lawyers in India

Police Firing - Perceiving the Sovereign Accountability

Written by: Pankaj Bansiwal & Jitendra Bansiwal - student of Gujarat national law & national law Jodhpur
Army Law
Legal Service
  • Injustice somewhere is a threat to the Justice everywhere' -Martin Luther King

    The conduct of the police is an important indicator of the state of governance, and their performance can significantly shape the social well being of nations. What distinguishes, good from bad policing is the commitment to protect the civil and political freedoms of individuals, while helping to create an environment that will maximize the enjoyment of economic, social and cultural rights as well.[1] The price that democracies pay for unreformed and unaccountable policing is high. Overall human and national security is compromised in a global environment often prone to terror without and insurgency within.

    The advent of Indian independence transformed the political system, but the police system retained its colonial underpinnings. The Police Act of 1861 was not replaced. Political control over the police remained intact. Implanting mechanisms to assure accountability of the police to the public it serves did not become a priority, as it should have. The managerial philosophy, value system, and ethos of the police remained militaristic in design, and suppressive in practice[2]. To this day, the police system in India can be characterized as a regime force, which places the needs of politicians or powerful individuals over the demands of the rule of law and the needs of citizens. Throughout the 1960s, many state governments took initiatives to set up commissions to examine the problems of the police and suggest improvements. But in this land in which even the transfer of power from British hands had to be effected at midnight on the advice of the astrologers, it has not yet been possible to find an auspicious time to replace the Police Act, 1861.[3]

    Police firing calls for a way of perceiving need for shift from a regime policing to democratic policing, the narrower and boarder perspectives of accountability, the wider ambit of changes of globalisation and the way the state machinery uses an organ called police to suppress the solidification of people against the policies of the ruling power. Police firing is an issue in all these contexts, lets remember the words of famous Martin Luther King 'Injustice somewhere is a threat to the Justice everywhere'.

    II. Background Issues
    It is painful to observe that, more often than not, the instances of police firings are meted out against the marginalized sections of the society. It will include the farmers of Nandigram, Students of Meghalaya, or displaced farmers of Kalinga Nagar. Another category of victims is closely linked with the Naxalite insurgencies. The Report of the Commonwealth Human Rights Initiative on Police Accountability reinstates the same in a global context. Almost everywhere, minorities - whether ethnic or religious - and vulnerable groups such as the poor and women, experience a more crushing weight of policing.[4] The Report points out concrete data indicating how the minority and weak races and groups are doubly burdened by a biased police force.

    The most 'popular' procedure that follows an incident of police firing is the appointment of an Enquiry Commission under the Commissions of Inquiry Act,1952. Inquiry under the Commission of Inquiry Act, 1952 can not be termed as Judicial Inquiry Commission, just because, incidentally, one sitting or retired judge is appointed as the presiding officer of such commission. Even if presided by a sitting or retired judge such commissions do not possess the power to direct or to punish like a court, nor has it the status of investigating authorities like the police or CBI, which can institute criminal proceedings on the basis of their investigation. The report and recommendation of such 'judicial' commissions are not binding on the government, unlike the order of a court. The depositions by any person before any such commission can not be used as evidence against himself before any court of law. The report of such commissions of inquiry at best can be used as a fact finding report by the government or the concerned public which can form a basis for initiating departmental or criminal proceedings, as the case may be, against any person or official or authority responsible for any act of commission or omission.

    Following the police firing in Maikanch in Orissa in 2000, Justice Misra Commission was appointed. The Action Taken Report (ATR) of the Government placed in the Assembly alongwith the Commission's Report, among other things mentioned that the Commission has justified the firing and that the Commission had not recommended any action against any police officer except to issue the displeasure of Government to Sri Pravasankar Naik , the then OIC of Kashipur Police station , after calling for his explanation and consideration thereof. However, in fact the Commission had opined that the large contingent force with which the Police ventured merely to investigate into an FIR cast the shades of doubt over them. This and other discrepancies in the ATR and the Report on which the former is claimed to have been based show how seriously the Enquiry Commissions are taken.[5]

    Further, the Commissions take so long in filing their reports that their corrective impact is lost. For example, the report of the firings at Poonch which took place on December 2, 1978 and January 5, 1979, was released 16 months later when the public had lost all interest. Ironically, the report justified the firings. Similarly, the report of the inquiry into firings that took place in Kairana and Muzaffarnagar as early as October 1976 was carried by the newspapers nearly four years later in August 1980.

