This Article is written by Achal Dhanpal Gedam, a Fourth Year Law Student of Manikchand Pahade Law College, chpt. Sambhaji Nagar

ABSTRACT:

Police brutality in India is a squeezing issue that reflects a systemic disappointment inside the Indian police framework. This thesis dives into the unavoidable nature of police wrongdoing, counting unlawful detainments, manhandling, and torment, highlighting that these hones are not separate occurrences but profoundly imbued inside the framework. It emphasizes that tending to police brutality requires more than fair ascribing it to a few “bad apples” but requires a comprehensive change of the whole framework. Past the quick physical hurt caused, police brutality damages principal human rights and dissolves belief between law requirements and the open. The thesis examines occasions of police brutality, analyses responsibility instruments, and prescribes ways to anticipate infringement and improve police responsibility. Investigate questions investigate the impact of race and ethnicity on encounters of police brutality, the impacts on casualties, legitimate cures accessible, societal results, the viability of preparing and arrangements, and worldwide approaches to tend to this issue. The theory sets those police brutality adversely influences people, abusing their rights and cultivating fear and doubt. Through a quantitative strategy including writing examinations and media reports, this consideration looks for to give experiences into the complex flow of police brutality in India.

Introduction:

The beginning of the word “police” can be followed back to the Latin term and Old Greek word “politia”. The Indian Structure incorporates all imperative angles like human rights, laws to anticipate major violations, etc for social soundness. Human rights incorporate rights to correspondence, the right to flexibility, the right against abuse, the right to flexibility of religion, social and instructive rights, and the right to protected cures. To make our country quiet and crime-free, the legal was set on the right track. The suggestion of law and citizens’ assurance was given in the hands of the police. India, being a union of 28 states and 8 union regions and ‘Police’ falls under List II of the 7th schedule under article 246 of the Structure, which is State List. The Police Act 1861 characterizes the term “police” in section 1, it peruses that the word “police” will join all the individuals who will be chosen under this act. The police are the gracious drivers of a state that is mindful of keeping up with laws and arrangements in society. It acts as a major interface in the lawful chain framework as it shields states from violations and maintains the rights of citizens. But with all that the police moreover got a terrible notoriety among common individuals for abusing their control and utilizing their regalia to spread fear instead of a positive security vibe in society. One of the reasons behind police brutality may be the nonappearance of anti-torture enactment in India. The auxiliary reason incorporates a need of mindfulness among citizens around their rights. We, as a society, in some way or another too fizzled in our obligation.

History:

The roots of brutality by powers and armed forces go way in history. It’s as ancient as our history itself. The Lord and Head utilized to have armed forces for the assurance of their realm and its individuals but the same armed forces too utilized to panic them. The police framework has come a long way, from the times of Kautilya to the Mughals to the Britishers, it has advanced and changed. In history, illustrations sometime recently the British Period won’t be specified as the situation was distinctive and the Lord or Ruler was treated as a divine official. Today’s police framework is closest to the British police framework. The “Khaki” as we see it nowadays is to some degree the same nowadays as well, not fair colour or uniform but propensities as well driven from there. After all, officers working in the police office of the British period were Indians as it were. The Police Act of 1861 was too passed by the Britishers as it were. It was amid the British run the show that respectful and criminal courts were defined and Faujdari Thanas and Chowkies were made, we still call police stations by these names in India. Under the British Raj, police were known for spreading fear among individuals. Physical torment of third-degree was commonly utilized on individuals who raised their voices against Britishers third-degree torment incorporates electric stuns, hitting private parts, putting hot irons over a human body, beating, and applying salt over the wounds of the blamed, and whatnot. Individuals had to go through this cruel treatment and slave work indeed in the correctional facilities of the British Raj, the Andaman and Nicobar Cellular Imprison is one example. These strategies still exist even though they are not commonly utilized presently “until required”.

Jillian Wala Bagh's slaughter, which happened on 13 April 1919, is a prime illustration of police brutality. In which 380 passed on and a few students of history think passings were possibly over the specified number and numerous harmed. All this was done on orders of Common Dyer, who did it on reason to set an “example” for other Indians. Indeed, sometime recently, in 1895, the Ganesh Visarjan parade passed from the region of the Sai Masjid in Ancient Dhule Township, Maharashtra, where communal squabbles between Hindus and Muslims followed. To control the revolt, police opened fire on a swarm in which numerous got slaughtered and injured. That sanctuary indeed presently is known as “Khooni Ganpati”.

