PRABHA YADAV W/O SH. LAXMI CHAND YADAV vs STATE OF RAJASTHAN

HIGH COURT OF JUDICATURE FOR RAJASTHAN
BENCH AT JAIPUR
S.B. Criminal Miscellaneous (Petition) No. 4784/2019
Prem Prakash Bidyasar S/o Shri Gyanendra Singh
----Petitioner
Versus
State of Rajasthan
----Respondent
Connected With
S.B. Criminal Miscellaneous (Petition) No. 4672/2020
Prabha Yadav W/o Sh. Laxmi Chand Yadav
----Petitioner
Versus
State of Rajasthan
----Respondent
For Petitioner(s) : Mr.Jaswant Singh for
Mr.Harendra Singh
For Respondent(s) : Mr.Rajesh Choudhary, GA-cum-AAG
assisted by
Mr.J.S. Rathore, Add.GA.
Mr.Gaurav Gupta, Asst.GA.
Mr.Vinod Kumar Sharma &
Mr.Anirudh Singh
Mr.V.K. Singh, ADG (Law & Order)
Mr.Vikas Sharma, DIG (Law & Order)
Mr.Vipin Pandey, ADG (Crime)
(through Video Conferencing)
Mr.Harendra Mahawar, IPS (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, S.I. (PS Ramgarh
Pachwara)
Mr.Mukesh Kharadiya, SHO, Dudu
JUSTICE ANOOP KUMAR DHAND
Order
21/05/2026
Reportable
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1. On the last occasion, when the case was listed before this
Court on 27.04.2026, the following order was passed:-
“1. *
2. *
3. This Court has noticed and felt on various
occasions that the investigation of several criminal
cases could not be completed expeditiously and the
same have remained pending for a considerably long
time because in many cases, the same Investigating
Officer, who has been assigned the task to investigate
the matter has also been assigned other duties of
maintaining law and order in the concerned area. Under
these circumstances, it becomes very difficult for such
Investigating Officers to discharge both the duties
simultaneously.
4. For separation of investigation work from law and
th
order, even the Law Commission of India in its 154
Report has recommended such separation to ensure
speedier investigation, better expertise and improved
rapport with the people without, of course, any
watertight compartmentalisation in view of both
functions being closely interrelated at the ground level.
5. In discharge of its constitutional duties, this Court
deems it just and proper to observe that certain
directions are required to be issued to the State
Government for separation of two wings, i.e., one wing
for investigation and the other wing for maintaining the
law and order, so that no delay occurs in conducting
the investigation and arriving at its conclusion.
6. The Investigating police shall be separated from
the law and order police to ensure speedier
investigation, better expertise and improved rapport
with the people. There should be full co-ordination
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between these two wings. The separation, to start with,
may be effected in towns/urban areas which have a
population of ten lakhs or more and gradually extended
to smaller towns/urban areas as well.
7. Whatever has been observed by this Court
hereinabove has already been examined by the Hon’ble
Apex Court in the case of Prakash Singh & Others
Vs. Union of India and Others reported in (2006) 8
SCC 1 , wherein several directions have been issued to
the Central Government as well as the State
Governments by the Hon’ble Apex Court for framing of
appropriate legislation, policy etc. for separation of
investigation from the police wing for maintaining law
and order.
*
8. *
9. More than two decades have elapsed since order
was passed by the Hon’ble Apex Court in the case of
Prakash Singh (supra) and even after passing of more
than two decades, i.e., 20 years, till date the
Government of Rajasthan has not formulated/enacted
any appropriate legislation/policy for creation of two
separate wings of Police so also in the light of the letter
dated 27.04.2022 issued by the Ministry of Home
Affairs, Government of India. The direction issued in
the case of Prakash Singh (supra) with further
reiteration by the Hon’ble Apex Court in the case of
Pramod Kumar Vs. Bihar Vyavasayik Sangharsh
Morcha reported in AIR 2007 SC 2948 requires to be
implemented at the earliest to avoid any such delays in
conducting investigations and bringing forward the
conclusions.
10. In the case of Prakash Singh (supra), the
Hon’ble Apex Court has issued clear and specific
directions to the Central as well as the State
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Governments to bring appropriate legislation by way of
bringing new Police Act for separation of investigation
work from law and order. Even the Hon’ble Apex Court,
after studying various committee reports on police
reforms has laid down certain directions in the nature
of police reforms to be operative until the new Police
Act is to be framed. It is necessary to quote the
following excerpt from the judgment:
“It is not possible or proper to leave this
matter only with an expression of this hope and
to await developments further. It is essential to
lay down guidelines to be operative till the new
legislation is enacted by the State Governments.