    Apart from the Enquiry Reports, there lies a series of 8 Reports submitted by National Police Commission headed by Dharma Vira and constituted in 1977( Reports being submitted in 1979-1981) having been rendered futile due to the failure to implement them on part of the successive Governments.[6] The PIL filed to demand the implementation of the same resulted in the Supreme Court directives issued in the case of Prakash Singh v. Union of India.

    III. Perceiving The Issue of Accountability

    III.1. The Broader perspective
    In a broader framework, we perceive the sovereign accountability as that towards the society at large, in the context of principles of rule of law and good governance that we claim that the civil society rests on. Democratic governance refers to the management of societal affairs in accordance with the universal principles of democracy as a system of rule that maximizes popular consent and participation, the legitimacy and accountability of rulers, and the responsiveness of the later to the expressed interests and needs of the public… Accountability is a sine-qua-non of democracy because as Benjamin Disraeli rightly reminds us all power is a trust – that we are accountable for its exercise that, from the people and for the people, all springs, and all must exit.

    This accountability is to be enforced not merely at the time of elections but during the life of the government in power. Otherwise democracy will become merely a ritualistic exercise in voting and not a continuous process of democratic governance.[7] Conceived as an end, thus democratic governance would also require that the Police Force, described as the most visible arm of the state's authority[8], reflects the norms and ethos that people perceive as aimed at their common good. When the Police had taken resort to killing against an agitation that could represent the opinion of the larger society in some way, this requirement is far from being fulfilled. Concerning the strategies adopted by the Police to suppress the naxalite insurgencies in Calcutta during the beginning of 1970s, it is said that the brutalities staged in those days created a rift between the common men and police.[9] If attempts to curb extremist operations invoke such a reaction from the people, one can assess to what extent the firings against peaceful masses with lawful objectives can claim public sanction.

    It is soothing to see that the statement of objectives of the Model Police Act drafted by the Committee headed by Soli Sorabji reflects an understanding of these issues at a fundamental level.[10]

    III. 2. The narrower perspective

    The narrower or the legal perspective would tell us how the state being the sole controlling agency over the police would be accountable for their conduct if and when it amounts to a crime. It is imperative to note here that we treat Police and the State as the limbs of the same machinery and also the accountability of police to victims as indirectly having a bearing upon that of the State.

    In the last few years through judicial activism the scope and ambit of the fundamental rights has been widened. The Supreme Court has re-enunciated the "State liability" in case of violation of these rights and thus the age-old British concept of "sovereign immunity" has been eroded.[11]

    III.2.1. The Code of Criminal Procedure

    Section 129 of Cr.P.C. provides for the options available to the police to disperse an unlawful assembly. What this provision has to strike balance against is the constitutional guarantee of right to assemble under Article 19(1)(b) and the right under 19(3)[12]. The section covers 1) an actual unlawful assembly 2) a potentially unlawful assembly. However, in the case of Hanuman v. State[13] it was observed that unlawful character of an assembly has to be determined with reference to section 141 of Indian Penal Code alone and failure or refusal to disperse does not convert a lawful assembly into an unlawful one, failing which use of force over such an assembly would be unjustified. Another requirement is that the officers charged with maintenance of law and order can use only that much force as is necessary for disposal of an unlawful assembly and suppression of riot.

    This principle emerges from the common law. An old judgment of QE v. Subba Naik[14] pronounces that killing can be justified only by the necessity for protecting persons or property against various forms of violent crime, or by necessity of dispersing a riotous crowd which is dangerous unless dispersed. In the absence of these necessities being fulfilled, what an instance of firing can give rise to any offence that it can fall under, committed in the normal circumstance. However, as per section 132, no such prosecution can take place without the sanction of the State Government. We believe this provision suffers from an inherent contradiction, leaving logic at sea. State Government would, more often than not, try to justify the conduct of a force under its control and refusal to give such sanction would be illegitimately legitimizing the actions of the police. Some say a policeman who kills, rapes and blinds is better protected by the State than a judge who may have indicted such a policeman.[15] It must be for these reasons that the Courts have been strict in inviting the prerequisites laid down by section 132 into play. If the Court find that prosecution could not be instituted without sanction, it should not order discharge of acquittal of accused, but should reject complaint. No sanction is necessary when the police officer is not an officer in charge of a police station as his action is illegal; nor when the police officers are charged under ss. 302, 304, 326, 148 IPC etc. but it becomes necessary if they can show that they acted or meant to act under section 129.

    However, the burden of proof lies on the prosecution to prove that the sanction is not necessary when it wants to proceed with a case against a police officer. Whether its necessity exists or not is a mixed question of fact and law.