Post Independence, the first police brutality illustration was the Angamaly terminating, which occurred on 13 June 1959, in which 7 individuals were slaughtered and numerous harmed in police firing. The all-inclusive Statement of Human Rights (UDHR) was formally embraced in 1948. The Universal Pledge on Gracious and Political Rights came into constrain in 1976. This was one of the to begin with steps, after India’s freedom toward the assurance of Human Rights.

Police Brutality and Human Rights in India:

After Freedom, all this proceeded and indeed to this day, the police constrain is known for its outrages and brutalities, against suspects, undertrials, and prisoners. A few are captured or brought without warrants to the police stations. Cases related to police brutality can be seen around the world but this paper centers on India as it were as the degree of brutality by police strengths is most noteworthy here, over the world. The suspects or prisoners are now and then minors, ladies, or elderly individuals, but indeed they have to go through torment in police guardianship. The most noteworthy number of custodial passings was detailed in Andhra Pradesh which was 27. India was too one of the nations that marked the Widespread Announcement of Human Rights and agreed to two pledges by storing the instrument in 1979.

In 1993, the Viena affirmation and program of activity ‘Human Rights and Essential flexibility are Inheritance of all Human Beings’ Human Rights Commission was established beneath the Assurance of Human Rights Act,1993, to hold the police responsible in any case of unfortunate behaviour. But the issue with NHRC was that it was great for collecting information and inquiring about it but was a frail body and was as it were with “recommendatory powers”. The law does not donate any control to NHRC to ask for complaints of human rights infringement against police. It was made to collect reports and a few times Central government has denied information given by NHRC. The commission has no authoritative specialist and it cannot uphold its choices. But this information is moreover not redressed as in rustic regions individuals are not mindful of their rights and most states have not set up a commission in their states.

The Indian National Congress built up the National Police Commission. The work of this commission was to audit the police framework and make a modern, new police framework, as both a law requirement organization as well as a defender of the rights of citizens. The primary assignment of this commission was to prescribe measures and courses of action concerning the abuse of powers by police and the abuse of police by lawmakers. From the year 1979 to 1981, this commission submitted 8 reports which were never taken into thought by the government. In its reports, the NPC recommended setting up the “Criminal Equity Commission”, partitioned wings of examination for in reverse social orders such as planned tribes and planned castes. It too proposed that no individual should be bound in any bailable offense until requested by the court. NPC moreover proposed that the working of the police constrain ought to be straightforward. The final report recommended expelling the assurance given to police beneath segments 132 and 197 of the Code of Criminal Methods of 1973 (CrPC).

An Overview Of Police Brutality in India:

India being the world’s greatest law-based nation, gives human rights to each citizen[1]. The Structure of India, Part-III contains principal rights that were the result of the All-inclusive Statement on Human Rights marked by India on January 01, 1942. The six essential rights include:

● Right to Equality

● Right to Freedom

● Right against Exploitation

● Right to Flexibility of Religion

● Cultural and Instructive Rights

● Right to Protected Remedies

The reason for a state is to secure the freedom of a person. In any case, when it comes to police torment, our society and government have appeared to be concerned about the principal rights. The police faculty is purportedly the essential guilty party when it comes to human rights. This all began with the British Raj and our police are proceeding with it despite they are presently the defenders of citizens and are not in uniform to smother voices and utilize physical control to halt individuals from going against the government. Offense and getting into mischief aren’t as they were done with wrongdoers or individuals charged with doing something unlawful but too with common individuals who have done nothing off-base. Cases of this can be seen on activity signals- and, at checking focuses and, indeed as of late amid Crown and Farmer’s dissents.

