disciplinary action or criminal charges under various sections of the Indian Penal Code, including Section 166 (public servant disobeying law with intent to cause injury to any person), Section 167 (public servant framing
5.                  An incorrect document with intent to cause injury), and Section 218 (public servant framing incorrect record or writing with intent to save someone from punishment).
6.                  Sexual harassment: If a police officer is found guilty of sexual harassment, they can face disciplinary action or criminal charges under the Sexual Harassment of Women at Workplace (Prevention, Prohibition and Redressed) Act, 2013.
7.                  Illegal detention: If a police officer detains someone without a valid reason or beyond the legal time limit, they can face criminal charges under Section 342 (wrongful confinement) of the Indian Penal Code.
8.                  Falsifying evidence: If a police officer falsifies or fabricates evidence, they can face criminal charges under Section 193 (false evidence) and Section 195 (giving or fabricating false evidence) of the Indian Penal Code.
9.                  Failure to register a complaint: If a police officer refuses to register a complaint or FIR (First Information Report), they can face disciplinary action and criminal charges under Section 166A (public servant disobeying direction under law) and Section 166B (neglect of duty to apprehend) of the Indian Penal Code.
10.              Use of fake Encounters: If a police officer engages in a fake encounter, i.e., killing a person in cold blood and then claiming that the person was a criminal, they can face criminal charges under Section 302 (murder) of the Indian Penal Code.
11.              Discrimination: If a police officer discriminates against a person based on their caste, religion, gender, or other factors, they can face disciplinary action and criminal charges under various sections of the Indian Penal Code and the Prevention of Atrocities Act, 1989.
12.              Cybercrime: If a police officer is found guilty of cybercrime, such as hacking, data theft, or online harassment, they can face criminal charges under the Information Technology Act, 2000 and the Indian Penal Code.
13.              Offences related to drugs: If a police officer is found involved in drug trafficking or abusing drugs, they can face criminal charges under the Narcotic Drugs and Psychotropic Substances Act, 1985.
14.              Dereliction of duty: If a police officer is found guilty of dereliction of duty, such as neglecting their duty, failing to report an offense, or not taking necessary action, they can face disciplinary action and criminal charges under various sections of the Indian Penal Code and the Police Act, 1861.
15.              Involvement in organized crime: If a police officer is found involved in organized crime, such as running a criminal gang or being a part of one, they can face criminal charges under various sections of the Indian Penal Code and the Maharashtra Control of Organized Crime Act, 1999.
 
Conclusion:
The Indian Police system is not a jellyfish but a multicellular evolving body, one should not forget the all sacrifices that police have in do while performing their duties, there are many defect in Indian Police system but the Government and the police system in itself is trying to reduce such defects. At a various circumstance questioned has been raised against the Indian Police system, but The Indian Police System and The Government had tried to address the same address the same. At various incident, police officers have sacrificed there life has to protect of citizens; one must utmost respected the martyred police officers and their sacrifices towards the nation. According to a 2018 survey of 15,562 respondents across 22 states on perceptions about policing, the Lokniti team at the Centre for the Study of Developing Societies (CSDS) found that less than 25% of Indians trust the police highly (as compared to 54% for the army).[6] There are various recommendation to increase the trust among the police in various reports. No system is truly prefects in the passage of time; every system need to evolve and reduce the defects in course of time, Indian Police System must introduce reform in current working system for its smooth functioning and to cover up its defects and flaw of the Indian Police system.


[1] Cambridge Dictionary, 'Police,' Cambridge Dictionary (last visited September 15, 2023), https://dictionary.cambridge.org/dictionary/english/police.
[2] The Police Act, 1861, Act No. V of 1861 (India)
[3] Times of India, '10 Years of Nirbhaya Case: Policing Up but Long Way to Go,' Times of India (publication date not available), https://timesofindia.indiatimes.com/city/delhi/10-years-of-nirbhaya-case-policing-up-but-long-way- to-go/articleshow/96291487.cms (last visited September 15, 2023).
[4] Mumbai Mirror, 'Hyderabad Rape and Murder Case: National Commission for Women Accuse Cyberabad Cops of Delay in Response,' Mumbai Mirror (publication date not available), https://mumbaimirror.indiatimes.com/news/india/hyderabad-rape-and-murder-case-national-commission-for- women-accuse-cyberabad-cops-of-delay-in-response/articlesh (last visited September 15, 2023).
[5] Economic Times, 'Kathua Rape and Murder: Trail Cop Washed Dress, Concocted Evidence,' Economic Times (last updated: July 17, 2018), https://economictimes.indiatimes.com//news/politics-and-nation/kathua-rape-and-murder- trail-cop-washed-dress-concocted- evidence/articleshow/65030316.cms?utm_source=contentofinterest&utm_medium=text&utm_campaign=cppst (last visited September 15, 2023).
[6] LiveMint, 'India's Police Force Among the World's Weakest,' LiveMint (June 19, 2019), https://www.livemint.com/news/india/india-s-police-force-among-the-world-s-weakest-1560925355383.html (last visited September 19, 2023).

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