    III. 2.2. International Principles

    UN Code of Conduct for Law Enforcement Officials requires that "In the performance of their duty, law enforcement officials shall respect and protect human dignity and maintain and uphold the human rights of all persons."It requires the police to uphold the rule of law, ensure the safety of citizens, be responsible, accountable and protect democratic values. When adopted more than 25 years ago, this Code of Conduct laid down three core features of acceptable policing: "Like all agencies of the criminal justice system, every law enforcement agency should be representative of, and responsive and accountable to the community as a whole."

    The United Nations Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (1990) lays down the international standards to be followed while policing unlawful assemblies. Principle 4 of the Police Code of Conduct in India lays down that as far as practicable, the methods of persuasion, advice and warning should be used. If the use of force becomes unavoidable then only the irreducible minimum force required in the circumstances should be used as per Principle 5. Further, Principle 7, most significant in this context makes the Government responsible for ensuring that arbitrary or abusive use of force and firearms by law enforcement officials is punished as a criminal offence under their law. Principle 9 lays down that firearms shall be used against persons to a limited extent, for the purpose of self defence or defence of others against the imminent threat of death or serious injury.

    Principle 14 provides that violent unlawful assemblies are to be dispersed with firearms only when less dangerous means are not practicable and only to the minimum extent necessary. [16] Principle 24 states that Governments and law enforcement agencies shall ensure that superior officers are held responsible if they know, or should have known, that law enforcement officials under their command are resorting, or have resorted, to the unlawful use of force and firearms, and they did not take all measures in their power to prevent, suppress or report such use. Complimenting it, Principle 25 enunciates Governments and law enforcement agencies shall ensure that no criminal or disciplinary sanction is imposed on law enforcement officials who, in compliance with the Code of Conduct for Law Enforcement Officials and these basic principles, refuse to carry out an order to use force and firearms, or who report such use by other officials. These guidelines evidently envisage that accountability should bind the hands that are loaded with more power and not only those who simply take up lathi or gun obeying the orders from their superior officer.

    III.2.3. Compensation and rehabilitation:

    The aftermath question
    One of the impacts of the new approach of the Supreme Court through judicial activism has been that in case of violation of the fundamental rights of the individual it has granted monetary compensation to one who might have suffered unduly or illegally and developed the concept of "public accountability".
    The Supreme Court, in the case of PUCL v. State of Bihar[17], as a working principle and for convenience, gave a direction that in case of police firing, Rs. 20,000/- should be paid for every case of death and Rs. 5,000/- for injured persons, without prejudice to any just claim for compensation. Violation of the right to life under Article 21 was thus sought to be remedied. However, this had been criticized for the compensation would be meager in case of death and also in case of injury to the limbs or eyes, rendering a person incapable of earning his daily bread. [18]

    In Dhananjay Sharma v. State of Haryana[19], a case of illegal detention, regarding the liability of the State, the Court once again reiterated that "the State must be held responsible for the unlawful acts of its officers and it must repair the damage done to the citizens by its officers for violating the infeasible fundamental rights of personal liberty without any authority of law in an absolutely high-handed manner".

    The Scheduled Castes and Scheduled Tribes Rules, 1995 prescribe that when a tribal is killed by a non-tribal, the State has to compensate the deceased tribal's family. This provision thus does justice to the emerging principles of victim-oriented criminal justice and also the state's responsibility to the weaker sections of the society.

    The National Human Rights Commission deserves mention at this juncture. The Commission had taken suo moto cognizance of the incidents in Nandigram and had given two weeks time to the Chief Secretary and DGP for the factual report and has asked them to indicate as to whether any ex-gratia relief has been provided to the next of the kin of the deceased.[20] Regarding an earlier incident on 30 September 2005, as per a report of the State Government, in Meghalaya, following the attempts to disperse an unlawful assembly that resorted to violence the police firings resulted in the death of 11 people. The National Human Rights Commission sought comments from the Chief Secretary, Meghalaya consequent to the State Government constituted a Commission of Inquiry.

    Once the Meghalaya Government informed the Commission that an amount of Rs. 5 lakh each had been paid as a special assistance to the family of those killed in police firing in Tura and Williamnagar districts of the State on 30 September 2005. The State Government also said that this was in addition to the ex-gratia payment of Rs.1 lakh. The Commission was also informed that Rs.10 lakh had been sanctioned by the State Government for meeting the hospital bills of those injured.[21] In view of the appropriate action taken by the State Government with respect to the ex-gratia compensation, the Commission decided that no further intervention by the Commission is called for.