Even though, there is a Human Rights Commission in India, the as it were thing it does is to observe such cases and issues and to keep information. It has not given any control separated from that. Be that as it may, no law has ever been able to settle any issue on its claim. For the security of citizen’s human rights, collective and deliberateness activity is required so that individuals of this nation can be secured from police brutality. Police brutality isn’t something that exists in India, it’s an around-the-world issue, and in the year 2021, UN specialists called for a conclusion to police brutality around the world and cautioned the US of the grave threat emerging from such manhandling of Human Rights and the run the show of law. As the Human Rights Committee has recognized “public certainty in the police and other law authorization authorities is fundamental for their capacity to perform their work viably and depends on, connect alia, their regard for the human rights, principal opportunities, and human nobility of all persons”. In this way, this appears that Police Brutality still exists and it requires to be pointed out and changed. India needs modern police changes to spare thousands of citizens from getting their human rights abused and for police responsibility for offenses. The current policy framework is working more for the capable and degenerate lawmakers than for the citizens. Police regularly surpass their limits and encroach on the human rights of guiltless civilians intentioned.

Law Commission on Police Brutality:

Law Commission[2] Recommended to the government that section 114B should be embedded in the Indian Evidence Act of 1872. Area 114B gives for the indictment of police officers for harm to an individual in guardianship and if such damage is caused amid police care at that point it’ll be assumed that harm is caused by the police. It moreover prescribed that a therapeutic examination of the captured ought to be done by the specialist. In its 152nd report, the Law Commission made a few suggestions to diminish custodial savagery. It was suggested that Sec. 41 (1A) of IPC, that capture must be authoritatively recorded and embedded in area 50A so that police can educate the family or relatives of the individual captured.

It moreover proposed embeddings Sec. 197 (1) which was “When any individual who is or was a Judge or Officer or an open worker not detachable from his office spare by or with the endorse of the Government is blamed of any offense affirmed to have been committed by him whereas acting or implying to act in the release of his official obligation, no Court should take cognizance of such offense but with the past sanction”. Numerous other proposals incorporate correction in CrPC, remuneration in case of police outrages, and compelling instruments for the assurance of complainants and victims.

Over 11,000 complaints of human rights infringement by police have been recorded with the National Human Rights Commission (NHRC) in 2020-21 so distant with Uttar Pradesh (UP) topping the list of bookkeeping for around 48% of the add-to complaints.[11] UP accounted for 5,338 in 2020-21 as of January 15 to beat the list of lowness taken after by Delhi (940), Tamil Nadu (575), Assam (562), and Haryana (408) at a remove. Karnataka had 175 such cases during this period. The add-up to cases managed by the Examination Division of NHRC from April 2019 to Walk 2020, which incorporates Police/Judicial custodial passings and fact-finding cases is 8019[12]. This information appears that there is a clear infringement of human rights that going on indeed right now in this nation and this is concerning. If indeed after 76 a long time of Autonomy, individuals still are confronting these issues that implies there is something that needs to be changed in this framework.

Right Conferred to a Person Under the Indian Constitution:

These rights are exceptionally basic for a captured individual[3]. Three articles in the Indian Structure talk about the security of an individual concerning the conviction, etc. They are:

Article 20: This article of the Indian Structure talks about security to an individual regarding conviction of offenses. It gives for three rights, specifically, ex-post-facto law (where an act, when committed, is not an offense, but afterward made an offense, the individual is not obligated to be rebuffed), Twofold risk (No individual might be rebuffed for the same offense twice), the right against self-incrimination (No individual might be compelled to witness against himself).

Article 21: This article of the Indian Structure gives for the Right to life and individual freedom, and it incorporates different rights such as the Right to security, the right to free lawful help, the right against open hanging, the right against cuffing, the right against postponed execution, etc. Articles 14, 19, and 21 of the Structure are alluded to as “the brilliant triangle”. The right to life and individual freedom is a pivotal right given to the citizens of India. Any individual can start a continuation in the Court if his right to life and individual freedom is encroached upon and approaches the High Court or the Supreme Court. In the case, Raghbir Singh v. State of Haryana (1980), the court in the moment case expressed those police torment is a despicable act done by the gatekeepers of the society, and it is not as if it were a wrong act but moreover ruins human rights ensured under Article 21 of the Indian Constitution.

