Rajasthan HC Accepts Police HQ Proposal for Three-Unit Model to Separate Investigation from Law and Order at 20 Pilot Stations
Justice Anoop Kumar Dhand accepted a Police Headquarters committee report recommending a three-unit model at 20 pilot stations, directing the State to establish modern forensic labs and increase cadre strength.
More than two decades after the Supreme Court issued directions in Prakash Singh & Others v. Union of India, reported in (2006) 8 SCC 1, the Rajasthan Police Headquarters has placed before the High Court at Jaipur a detailed committee report proposing a concrete structural reform: reorganising each police station into three functional units — Investigation, Law and Order, and Administration — beginning with a pilot at 20 identified stations. Justice Anoop Kumar Dhand, sitting singly, accepted the proposal on 21 May 2026, commended the Police Headquarters for the steps taken, and directed the State to additionally address the absence of modern forensic science laboratories in Rajasthan. The order arises from two connected criminal miscellaneous petitions in which the court had, on earlier dates, taken up the systemic problem of delayed investigations caused by the same officer handling both investigative and law-and-order duties simultaneously.
How the Matter Reached This Point
S.B. Criminal Miscellaneous (Petition) No. 4784/2019, filed by Prem Prakash Bidyasar, and the connected S.B. Criminal Miscellaneous (Petition) No. 4672/2020, filed by Prabha Yadav, were both pending before Justice Dhand. On 27 April 2026, the court passed a detailed interim order observing that investigations in several criminal cases had remained pending for long periods because the same investigating officer was simultaneously burdened with law-and-order duties. The court noted that the Law Commission of India in its 154th Report had recommended separation of the two functions, and that the Supreme Court's directions in Prakash Singh — reiterated in Pramod Kumar v. Bihar Vyavasayik Sangharsh Morcha, AIR 2007 SC 2948 — had not been implemented by the Government of Rajasthan even after twenty years.
In that April order, the court had also referred to its own earlier directions issued in Jitendra Meena v. State of Rajasthan, S.B. Criminal Misc. Petition No. 7231/2025, where it had directed the Chief Secretary, the Additional Chief Secretary (Home), and the Director General of Police to draft a policy for separation of the two wings. The Director General of Police (Law and Order) was permitted to join proceedings through video conferencing on the next date.
Pursuant to the 27 April 2026 order, senior police officials appeared before the court on 21 May 2026: Mr. V.K. Singh, ADG (Law & Order); Mr. Vikas Sharma, DIG (Law & Order); and Mr. Vipin Pandey, ADG (Crime) appeared through video conferencing, while Mr. Harendra Mahawar, IGP-PHQ; Mr. Shiv Lal Bairwa, Addl. SP, Dudu; Mr. Puran Mal, CI, PS Pratap Nagar; Mr. Vinod Kumar, Addl. SP, Lalsot; Mr. Madan Lal, SI, PS Ramgarh Pachwara; and Mr. Mukesh Kharadiya, SHO, Dudu appeared physically.
The Committee Report and Its Diagnosis
ADG (Law & Order) Mr. V.K. Singh informed the court that a committee had been constituted by the Director General of Police, Rajasthan, after studying four reference States — Kerala, Punjab, Delhi, and Bihar. The committee produced an eleven-chapter proposal titled “Proposal For Separation Of Functions Of Investigation And Law And Order At Police Station Level.”
The diagnosis in Chapters I and II of the proposal was direct. Indian police stations operate on an undifferentiated model in which the same officers register FIRs, supervise beat patrolling, manage communal incidents, perform VIP security duties, and also act as investigating officers responsible for evidence collection, witness examination, and filing of charge-sheets. The investigation function, which is intellectually demanding and time-bound, is consistently subordinated to law-and-order duties because of their emergent nature and public visibility.
The committee's data on Rajasthan was specific. Conviction rates in heinous offences, including crimes against women and property offences, have remained between 40% and 50%. Pendency of investigation in economic offences, cyber-crime cases, and NDPS Act cases often exceeds two years. In high-load urban police stations, individual investigating officers carry between 40 and 70 active cases at any point, well above the Padmanabhaiah Committee benchmark. Bureau of Police Research and Development time-and-motion analysis indicated that investigation occupies only 15% to 25% of a police officer's schedule. The committee also found that separation orders had been breached constantly, with investigation wing personnel routinely diverted to bandobast, escort, and VVIP duties without consequence.