    In another incident, the Commission took cognizance of a complaint of unprovoked lathicharge, firing and pelting of stones by the police on 7th and 8th July-2006 on the villagers of Ghaziabad District who were protesting against acquisition of their farm-lands and habitats in the name of mega development project and a related incident on 17th of September . The Petitioners in this case had requested the commission to send its inquiry team to inquire into the events of 7th & 8th July 2006 and also of 17th September-2006 to fix the responsibility and initiate action against the police officials found guilty. However, it is submitted that initiating action against the police officials found guilty is beyond the power of the Commission. The Commission thus requested the Chief Secretary, UP to furnish, within six weeks, whether any plan had been formulated for compensation and rehabilitation of the persons dislocated from their habitats/lands for mega development projects, and if so, whether any plan had been formulated for relocation and rehabilitation of the persons affected by the acquisition of land for Reliance Power Project.

    Thus it is evident that scope of activities of the NHRC is at ensuring compensation to and rehabilitation of the victims, than rendering the guilty accountable for the mishaps. Hence we conclude that NHRC is not the savior the system awaits.

    IV. Autonomy And Accountability

    On 22 September 2006, the Supreme Court of India delivered a historic judgment in Prakash Singh vs. Union of India instructing central and state governments to comply with a set of seven directives laying down practical mechanisms to kick-start police reform. The Court's directives seek to achieve two main objectives: functional autonomy for the police – through security of tenure, streamlined appointment and transfer processes, and the creation of a buffer body between the police and the government – and enhanced police accountability, both for organisational performance and individual misconduct. The need for reform is particularly acute as the archaic Police Act of 1861 continues to govern policing, despite far reaching changes in governance. Given the gravity of the problem and total uncertainty as to when police reforms would be introduced, the Supreme Court considered in 2006 that it could not further wait for governments to take suitable steps for police reforms and had to issue appropriate directions for immediate compliance. These directions are binding upon governments until they frame appropriate legislation. The Supreme Court required all governments, at centre and state levels, to comply with the seven directives by 31 December 2006 and to file affidavits of compliance by the 3rd of January 2007. State government responses have varied tremendously, ranging from complying in time with the directives through executive orders, to expressing strong objections to the directives and asking the Court to review them. Others have requested the Court to grant them more time to comply with the judgment. On 11 January 2007, the Supreme Court cast away the objections raised and stated that its directions had to be complied with without any modification. The Court granted a three month extension to comply with four of its directives, while stating that the others had to be complied with immediately.

    A number of states have taken the initiative to put in place special committees to draft a new Police Bill and committed to introducing it in the legislature in the coming months.

    The SC's directives are supposedly aimed at weakening the politician-bureaucrat hold over the police. But human rights activists warn that it should be replaced with independent civilian control (UK has the best such mechanism) to prevent further chaos. However, we agree with those who say that given the high numbers of custodial deaths and cases of police brutality, replacing political control with that of toothless agencies will only worsen the situation. Granted that the threat/bribe of punitive or sought after transfers is freely used to demoralise honest police officers and that the political executive sees the police force as enforcer of its own whims and fancies rather than as servants of the public. But it is also true that the police leadership is a willing partner in this game of give-and-take and the police see themselves as answerable to the rulers of the day rather than to the law.[22] Arvind Verma, in his book The Indian Police: a Critical Evaluation, voices the same opinion and states that Politicization of police is the price that paid for the democratic functioning of the Country.[23] He is against the convenient traditional tendency to tarnish the politicians may whatever be the ill that we seek to cure. Moving a step ahead, the Report of the Commonwealth Human Right Initiative Report Police Accountability: Too Important to Neglect, Too Urgent to Delay, even suggests the multiparty oversight over the police by Members of Parliaments, Assemblies and Local Councils. [24]

    V. From Police Force To Police Service

    The constitution of the Police Act Drafting Committee was prompted by the Prime Minister's concern expressed at the Conference of District Superintendents of Police in early 2005 that: We need to ensure that police forces at all levels, and even more so at the grassroots, change from a feudal force to a democratic service[25] True as it remains, it is equally important to make sure that the constitution of the Executive that controls the Police also responds to the spirit of this transformation. Some find the feudal outlook of India's rulers, including Jawaharlal Nehru, responsible for rendering the police system rotten. [26] The model Police Act submitted by the committee does set apart a whole chapter for police accountability (Chapter XIII). However, the definition of 'serious misconduct' allegations regarding which the Police Accountability Commission is empowered to enquire into does not include death in case of Police Firing. The definition covers 'grievous hurt' within the meaning of section 320 and death in police custody. A death in the case of police firing, needless to say, does not fall into either of these categories. Otherwise the success of the Act in this regard needs to be seen in the effectiveness of its implementation and the functioning of the Police Accountability Commission.