Article 32 read with Article 142 of the Constitution
empowers this Court to issue such directions, as
may be necessary for doing complete justice in
any cause or matter. All authorities are mandated
by Article 144 to act in aid of the orders passed
by this Court….In the discharge of our
constitutional duties and obligations having
regard to the aforenoted position, we issue the
following directions to the Central Government,
State Governments and Union Territories for
compliance till framing of the appropriate
legislations.”
11. Taking a serious note of the above situation, this
Court has issued certain directions to the Chief
Secretary; Principal Secretary, Department of Home
Affairs; and Director General of Police, Rajasthan,
Jaipur in the case of Jitendra Meena Vs. State of
Rajasthan and Anr . while deciding the S.B. Criminal
Misc. Petition No.7231/2025 in para 31, 32, 33 and 37
which reads as under:-
“31. Until the new Police Act is framed by the
Central Government or by the State of Rajasthan,
in pursuance of the directions issued by the
Hon’ble Apex Court in the case of Prakash Singh
(supra) and in pursuance of the letter dated
27.04.2022 issued by the Ministry of Home
Affairs, Government of India, this Court deems it
just and proper to direct the State Heads of
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various Departments, i.e., the Chief Secretary, the
Principal Secretary, Department of Home Affairs,
the Director General of Police, Government of
Rajasthan to form appropriate policy for
separation of police investigation wings from the
Police and create a separate wing for maintaining
law and order.
32. Therefore, this Court deems it just and
proper to issue directions to the Chief Secretary,
Government of Rajasthan; and the Additional
Chief Secretary, Department of Home,
Government of Rajasthan, Director General of
Police to draft a policy for separation of powers of
police by constituting two different wings, i.e.,
one for maintaining law and order and another for
investigating the case registered with the
concerned Police Station until a legislation is
introduced in this regard.
33. This Court hopes & trusts that appropriate
legislation would be introduced by the State
Government, in terms of the observations issued
by the Hon’ble Apex Court in the case of Prakash
Singh (supra).
34 to 36 xx xx xx xx xx xx xx xx
37. Let a copy of this order be sent to the Chief
Secretary, Government of Rajasthan; the
Additional Chief Secretary, Department of Home,
Government of Rajasthan; the Director General of
Police, the Commissioner of Police, the Additional
Commissioner of Police (East), Jaipur and the
Station House Officer, Police Station Pratap Nagar
(East), Jaipur for necessary compliance of this
order.
12. In the interest of better administration of
investigation and maintaining Law and Order, the
officials named in the para No. 11 of this order are
directed to apprise this Court regarding the steps so far
taken by the concerned Police Officials for expeditious
investigation of the pending cases and establishment of
two separate wings i.e, one for investigation; and
another for maintaining law and order in the State of
Rajasthan, in the light of the order dated 16.03.2026
passed by this Court in the case of Jitendra Meena
(Supra).
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13. The Director General of Police (Law and Order) is
further directed and permitted to join the Court
proceeding through Video Conferencing on the next
date of hearing.”
2. Pursuant to the aforesaid order dated 27.04.2026, passed by
this Court, Mr.V.K. Singh, ADG (Law & Order); Mr.Vikash Sharma,
DIG (Law & Order); and Mr.Vipin Pandey, ADG (Crime) have put in
appearance through video conferencing and 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
have also put in appearance physically before this Court.
3. Mr. V.K. Singh, ADG (Law & Order) submits that in pursuance
of the previous order dated 27.04.2026 passed by this Court, a
committee was constituted by the Director General of Police,
Rajasthan for compliance of the orders/directions issued by this
Court. He submits that after getting the reports from four
reference States i.e. Kerala, Punjab, Delhi and Bihar,
recommendations have been made by the Committee to organise
each Police Station into three functional units, i.e., (i) Law & Order
Unit, (ii) Investigation Unit and (iii) Administrative Unit, and for
that purpose, 20 Police Stations have been identified for the
proposed pilot project.
