Custodial Deaths in India: Law, Reform, and the Crisis of Accountability

Abstract

Custodial deaths reveal not just administrative lapses but a deep moral and constitutional crisis  within India’s criminal justice system. Even though Article 21 promises every individual dignity  and protection of life, and despite decades of judicial attempts to reinforce these safeguards, the  reality inside police stations and prisons continues to reflect a troubling culture of impunity.¹ As  per the NCRB’s 2023 report, there were 117 deaths in police custody and 1,692 in judicial custody,² whereas the National Human Rights Commission (NHRC) recorded more than 2,500 related  complaints,³highlighting how widespread underreporting still is. This article undertakes a socio

legal, evidence-driven examination of custodial deaths in India. It studies the constitutional,  statutory, and institutional frameworks governing custody, traces important shifts in judicial  reasoning, draws on criminological and international insights, and suggests concrete structural  reforms. The central argument is that custodial deaths endure not because India lacks laws, but  because weak accountability mechanisms, ineffective oversight, and deeply embedded policing  practices allow violations to continue unchecked. Meaningful reform, therefore, requires  independent investigations, statutory incorporation of protective safeguards, and a broader  transformation of custodial culture in line with the values of India’s constitutional morality.

Introduction

In June 2020, the custodial deaths of Jayaraj and Bennix in Tamil Nadu’s Tuticorin district shook  the country’s conscience.⁴ The brutality they suffered during police interrogation was not just an  isolated incident; it reflected a deeper, long-standing pattern of abuse that has become disturbingly  normalized within India’s custodial spaces. The Indian Constitution, especially Articles 21 and  22, promises every person the right to life, dignity, and protection from arbitrary arrest.⁵ Yet, these 

¹India Const. art. 21.

² National Crime Records Bureau, Crime in India 2023: Statistics, at tbl. 12C (2023).

³ National Human Rights Commission, Annual Report 2023–24, at 45–47 (2024).

⁴ J. Venkatesan, Tuticorin Custodial Deaths Trigger Nationwide Outrage, The Hindu (June 27, 2020) (reporting  the facts surrounding the deaths of P. Jeyaraj and J. Bennix).

⁵India Const. arts. 21, 22.

safeguards often fade the moment someone enters a police station or prison. Between 2017 and  2023, India witnessed over 830 police custodial deaths,⁶ while conviction rates for such offences  have remained below a dismal 2%,⁷a statistic that speaks volumes about the gap between  constitutional guarantees and everyday reality.

Custodial violence is not just a human rights violation; it exposes a deep constitutional paradox. The very state that is expected to safeguard an individual’s liberty under Article 21 often ends up  being the one that violates it. The Supreme Court acknowledged this irony in D.K. Basu v. State  of West Bengal (1997), describing custodial torture as “a naked violation of human dignity,”⁸a  phrase that captures both the brutality of the act and the betrayal of constitutional promises.

This article argues that custodial deaths in India do not stem from a lack of laws, but from persistent  failures in enforcement and accountability. It examines the crisis across multiple dimensions, legal  gaps, institutional weaknesses, sociological patterns, and deeper moral failures that collectively  enable custodial impunity to thrive. The discussion also places custodial reform within the  framework of transformative constitutionalism, highlighting that the Indian Constitution is not  merely a written document but a moral and social commitment to ensure that justice is actually  experienced in people’s everyday lives.⁹

Legal and Constitutional Framework

1. Constitutional Protections

The trio of Articles 20(3), 21, and 22 forms the backbone of India’s custodial rights framework.¹⁰ In Maneka Gandhi v. Union of India (1978), the Supreme Court broadened the scope of Article 21  by reading into it the requirements of “substantive fairness” and “procedural reasonableness,” 

⁶ National Crime Records Bureau, Crime in India 2023: Statistics, at tbl. 12C (2023) (reporting cumulative police  custodial deaths between 2017–2023).

⁷ Law Comm’n of India, Report No. 273: Implementation of “United Nations Convention Against Torture” and  Other Cruel, Inhuman and Degrading Treatment or Punishment 18–19 (2017) (noting extremely low conviction  rates in custodial death cases).

⁸ D.K. Basu v. State of W.B., (1997) 1 S.C.C. 416, 427 (“Custodial torture is a naked violation of human dignity…”). ⁹ Navtej Singh Johar v. Union of India, (2018) 10 S.C.C. 1, 122–23 (Chandrachud, J., concurring) (discussing  transformative constitutionalism and constitutional morality).

¹⁰ India Const. arts. 20(3), 21, 22.

effectively turning custodial protections into meaningful, enforceable rights.¹¹ Alongside this,  Article 22 guarantees that anyone who is arrested must be informed of the grounds for their arrest  and brought before a magistrate within 24 hours, basic safeguards meant to prevent misuse of state  power.¹²

The Supreme Court has consistently interpreted Article 21 through the lens of human dignity,  beginning with Francis Coralie Mullin (1981) and reaffirmed decades later in Puttaswamy v.  Union of India (2017).¹³ These judgments make it clear that state power must respect an  individual’s basic personhood at all times, including while they are in custody. 