Article 22: This article of the Indian Structure talks about different rights of a captured individual or charged, to be specifically illuminating of the grounds of capture, the right to be delivered sometime recently a judge within 24 hours, the right to be protected by a legal counsellor of his choice, right whereas he was captured beneath PD Act, 1950 (he might not be kept in guardianship for more than 3 months without a competent court’s endorsement).

Important Provision Related to the Rights and Powers of Police Officials:

Various arrangements give for the rights and powers of the Police, their rights are conferred in the Code of Criminal Strategy, 1973, the Indian Prove Act, 1872, and The Police Act, 1861.[4]

CrPC, 1973 The Code of Criminal Method, 1973 is a comprehensive procedural law.[5] Managing the method for the direction of criminal trials in India. Beneath CrPC, we have different arrangements managing the rights and powers of the police. They are

Section 41: This area is secured beneath Chapter V of the CrPC (capture of an individual) and the area talks about the occurrences where a police officer may capture without a warrant. Beneath this Segment, a police officer can capture an individual to prevent him from committing assist offenses upon sound data, or when an individual commits a cognizable offense in his presence.

Section 41A-D: These segments bargain with the take note of appearance to an individual, the strategy of the capture of an individual, control rooms, and recording of data and moreover unequivocally say the capacity of the recorded data for 18 months, rights of a captured individual to meet an advocate of his choice amid cross-examination, and not all through the course.

Section 129,130: These Segments are secured beneath Chapter X of CrPC, they bargain with the dispersal of together by utilizing gracious drive on the arrange of a competent individual, and the utilization of equipped strengths to scatter assembly.

Section 151: This segment bargains with capture by a police officer to avoid the commission of a cognizable offense and the confined individual must be delivered sometime recently to a Judge within 24 hours of his detention.

Section 154: This area bargains with data in cognizable cases. Beneath this Segment, any verbal complaint must be diminished to composing and if the offense falls beneath sections 354, and 376 of IPC, the data being recorded must be by a lady police officer.

Section 161: This area bargains with the examination of witnesses by the police where the witness must reply to all the questions posed by the police officer. The Area too says that an offense falling beneath Sections 354, and 376 of IPC must be recorded as it were by a lady police officer.

Under the Evidence Act, of 1872:

Section 25: Under section 25, any confession made to a police officer is considered unimportant and it might be forbidden as evidence. In Narayan Rao v. State of Andhra Pradesh (1957), the court held that a confession made to a police officer rises to in title or position as an Officer should moreover be considered unacceptable.[6]

Section 26: This area talks about how any confession made to an officer should be not permissible in a court unless it is done in the nearness of a Magistrate.

Section 27: This segment talks about if a charge confesses a reality, that leads to a revelation of modern truths, the confession might be regarded as permissible in a court of law. In Damodar Prasad v. State of U.P (2019), the Honourable Allahabad High Court expressed that the confessions made forbidden beneath Section 25, if lead to a disclosure of unused realities, should be allowable beneath this Section.

Section 28: This area lays down that if the impression of the confession made was that it was gotten using risk, affectation, or guarantee, once it is completely expelled, the confession might be regarded as significant to the Court. In Abdul Razak Shaikh v. State of Maharashtra (1987), the Bombay High Court ruled that if the impression of risk or actuation is completely evacuated, it might be said as a substantial confession.

Police Act, 1861:

Section 29: This area talks almost savagery by police officers on an individual in care, and the officer might be obligated for a punishment or detainment not surpassing three months.

Section 31: This area talks about the obligation of a police officer to keep up peace and arrange on open roads/streets/places. Resisting an arrangement of a police officer should result in a fine not surpassing ₹200.

Section 34: This area engages a police officer to take into care any individual without a warrant if he commits any of the acts said in the eight clauses. These offenses incorporate butchering cattle, hindering travellers, obscene introduction, and being found inebriated, and crazy.

Section 43: This segment secures acts done beneath a warrant marked by a Judge. These laws give for major powers of police and their rights while performing their obligation. Where a few rights donate clear inconclusive security to police, a few too abridge the security given by law. It is similarly vital to examine the rights of an individual concerning conviction to get it police brutality.