4. The recommendation report of the Committee in the form of
“Proposal For Separation Of Functions Of Investigation And Law
And Order At Police Station Level” has been prepared by the Police
Headquarters, Rajasthan, which contains Eleven Chapters and
Three Annexures. It is relevant to reproduce the Table of Contents
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of Chapters I, II, III, IV, V, VI, VII, VIII, IX, X of the proposal,
which read as follows:
TABLE OF CONTENTS
“
CHAPTER I - BACKGROUND AND MANDATE...................…….............4
Hon'ble High Court direction dated 27.04.2026 and constitution of the
•
Committee
The undifferentiated-model problem and the consistent findings of
•
expert bodies
CHAPTER II - DIAGNOSIS OF THE EXISTING PROBLEM......…..........5
Operational overlap/diversion between Law and Order and Investigation
•
functions
Conviction rates, pendency, and Case-load indicators in Rajasthan
•
Structural and manpower constraints
•
CHAPTER III - COMPARATIVE ANALYSIS OF FOUR STATE
MODELS………………………………………………………………………………….7
Kerala - Section 3(A), Kerala Police Act
•
Bihar - Additional SHO model; 50:50/75:25 split
•
Delhi - Standing Order LO/46/2024 and the Outer North District pilot
•
Punjab - Bureau of Investigation and specialised civilian support
•
Comparative matrix of salient features
•
CHAPTER IV – SEPARATION IN PRACTIVE: OUTER NORTH
DISTRICT, DELHI……………………………………………............…….…….14
Pilot rollout (Samayypur Badli, Shahabad Dairy) and district-wide
•
expansion.
Staff distribution (42%/28%/30%) and functional division of work.
•
Outcomes, challenges, and the role of the DCPs monitoring system.
•
CHAPTER V - SPECIFIC CONCERNS REGARDING RAJASTHAN….…..16
Geography, international border, and tourist districts
•
Emerging crime profile; crimes against women; manpower realities
•
CHAPTER VI - DESIGN PRINCIPLES FOR THE RAJASTHAN
MODEL………………………………………………………………………………….17
Three-Unit Model at the Police Station level
•
Workload driven staffing with differentiated benchmarks
•
Single SHO command and guarded protocol for diversion
•
The Investigation Unit; the Law and Order Unit; the Administrative
•
Unit
District-level specialist support pools
•
• Consolidated unit-wise allocation of functions
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CHAPTER VII - IMPLEMENTATION, SAFEGUARDS AND STATUTORY
ANCHORING………………………………………………………………………….24
Structure and composition of a Police Station – rank-wise framework
•
Manpower estimation methodology – the IO Workload Formula
•
Composition Table (500-800 IWL) – total 100 personnel
•
Composition Table (800 IWL and above) – total 125 personnel
•
CHAPTER VIII - IMPLEMENTATION STRATEGY..............….............26
Three anchoring objectives
•
Selection of pilot Police Stations – the two-step filtering protocol
•
Establishment of institutional architecture - DGP Standing Order,
•
SOPs, CCTNS
Risk Register and Mitigation
•
CHAPTER IX - INFRASTRUCTURE, EQUIPMENT AND MANPOWER
REQUIREMENTS……………………………………………….…………………...28
CHAPTER X- OUTCOME MEASUREMENT FRAMEWORK........…..........31
• Primary outcome indicator – reduction in investigation pendency
Secondary indicators – investigation quality, Law and Order
•
effectivness, compliance
Before-after comparison protocol – T 0 baseline and matched control
•
stations ”
5. Chapters I & II of the aforesaid Proposal submitted by the
Police Headquarter, deals with the issue raised by this Court with
regards to the establishment of two separate wings, i.e., one for
Investigation and another for maintaining Law & Order in the
State of Rajasthan. For ready reference, the contents of Chapter I
& II are reproduced herein below:-
“ CHAPTER I
BACKGROUND AND MANDATE
The increasing complexity of crime, coupled with rising
public expectations for professional policing,
necessitates structural reforms in police functioning.
One of the key reforms recommended by various
expert bodies, including the National Police
Commission, and reaffirmed by the Hon'ble Supreme
Court of India in the judgement in the Prakash Singh vs
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Union of India, is the separation of investigation and
law and order duties at the Police Station level.
On 27.04.2026, the Hon'ble High Court of Rajasthan,
directed the State of Rajasthan to assess the
formalities required for the separation of the function of
investigation of crime from Law and Order maintenance
function, and submit a report before the Hon'ble High
Court.