The committee examined the Delhi Outer North District pilot, where separation was first made operational at Samaypur Badli and Shahabad Dairy police stations and then extended district-wide, with staff distributed at 42% (Investigation), 28% (Law and Order), and 30% (Administration). The Delhi pilot demonstrated improved follow-up of investigations, better disposal of pending cases, and increased police visibility in the community. The committee also studied Kerala's Section 3(A) of the Kerala Police Act, Bihar's Additional SHO model with a 50:50 or 75:25 split, and Punjab's Bureau of Investigation and specialised civilian support structure.
On manpower, the committee was candid: full implementation requires approximately 60% to 100% additional police strength against current sanctioned levels. Rajasthan's police forces currently have 20% to 30% vacancies against sanctioned strength. The committee identified this as the principal reason full separation had not been achieved despite two decades of court directions.
The Three-Unit Model and Key Recommendations
Chapter XI of the proposal set out the committee's recommendations. The core architecture is a Three-Unit Model at the police station level: an Investigation Unit, a Law and Order Unit, and an Administrative Unit, all under a single SHO. Approximately 40% of total police station strength is to be dedicated to the Investigation Unit, with differentiated workload-driven staffing benchmarks of 40 to 60 cases per investigating officer per year.
Police Inspectors are to be designated as unit heads for the Investigation and Law and Order Units respectively, each heading their unit under the SHO. The Administrative Unit is to be headed by a senior Head Constable or ASI. The committee recommended adopting the Bihar eligibility framework for SHO posting, requiring two years of experience each in the Investigation and Law and Order units separately.
On operational discipline, the committee recommended a hard wall against diversion: Investigation Unit personnel may not be deployed for routine law-and-order duties. Cross-deployment is to be permitted only in four defined situations — riots, VVIP duties, encounters with criminals, and natural or man-made disasters — and only with the written approval of the District SP or Commissioner of Police. Surge support is to be drawn first from neighbouring Law and Order Units, then from Police Lines or RAC Battalions, and only as a last resort from the affected station's Investigation Unit.
The committee proposed configuring CCTNS to enforce unit-tag locking, prevent cross-assignment of investigating officers through the user interface, and generate a real-time compliance dashboard at district and range level. It also recommended a dedicated training pipeline with segregated tracks: Investigation Unit personnel to receive training in forensic literacy, digital evidence handling, e-Sakshya, CCTNS proficiency, BNSS and BNS procedural mastery, and cyber and financial-crime investigation; Law and Order Unit personnel to receive training in crowd management, tactical operations, fitness and weapons training, community engagement, and social-media monitoring.
To address the manpower gap at the 20 pilot stations, the committee proposed fresh sanction of approximately 935 posts, reabsorption of 107 surplus ASIs within their respective districts, and engagement of cyber, forensic, and financial-crime specialists at the district pool level on contract.
The Court's Observations on Forensic Science Laboratories
Beyond accepting the committee's proposal, Justice Dhand made a separate and pointed observation about the state of forensic infrastructure in Rajasthan. The court noted that adequate investigation laboratories are not available in the State, compelling the police to rely on FSL reports and analysis from laboratories situated in other States. This causes unnecessary delay in investigation, and the court observed that culprits often seek to benefit from such delay.
The court held that the existing FSL capacity in Rajasthan is not sufficient given the increase in the rate of crimes. It stated that the State is under a constitutional obligation to provide adequate infrastructure for fair and speedy investigation, and that delay in investigation due to lack of adequate infrastructure violates the right of fair investigation and speedy trial. The court directed that latest investigation labs with adequate infrastructure and trained personnel be established in Rajasthan expeditiously.
A copy of the order was directed to be sent to the Chief Secretary, the Additional Chief Secretary (Home), and the Director General of Police to look into the matter from all corners and develop and establish appropriate, well-equipped investigation labs in the State in the interest of the public at large.
Directions on Pending Cases and the Connected Petition
For expeditious disposal of cases pending for more than five years, the court issued directions to all stakeholders for expeditious investigation of pending matters, requiring a compliance report from the Additional Superintendent of Police, CID (CB), Jaipur and the officer-in-charge of the instant case. A part compliance report dated 20 May 2026 was ordered to be retained on record.
In the connected S.B. Criminal Miscellaneous (Petition) No. 4672/2020 filed by Prabha Yadav, the court directed the petitioner and the concerned investigating officer to file affidavits on whether the interim order dated 19 November 2020 had been communicated to the investigating officer.
Order
Justice Dhand placed on record the court's appreciation for the steps taken by the Police Headquarters. Both matters were listed for 21 July 2026 at 2:00 PM. Higher police officials were directed to appear through video conferencing on that date and apprise the court of the progressive steps taken by the Police Headquarters and the Department of Home, Government of Rajasthan. The order is marked Reportable.