    The factors that would help the Police System to transform into a democratic force from regime force are also diverse. In Canada, the combination of a highly diverse population, a liberal rights culture, and decentralised local policing has led to some of the most progressive developments in community policing and local-level accountability. Tightly controlled Singapore has nevertheless developed a trusted and community friendly police. Ironically, the UK, which introduced policing to most Commonwealth countries, has developed a policing model diametrically opposite to the one it left in place in its former colonies.

    Arvind Verma, in his book The Indian Police:

    a Critical Evaluation, suggests replication of successful models abroad as a means to the end of fruitful police reforms.[27]However there are dangers in accepting these models as they are. There is a healthy reluctance to accept first-world models in most parts of the Commonwealth, and sensitivity to the need for policing to respond to specific local conditions.[28] A model that aptly suits the peculiarities of our social system, hence, is indeed needed. Constant interaction between the community and the police will be helpful in reducing the instances of atrocities on the latter's part. The broader perspective of the accountability that we had talked of earlier would be sufficiently taken care of if the Police is accountable to the community and not to their superior officers only.

    Further, the reforms so far talked of deals with police accountability as a broad issue and not with police firing in particular. This statement however does not mean that we choose to overlook the intricate linkages between each of the aspects of the reform pattern that had been suggested by various agencies.

    VI. Suggestions and Observations
    The suggestions with immediate effect that we put forth are:
    1) An offence of unwarranted police firing should be treated as a special offence, punishable with fine too, just the way rape in police custody is.
    2) To see whether a Police Officer has acted in consonance with his powers under section 129, there should be provision for a preliminary enquiry by an independent Agency, following which the prosecution can be launched on any offence that be committed. The current provision that requires the sanction from the Government before launching prosecution shall be removed.

    The guidelines to see whether an instance of police firing had been in conformity with the tests of necessity and proportionality could be:
    1) The proportionality of the size of the police force to that of the gathering that had been sought to be dissolved

    2) The source of the information which led the police to form opinion about the existence, nature, and objectives of the crowd- whether it was one that could be reasonably relied on

    3) Nature of the crowd- whether they were armed or not, whether it was largely comprised of more of female members or not; whether they belong to the mainstream society or not

    4) The nature of the demands put forth by the assembly; or the objectives of the gathering should be carefully scrutinized to see whether there was sufficient reasons for the police to believe that it could turn dangerous.

    5) The time period over which the whole incident occurred; whether the firing was tainted by 'undue haste'.
    We believe the guidelines are required because there are always two sides of a coin, each instance of police firing could be easily termed as another 'police brutality' by uninformed majority of people and the media. However, it is always possible that a police officer had valid reasons to believe that his or the community's safety could be ensured only if the force of the target gathering ebbs out of a bullet wound, since it could not be rendered blunt by a 'lathi'. The existing jurisprudence revolving around section 129 of Cr.P.C.has failed to develop any such principles and the commissions of inquiry that are normally appointed are not capable of throwing any light on these aspects.

    Whether forceful intervention is justified under the "right to protect" or the more imperious "responsibility to protect," the decision to intervene with force should never be made by one country only, for this would be too prone to subjective self-interest, passion, or even vengeance. Rather, intervention needs to be weighed collectively, on a case-by-case basis, starting with the premise of nonviolence, but not employing that as a justification for never taking action, even after all other means of addressing the climate of impunity have been tried to no avail.

    Here another caution is in order. Even ostensibly non-violent actions such as severe economic sanctions can have "violent" albeit not induced by or imposed in support of active combat effects on a population. Arguably, such draconian economic sanctions as were imposed on Iraq after Operation Desert Storm in 1991 could be perceived as a continuation of that war "by other means" and thus have legal and moral implications arising from their indiscriminate effects on masses of innocent Iraqi civilians.

    Legally, there seem to be two questions: "Can economic sanctions imposed by an international organization (regional or the UN) to compel or dissuade actions by a country constitute a state of war?" If a state of war does exist, "At what point, if any, does the toll from economic sanctions constitute a 'war' crime?"