In pursuance of the directions of the Hon'ble High Court
of Rajasthan, a Committee was constituted by DGP,
Rajasthan, to examine the feasibility for the same, and
to suggest a framework and implementation strategy
for such separation.
Indian Police Stations operate on an undifferentiated
model in which the same set of officers register FIRs,
supervise beat patrolling, manage communal incidents,
perform VIP security duties, control religious
processions, and also acts as Investigating Officers
responsible for evidence collection, witness
examination, and filing of and charge-sheets and Final
Closure Reports within statutory timelines. The
Investigation function, which is intellectually
demanding and is time-bound, is consistently
subordinated to Law and Order duties, due to its
emergent nature and huge public visibility. The result is
poor quality of investigation, low conviction rates, and
persistent pendency of cases under investigation.
Successive expert bodies, the National Police
Commission (1977-81), the Padmanabhaiah Committee
(2000), the Malimath Committee (2003), the Law
Commission of India (1996), and the Hon'ble Supreme
Court in its judgement pronounced in Prakash Singh vs
UOI (2006), have unanimously recommended
separation of the functions of maintenance of Law and
Order and investigations of criminal cases. However,
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the recommendations are still to fully see the light of
the day, across the States of the Union.
Implementation has only been partial, and also uneven,
across States.
The Committee examined the directives issued
regarding the implementation of the separation of
functions in four reference States- Kerala, Bihar, Delhi
and Punjab, and also studied the actual status of
implementation on the ground in the Outer North
District of Delhi, where the recommendations were
made operational initially on a pilot basis, and there
after extended to the entire district.
The most consistent failure seen was the silent
diversion of the Investigation Wing personnel for
routine Law and Order duties -bandobast, escort
duties, examination centres security, election work etc.,
which hollowed out the whole idea of separation. The
Delhi pilot, by contrast, demonstrates what is
achievable when the separation is sustained: improved
follow-up of investigation, better disposal of pending
cases, and increased police visibility in the community.
CHAPTER II
DIAGNOSIS OF THE EXISTING PROBLEM
Law-and-order work is time-critical, visibility heavy,
•
and often volatile (crowds, protests, violence, VVIP
visits). It requires rapid decision making, and physical
presence with immediate response. Investigation
requires continuity, documentation discipline, evidence
handling, witness follow-up, and methodical
progression from the scene of Crime to the Court of
Law.
• Law and Order maintenance requires crowd psychology
management, physical endurance, rapid response,
engagement/persuasion skills, and liaisoning with local
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pressure groups. Modern investigation requires forensic
literacy, use of digital apps like e-Sakshya, digital
evidence tracking, legal acumen, and patience. A single
officer rarely excels at both simultaneously. Poor quality
of investigation, caused by time constraints and lack of
specialization, directly correlates with low conviction
rates.
• When the same Police Officer handles both functions,
and if investigation fails in court, or if pendency of
investigation is high, he always throws the burden on
"Law and Order duties".
Conviction rates in heinous offences in Rajasthan have
•
remained between 40% and 50%, particularly in cases
of crimes against women, and in property offences.
• Pendency of investigation in economic offences cases,
of cyber-crime, and of cases under NDPS Act, often
exceed two years.
In high-load urban Police Stations, individual IOs carry
•
between 40 and 70 active cases at any point of time,
well above the Padmanabhaiah Committee benchmark.
BPRD time-and-motion analysis indicate that
•
investigation occupies only 15% to 25% of the
schedule of a Police officer.
• Separation orders have been breached constantly.
Investigation Wing personnel have been routinely
diverted to bandobast, escort and VVIP duties, with no
consequence.
Where separation has been attempted without coherent
•
staffing, it has produced shortage on the law and order
side, met by quietly drawing on the Investigation Wing,
defeating the reform.
Investigation has been treated as a less prestigious
•
posting, with Law and Order seen as the path to prized
postings.
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Modern crime cannot be investigated by a generalist
•
Sub-Inspector working alone.
The Indian Police Station have functioned in an
undifferentiated mode for over a century. Cultural change
requires sustained leadership attention, training, and
visible enforcement; not merely an order. Separation of
the functions of Law and Order maintenance, and
criminal investigation, requires additional police strength
─ this is the consistent finding across the Padmanabhaiah
Committee recommendations, the Bureau of Police
Research and Development studies, and field
observations from the States of Punjab, Bihar, and Delhi.
