State Must Separate Police Investigation from Law and Order Duties to Ensure Speedier, Specialized Investigations

The High Court observed that numerous criminal investigations in Rajasthan remained pending for excessively long periods because Investigating Officers (IOs) were simultaneously burdened with maintaining law and order

Initially, on 27.04.2026, the Court noted that despite the Supreme Court's 2006 mandate in Prakash Singh, the State of Rajasthan had failed to separate these two police functions

Following a subsequent court order in Jitendra Meena v. State of Rajasthan, the Director General of Police (DGP) constituted a committee to study and propose a model for functional separation

The matter came before the Court to review the "Proposal For Separation Of Functions Of Investigation And Law And Order At Police Station Level" submitted by the Police Headquarters

1. Whether the functional separation of the investigation wing from the law and order wing at the police station level is necessary to ensure speedier and more professional investigations.

2. Whether the State of Rajasthan is constitutionally obligated to provide adequate infrastructure, such as advanced Forensic Science Laboratories (FSLs), to prevent delays in criminal proceedings.

The Court primarily relied on the Landmark Supreme Court judgment in Prakash Singh & Others v. Union of India (2006) 8 SCC 1, which issued specific directives to State Governments to separate investigation from law and order duties to improve police professionalism

It further applied principles from the 154th Law Commission Report, the Padmanabhaiah Committee (2000), and the Malimath Committee (2003), all of which recommended specialized investigation units

The Court also invoked the constitutional right to fair investigation and speedy trial, which mandates the State to provide necessary infrastructure to avoid procedural delays

The Court analyzed the "Three-Unit Model" (Investigation, Law & Order, and Administration) proposed by the Rajasthan Police Committee, which studied models from Kerala, Punjab, Delhi, and Bihar

The Court noted that the "undifferentiated-model" currently in use consistently subordinates time-bound, intellectual investigation work to urgent, high-visibility law and order duties, resulting in poor conviction rates (40-50% in heinous crimes) and prolonged pendency

The Court highlighted that modern crime requires "forensic literacy" and "digital evidence tracking," which cannot be achieved if the same officer is occupied with crowd control or VIP security

Furthermore, the Court observed that the lack of internal FSL infrastructure in Rajasthan forces reliance on other states, causing delays that violate the right to a speedy trial

The Court reasoned that augmenting manpower (approx. 935 new posts for the pilot) and imposing a "hard wall" against diverting investigation staff for routine duties are essential for the reform's success

It held that the State is under a constitutional obligation to provide modern investigation labs and adequate scientific facilities to ensure fair and speedy trials

The Court directed the Chief Secretary and Additional Chief Secretary (Home) to establish well-equipped labs and increase cadre strength

Regarding the individual petitions, the Court ordered affidavits concerning notice of interim orders and scheduled the next hearing for 21.07.2026 to monitor progress on the pilot project and legislative steps