Landmark Cases:

Rudul Shah vs. State of Bihar (1983):[7]

In this case, the solicitor was confined for over 14 a long time after his quittance by the Court. The solicitor looked for a stipend for his unlawful detainment. The Incomparable Court ruled that the detainment was entirely unjustified and requested the Bihar Government to pay a whole of ₹30,000 and ₹5,000. Joginder Kumar v. State of UP (1994) In this case, the realities were that the applicant, a legal counsellor, was confined illicitly after he was called for addressing by the police officers. When the family individuals of the solicitor enquired about his whereabouts, the police lied about his area. The Court held that the detainment was illegal.

D. K. Basu v. State of UP (1994):

In the case of D.K. Basu[8], the Supreme Court recognized custodial viciousness and police brutality. The Apex Court expressed that “Custodial savagery is an assault on the nobility of an individual”. The Court in this case gave a few rules to be followed by the police when capturing an individual.

● Police staff are to bear title labels with assignments when capturing or interrogating.

● A capture reminder is to be arranged and a duplicate of the same is to be validated by a family part or any individual respectable in the region. The reminder must comprise of the date and time of capture and the same might be marked by the arrestee.

● Where, at the time of capture, no family part is shown, he should educate a companion, relative, or any other individual interested in his welfare almost the capture and area of his detention. The individual captured should be made mindful of his right to educate somebody about his arrest.

● A section is to be made in the journal of the concerned police station, which

● incorporates the date and time of capture, the individual educated of his capture, and a list of police officers who had guardianship of the arrestee.

● All the wounds on the arrestee are to be recorded at the time of capture and should be marked by the arrestee and the police officer. A therapeutic examination of the arrestee is to be done every 48 hours by a specialist amid the detention.

● All the duplicates of archives are to be sent to the Magistrate.

● The police control room of the concerned locale is to be made mindful of the capture within 12 hours

Prakash Singh v. Union of India and Ors (2006):

In the moment case, Prakash Singh[9], the solicitor who served as the Executive Common of Police in the State of UP, post his retirement recorded a Public Interest Litigation Case in the Supreme Court looking for policy changes. The Apex Court gave required arrangements to be taken after by each State and Union Region, they are

● A settled residency for the post of DGP (Chief Common of Police), IG (Examiner Common of Police).

● To Protect police from political impact, the Court coordinated for foundation of Police Foundation Sheets (PEB), the body should have the control postings and exchange police.

● Establishment of a State Police Complaints Specialist (SPCA), where common individuals abused by the administrations of the police, can approach the forum.

The mandates given in this case by the Summit Court were not completely complied with by any state, but 18 states have revised or passed their Police laws to advance toward the headings given by the Summit Court.

Paramvir Singh Saini v. Baljit Singh & Ors (2020):

In this case[10], the solicitors recorded an Extraordinary Take-off Appeal arguing with the Court to check and issue headings concerning the establishment of Closed-Circuit cameras in the police stations. The Supreme Court coordinated states to introduce observation cameras in the D.K. Basu case and the Shafhi Mohammad case, but it was not made essential by the Pinnacle Court. The Apex Court in this case gave orders comprising a few rules and guidelines:

● An oversight committee to be set up at local and state levels.

● State Human Rights Commission to be set up in each State. The positions are to be filled as and when an opportunity arises.

● Every police station has reconnaissance cameras with night vision and sound recording capability.

● The areas of CC cameras must incorporate all passages, exits, ways, lock-ups, and all other ranges so that no range is cleared out exposed.

● The film is to be kept accessible for 18 months.

● The region ought to be educated about the nearness of CCTV in the station, and the police ought to make any doubt that blurbs specifying that they are beneath CCTV camera observation when they are in the police station.

● Allocation of legitimate and adequate reserves by the budgetary offices of the Middle and States to guarantee that the orders are taken after

Accountability Measures:

The by and large legal framework is fortified by responsible policing, which ensures that everybody is treated similarly and in compliance with the law. Police responsibility and changes are essential components of a law-based society that values equity, openness, and the guard of personal rights; they go past basic authoritative procedures. Some of the measures are[11]:

● Making the police a Shrewd force: The Indian police drive must end up strict and delicate, advanced and portable, alarm and responsible, solid and responsive, tech-savvy and prepared. Various things appear that when police officers treat individuals with regard, permit them a voice in intuitive, and carry on taking after standards of straightforwardness and responsibility, individuals are more likely to comply with the law, which decreases the probability of crimes.