The existing available strength is already substantially
absorbed in Law and Order duties; hence creating a
dedicated Investigation Unit alongside an undisturbed
Law and Order Unit cannot be done without augmenting
manpower. Police forces, including in the State of
Rajasthan, currently have 20% to 30% vacancies against
the sanctioned strength. Hence the manpower
environment is structurally constrained from the start.
This is the principal reason that full separation has not
yet been realised, despite two decades of court directions
and recommendations of expert Committees. The Hon'ble
Supreme Court in the case of Prakash Singh vs UOI has
itself acknowledged manpower shortage as the major
challenge towards the path of separation of functions,
and had directed that separation should begin in cities
with population over one million.”
6. Accordingly, the Committee was constituted and it has made
the following recommendations to the Additional Chief Secretary,
Department of Home for taking appropriate action, in Chapter XI
of the aforesaid Proposal:-
“CHAPTER XI
RECOMMENDATIONS OF THE COMMITTEE
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Based on the foregoing analysis, the Committee makes the
following recommendations:
ARCHITECTURE AND STAFFING:
1. Apply the Three-Unit Model to pilot Police Stations
selected through the filtering protocol set out in this Report,
with staffing scaled to their Investigative Workload (IWL).
Each pilot station shall be organised into three functional
units (Investigation, Law and Order, Administration) under a
single SHO. Subject to evaluation of pilot outcomes, the
model may be extended in subsequent phases to other Police
Stations across the State.
2. Adopt the differentiated workload-driven staffing
benchmarks of 40 to 60 cases per IO per year.
Approximately 40% of total Police Station strength is to be
dedicated to the Investigation Unit.
3. Constitute the Investigation Unit, Law and Order Unit
and formalise the Administrative Unit as the third unit at
every covered Police Station.
4. Designate Police Inspectors as Unit heads for
Investigation and Law and Order Units each heading
their respective Unit under the SHO. The Administrative Unit
is to be headed by a senior HC/ASI. Eligibility and tenure
rules for these positions to be notified.
5. Adopt the Bihar eligibility framework for SHO posting
of two years of experience, each in the Investigation and the
Law and Order units separately.
6. Mandate Law and Order tenure for fresh recruits and
promotees , which tenure shall be a positive consideration in
further promotions and postings.
7. Notify a long-term posting policy for Investigation Unit
officers, with a minimum of two years.
OPERATIONAL DISCIPLINE AND SAFEGUARDS:
1. Apply the hard wall against diversion – Investigation
Unit personnel may not be deployed for routine Law and
Order duties. Cross-deployment may be permitted only in
the four defined situations. (riots, VVIP duties, encounters
with criminals, natural and man-made disasters).
2. Adopt the Inter-station Mutual Support Protocol –
Surge support should be drawn first from neighbouring Law
and Order Units, then from Police Lines/RAC Battalions, and
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only as the last resort from the affected Police Station's
Investigation Unit, and that too with the written approval of
the District SP/CP.
3. Configure CCTNS to enforce unit-tag locking; prevent
cross-assignment of IOs through the user interface; and to
generate a real-time compliance dashboard at District and
Range level.
4. Provide differentiated resources to each Unit like
tablets, laptops with CDR/IPDR/social media analytics, MOB
Unit access, operational funds, training in Nyay Samhita, FSL
coordination, separate seating, computer-proficient staffing,
weapons access, vehicles, latest wireless equipment, periodic
tactical tests, and technological support for interception.
5. Acknowledge and address the manpower gap by
recognising that the full implementation requires
approximately 60% to 100% additional police strength
against current sanctioned levels, to be addressed by the
fresh sanction of approximately 935 posts across the twenty
pilot Police Stations, by the reabsorption of 107 surplus ASIs
elsewhere within the respective districts, and by the
engagement of cyber, forensic and financial-crime specialists
at the district pool level on contract.
6. Institute a dedicated training pipeline at Training
Centres, with segregated tracks for Investigation Unit
personnel (forensic literacy, digital evidence handling, e-
Sakshya, CCTNS proficiency, BNSS / BNS procedural
mastery, cyber and financial-crime investigation, court-craft)
and for Law and Order Unit personnel (crowd management,
tactical operations, fitness and weapons training, community
engagement, intelligence collection, social-media
monitoring), supplemented by mandatory refresher modules
at defined intervals, and by joint cross-Unit modules in topics
requiring coordination (communal sensitivity, women safety,
victim handling). Training completion is to be recorded in
CCTNS and linked to APAR and posting eligibility.