    Morally, the issue is clear. Economics, if it ever did, no longer exists as a separate discipline. In fact, until the end of the 19th century in the same time-frame in which the laws of warfare were being formulated there really was not a discipline called economics separate from politics (and its extension, war) and the view of what constitutes a just and compassionate society. Even Adam Smith thought of himself as a moral philosopher.

    [1] Maja Daruwala and Clare DoubePolice(Ed) , Police Accountability: Too Important to Neglect, Too Urgent to Delay, Commonwealth Human Rights Initiative, New Delhi, 2005, p.3
    [2] Last viewed on 25/05/2007
    [3] Madhav Godbole, " Police Reforms: Pandora's Box No One Wants to Open", Economics and Political Weekly March 25, 2006 at 1176
    [4] at p. 7, Chapter 1 of the Report Last viewed on 25/05/2007
    [5] Sri Biswapriya Kanungo, Maikanch Police Firing and Misra Commission Report- A Misleading Exercise, last viewed on 23/05/2007
    [6] A G Noorani, Police and the Constitution, Economic and Political Weekly March 25, 2006, p. 1163
    [7] Dr. Justice A.S.Anand, the then Chairperson, NHRC in the Inaugural Address at Seminar on Human Rights Sine-Qua-Non of Democratic organized by Merchants' Chamber of Commerce at Kolkata on 8th September 2006
    [8]Police Overhaul: Courts and Reforms, Economic and Political Weekly, May 7, 2007, p. 1584
    [9]Ashoke Kumar Mukhopadhyay, Through the Eyes of the Police: Naxalites in Calcutta in the 1970s, Economic and Political Weekly July 22, 2006, p. 3277
    [10] Preamble of the Act reads- WHEREAS respect for and promotion of the human rights of the people, and protection of their civil, political, social, economic and cultural rights, is the primary concern of the Rule of Law; AND WHEREAS, it is the constitutional obligation of the State to provide impartial and efficient Police Service safeguarding the interests of vulnerable sections of society including the minorities, and responding to the democratic aspirations of citizens;AND WHEREAS such functioning` of the police personnel needs to be professionally organised, service oriented, free from extraneous influences and accountable to law; AND WHEREAS it is expedient to redefine the role of the police, its duties and responsibilities, by taking into account the emerging challenges of policing and security of State, the imperatives of good governance, and respect for human rights; AND WHEREAS it is essential to appropriately empower the police to enable it to function as an efficient, effective, people-friendly and responsive agency;NOW, THEREFORE, since it is necessary for this purpose to enact a new law relating to the establishment and management of the Police Service, it is hereby enacted as follows

    [11] Dr Paramjit S. Jaswal, Public Accountability for Violation of Human Rights and Judicial Activism in India: Some Observations, (2002) 3 SCC (Jour) 6
    [12] Cf. Himatlal v. Police Commissioner, AIR 1973 SC 87
    [13] AIR 1969 All 130
    [14] 1898 ILR 21 Mad 249
    [15] Police Firings- Aimed to Quash Protest, PUCL Bulletin, 1981 from last viewed on 20/05/07
    [16]Basic Principles on the Use of Force and Firearms by Law Enforcement Officials, Adopted by the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, Cuba, 27 August to 7 September 1990. downloaded at visited on 22/05/2007
    [17] (1987) 1 SCC 265
    [18] Dr Paramjit S. Jaswal, Public Accountability for Violation of Human Rights and Judicial Activism in India: Some Observations, (2002) 3 SCC (Jour) 6
    [19] (1995) 3 SCC 757
    [20] last visited on 21/05/07
    [21] last visited on 21/05/07
    [22] Police Overhaul: Courts and Reforms, Economic and Political Weekly, May 7, 2007, p. 1584
    [23](Regency Publications, 2005) at p. 171 cited from K S Subramanian, Reforms For Indian Police, Economic and Political Weekly, March 25, 2006 p. 1185
    [24] at p.33
    [25] last visited on 25/05/07
    [26] Kirpal Dhillon, Police and Politics in India, Colonial Concepts and Democratic Compulsions, (Manohar, 2002) cited from A G Noorani, Police and the Constitution, Economic and Political Weekly March 25, 2006, p. 1164
    [27] (Regency Publications, 2005) cited from K S Subramanian, Reforms For Indian Police, Economic and Political Weekly, March 25, 2006 p. 1184
    [28] Maja Daruwala and Clare DoubePolice(Ed) , Police Accountability: Too Important to Neglect, Too Urgent to Delay, Commonwealth Human Rights Initiative, New Delhi, 2005, p. 8

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