● Use of Body Cameras: Body-worn cameras can aid police officers keep an objective record of their intelligence with citizens, which can serve as fundamental proof in case of any examinations and hold both parties responsible and dependable for their conduct. The Prakash Singh rules, issued by the SC of India, advocate the utilization of body cams.

● Oversight committees: The Show Police Act advances setting up free civilian oversight committees which can give an outside point of view on the conduct of the police drive. These committees made up of community pioneers or agents, keep an eye on and assess police activities to make beyond any doubt comply with ethical and legitimate requirements.

● Training on Morals and Instruction: Advancing a responsibility culture inside police authorization requires progressing preparation on moral conduct, human rights, and community relations. It gives officers the understanding and capacity to react to circumstances suitably and competently.

● Set up Police Complaints Specialist: Taking after the Incomparable Court, an autonomous specialist must be set up to bargain with and explore the complaints of police offense. The Demonstrate Police Act of 2006 notices that each state must set up a specialist comprising of resigned tall court judges, police officers, and open directors from another state.

Recommendation by NHRC:

The National Human Rights Commission made different suggestions for policy changes. They are [12]

● Insulating the police specialists from political weights to secure reasonable administration.

● Setting up of a body called the Police Security and Astuteness Commission (PSIC) at a state level to guarantee the change of the quality of police and to arrange cases where the officers are subjected to unlawful orders by superiors.

● Constitution of a modern non-statutory body called “District Police Complaints Authority” to bargain with the complaints of the open relating to manhandling of control by

The Need for Transparency: Transparency is vital for building open belief in police operations. Open decision-making nature certainty that the law is connected decently. Accomplishing straightforwardness requires holding law authorization responsible, cultivating moral conduct, and empowering citizen engagement. In police change endeavours, straightforwardness encourages open inclusion. Educated citizens can advocate for fundamental changes. Straightforwardness helps in pinpointing zones that require police hone and approach changes, recognizing deviations from planning strategies and tending to inclinations. This guarantees that rules are taken after as aiming and advance reasonableness and equity in law authorization, eventually upgrading results and open belief.

Community Engagement:

Community engagement altogether improves police change endeavours by cultivating belief, understanding, and neighbourhood understanding. Effectively including communities gives profitable information about their particular needs and needs. This data empowers law authoritarians to tailor their methodologies and strategies to address community-specific issues successfully. Besides, community interaction makes a stage for open discourse and criticism, permitting individuals to voice concerns, report wrongdoing, and propose advancements to policing methods, advancing accountability.

Furthermore, civic engagement makes a difference in constructing positive connections between the police workforce and citizens. Officers who effectively lock in with their communities end up receptive and reliable accomplices, driving them to make strides in communication and more effective wrongdoing avoidance and determination. Eventually, community inclusion drives comprehensive, people-cantered approach changes, underscoring the significance of collaboration between law authorization and the communities they serve. It too strengthens a shared duty for security and security, reinforcing the general adequacy of policing endeavours.

Conclusion:

After freedom, India has come a long way and has made numerous changes concerning the police division and its work. But still has a long way to go. Police brutality has been displayed since pre-independence and most of the cases related to police authorities abuse human rights or sacred rights. Despite a few recommendations by diverse Hon’ble Courts as well as committees and information by handfuls of organizations, no major changes have been made that can halt police brutality. The proposal made by the Pinnacle Court, the Prakash Singh case, was not involved on the ground level, and the Equity Thomas Committee, whereas working on this “expressed alarm around the add up to lack of interest to the issue of reforms” shown by the States. The greatest issue here is that most of the information that is given by police in police brutality cases cannot be trusted so that needs to be changed. The laws and statutes administering the police give insusceptibility to them and this limits the scope of casualties as resistance will spare policemen from detainment.