Hire specialist experts on contract at district pool level
- Legal experts (for charge-sheet vetting, court strategy), IT
and digital-forensic experts (for device, phone and data
extraction; cyber trail analysis), financial-investigation
experts (bank trails, attachment proposals under Section
107 BNSS), and Scene of Crime Forensic experts, thereby,
capturing the operational benefit of the Punjab Specialised
Support Service model.
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The Committee has proposed a dynamic model with several
variables in the pilot project of 20 Police Stations. Since it is a
new model, there shall always be an element which cannot be
quantified, or changes may have to be incorporated as the
model becomes operational. The proposed State
Implementation Committee shall monitor, regulate, and modify
requirements and manpower as and when required.
The Committee respectfully submits that the proposed model –
drawing on the strongest features of four reference States,
validated by field evidence of six months from the Delhi Outer
North District pilot, and refined by the operational insights of
serving District SPs in Rajasthan, calibrated for Rajasthan's
policing geography, and equipped with three structural
safeguards not present in any of the reference States –
represents a workable, fiscally sustainable and durable
response to the directions of the Hon'ble Rajasthan High Court
and the long-standing mandate of the Hon'ble Supreme Court
of India in Prakash Singh vs UOI .”
7. Several recommendations have been made in the above-
extracted Chapter XI of the Committee Report/Proposal, including
providing of manpower, infrastructure & training to all the
stakeholders. For that purpose, the cadre strength of the Police is
also required to be increased by way of fresh recruitment and
filling up of the posts already advertised at the earliest.
8. For expeditious disposal of the cases pending for more than
5 years, several directions have been issued to all the
stakeholders for expeditious investigation of the pending matters
by submitting the compliance report formed by the Additional
Superintendent of Police, CID (CB), Jaipur and OIC of the instant
case. The same is ordered to be taken on record.
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9. The aforesaid steps taken by the Police Headquarters
deserve commendation and this Court places on record its
appreciation for the same.
10. In the considered opinion of this Court, when the entire
system and society are moving at a fast and rapid pace in the
current era and criminals are also adopting latest and advanced
techniques to commit offences, then under such circumstances,
the investigation mechanism of the Police is also required to be
strengthened with modern and well-equiped Investigation Labs,
etc. having adequate scientific facilities. Investigation Labs are not
available in the State of Rajasthan and therefore, the State Police
Department is compelled to conduct its investigation based on the
reports and analysis carried out by the Investigation Labs situated
in other States, which causes unnecessary delay in the
investigation and the culprits often desire benefits of such delay.
Looking to the increase in the rate of crimes, the existing FSL in
State is not sufficient. The time has now come to strengthen and
expand the increase the cadre strength of the investigators/staff,
etc. so that the FSL reports can be received at the earliest and the
conclusion report of investigation can be submitted before the
Court expeditiously and in a time bound manner.
In the considered opinion of this Court, now the time has
come to modulate and strengthen the Police Investigation wings
from all the corners. Latest Investigating Labs are required to be
established in the State of Rajasthan expeditiously having
adequate infrastructure and trained stakeholders, so that the
investigation can be done expeditiously and brought to its logical
end at the earliest. The State is under constitutional obligation to
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[CRLMP-4784/2019]
provide adequate infrastructure for fair and speedy investigation
as the delay in investigation, due to lack of adequate
infrastructure for investigation, violates the right of fair
investigation and speedy trial.
11. Let a copy of this order be sent to the Chief Secretary;
Additional Chief Secretary, Department of Home, Government of
Rajasthan; and Director General of Police to look into the matter
from all corners to develop and establish appropriate and well-
equipped labs, for investigation, in the State of Rajasthan in the
interest of public at large.
12. A part compliance report dated 20.05.2026 is ordered to be
retained on the record.
In S.B. Criminal Miscellaneous (Petition) No. 4672/2020
1. Petitioner as well as the concerned Investigating Office are
directed to file their affidavits as to whether the interim order
dated 19.11.2020 passed by this Court was apprised to the
Investigating Office or not?
2. List these cases on 21.07.2026 at 02:00 PM. The Higher
Police Officials are directed to appear through VC and apprise this
Court about the progressive steps taken by the Police
Headquarters and Department of Home, Government of
Rajasthan.
(ANOOP KUMAR DHAND),J
Aayush Sharma/27 & 30
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