References:

1. Indian Evidence Act, 1872. (Sec 25,26,27,28)

2. The Code of Criminal Procedure, 1973. (sec 41,41A-D,129,130,151,154,161)

3. The Police Act, 1861. (Sec 29,31,34,43)

4. Koushik Chittella, “Role of Constitutional Courts in Cases of Police Brutality” blog. Leaders.in “https://blog.ipleaders.in/role-of-constitutional-courts-in-cases-of-police-brutality/” accessed on April 27, 2023

5. Diljinder Singh, Dr, Shailja Thakur, “Police Brutality in India: Critical Analysis from a Human Rights Perspective.” Whiteblacklegal.co.in https://www.whiteblacklegal.co.in/details/police-brutality-in-india-a-critical-analysis-from-a-human-rights-perspective-by---diljinder-singh-dr-shailja-thakur (No Date)

6. Anurag Tiwari, “The Unlawfulness of Police Brutality in India” theleaflet.in, “https://theleaflet.in/the-unlawfulness-of-police-brutality-in-india/” accessed on October 26, 2021

7. DRISHTI IAS BLOG, “Police Reforms and Accountability”, dristiias.com, “https://www.drishtiias.com/blog/police-reforms-and-accountability” accessed on Nov 21, 2023.

8. Law Commission of India, “Implementation of ‘United Nations Convention against Torture and other Cruel, Inhuman and Degrading Treatment or Punishment’ through Legislation” Report No 273, [D.O.No.6(3)314/2017-LC(LS)], accessed on October 2017.

9. Rudul Sah vs State of Bihar and Another (August 1983) 4SCC 141 https://indiankanoon.org/doc/810491/

10. Shri. D. K Basu, Ashok K, Johri vs State of West Bengal, State of UP on 1997 (1) SCC 416 https://indiankanoon.org/doc/501198/

11. Prakash Singh & Ors vs Union of India & Ors on 22 September 2006 Case No: Writ Petition (civil) 310. https://indiankanoon.org/doc/1090328/

12. Paramvir Singh Saini vs Bljit Singh on 2 December, 2020.1 SCC 184. https://indiankanoon.org/doc/88573149/
    
    

[1] Anurag Tiwari, “The Unlawfulness of Police Brutality in India” theleaflet.in, “ https://theleaflet.in/the-unlawfulness-of-police-brutality-in-india/ ” accessed on October 26, 2021

[2] Law Commission of India, “Implementation of ‘United Nations Convention against Torture and other Cruel, Inhuman and Degrading Treatment of Punishment’ through Legislation” Report No 273, [D.O.No.6(3)314/2017-LC(LS)], accessed on October 2017.

[3] Koushik Chittella, “Role of Constitutional Courts in Cases of Police Brutality” blog.ipleaders.in “ https://blog.ipleaders.in/role-of-constitutional-courts-in-cases-of-police-brutality /” accessed on April 27, 2023

[4] The Police Act, 1861. (Sec 29,31,34,43)

[5] The Code of Criminal Procedure, 1973. (sec 41,41A-D,129,130,151,154,161)

[6] Indian Evidence Act, 1872. (Sec 25,26,27,28)

[7] Rudul Sah vs State of Bihar and Another (August, 1983) 4SCC 141 https://indiankanoon.org/doc/810491/

[8] Shri. D. K Basu, Ashok K, Johri vs State of West Bengal, State of UP on 1997 (1) SCC 416 https://indiankanoon.org/doc/501198/

[9] Prakash Singh & Ors vs Union of India & Ors on 22 September, 2006 Case No: Writ Petition (civil) 310. https://indiankanoon.org/doc/1090328/

[10] Paramvir Singh Saini vs Bljit Singh on 2 December, 2020.1 SCC 184 https://indiankanoon.org/doc/88573149/

[11]DRISHTI IAS BLOG, “Police Reforms and Accountability”, dristiias.com, “ https://www.drishtiias.com/blog/police-reforms-and-accountability ” accessed on Nov 21, 2023.

[12] Diljinder Singh, Dr, Shailja Thakur, “Police Brutality in India: Critical Analysis from a Human Rights Perspective.” Whiteblacklegal.co.in https://www.whiteblacklegal.co.in/details/police-brutality-in-india-a-critical-analysis-from-a-human-rights-perspective-by---diljinder-singh-dr-shailja-thakur (No Date)