Custodial torture, therefore, is far more than just a criminal wrong; it amounts to a constitutional  violation that strikes at the core values of dignity, equality, and justice.¹⁴

2. Statutory Provisions

The Code of Criminal Procedure (CrPC) also lays down several procedural safeguards meant  to protect individuals in custody.

• Sections 41B–41D require police officers to wear identification, prepare proper arrest memos, and allow the arrested person to meet a lawyer during interrogation.¹⁵
• Section 176(1A) mandates that every custodial death must be examined through an independent judicial inquiry, rather than an internal police investigation.¹⁶ • Sections 46, 49, and 50 regulate how force can be used during arrest and outline the rights of detainees, such as protections against needless restraint and the requirement to be informed of  the grounds for arrest.¹⁷

¹¹ Maneka Gandhi v. Union of India, (1978) 1 S.C.C. 248, 279–80 (interpreting Article 21 to include procedural  fairness and substantive due process).

¹² India Const. art. 22(1)–(2).

¹³ Francis Coralie Mullin v. Adm’r, Union Territory of Delhi, (1981) 1 S.C.C. 608, 618 (recognizing the right to  dignity under Article 21); K.S. Puttaswamy v. Union of India, (2017) 10 S.C.C. 1, 112–13 (reaffirming dignity as a  core facet of Article 21).

¹⁴ D.K. Basu v. State of W.B., (1997) 1 S.C.C. 416, 427 (calling custodial torture a violation of human dignity). ¹⁵ Code of Criminal Procedure, 1973, §§ 41B–41D (India).

¹⁶ Id. § 176(1A).

¹⁷ Id. §§ 46, 49–50.

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The Protection of Human Rights Act, 1993, led to the establishment of the NHRC, giving it the  authority to investigate custodial deaths and recommend compensation or corrective action.¹⁸ However, because the NHRC’s recommendations are not legally binding, many of its directives  are ignored or only partially implemented by state authorities, which significantly weakens its  overall impact.¹⁹

The newly introduced Bharatiya Nyaya Sanhita (BNS), 2023, and Bharatiya Nagarik  Suraksha Sanhita (BNSS), 2023, may modernize the language of criminal law, but they fall short  where it matters most for custodial rights.²⁰ They do not expand protections against custodial  abuse, nor do they incorporate the D.K. Basu safeguards into the statutory text, a gap many scholars  and practitioners view as a “lost opportunity” for meaningful reform.²¹

3. Judicial Evolution

Judicial creativity has often stepped in to fill gaps left by legislation.

• D.K. Basu v. State of West Bengal (1997): Eleven mandatory arrest and detention guidelines, treated as enforceable law under Article 141.²²
• Nilabati Behera v. State of Orissa (1993): Established constitutional tort, holding the state vicariously liable for custodial deaths and mandating compensation.²³
• Prakash Singh v. Union of India (2006): Directed states to create Police Complaints Authorities for independent investigation of custodial violence.²⁴

¹⁸ Protection of Human Rights Act, 1993, §§ 3–12 (India) (establishing the National Human Rights Commission  and defining its powers).

¹⁹ Gautam Bhatia, The Promise and Limits of the NHRC, 45 Econ. & Pol. Wkly. 15, 17 (2010) (discussing the non binding nature of NHRC recommendations and their weak enforcement).

²⁰ Bharatiya Nyaya Sanhita, 2023 (India); Bharatiya Nagarik Suraksha Sanhita, 2023 (India). ²¹ See, e.g., Abhinav Sekhri, Missed Chances in the New Criminal Codes, Wire (Aug. 2023) (arguing that the new  laws failed to codify D.K. Basu safeguards).

²² D.K. Basu v. State of W.B., (1997) 1 S.C.C. 416, 427–30 (laying down arrest and detention guidelines enforceable  under Article 141).

²³ Nilabati Behera v. State of Orissa, (1993) 2 S.C.C. 746, 754–55 (establishing constitutional tort and state liability  for custodial deaths).

²⁴ Prakash Singh v. Union of India, (2006) 8 S.C.C. 1, 14–18 (directing states to create Police Complaints  Authorities).

• Re: Inhuman Conditions in 1382 Prisons (2016): Expanded the right to dignity of prisoners and mandated CCTV surveillance.²⁵

Yet, in practice, implementation remains patchy at best. The Prakash Singh directives, in  particular, have seen poor compliance; by 2024, only about twelve states had functional Police  Complaints Authorities.²⁶ This gap makes it clear that even the strongest legal principles mean  little when enforcement remains weak; law without implementation ultimately becomes an  illusion.

1. The Data Paradox: Law vs. Reality

Year	Police Custodial Deaths (NCRB)	NHRC Recorded Complaints	Convictions
2019	85	175	0
2020	76	196	1
2021	100	210	2
2023	117	2,500+	0

Compiled from NCRB Crime in India Reports & NHRC Annual Statements.²⁷The data makes the illusion of accountability painfully clear. Because NCRB depends on figures  reported by state police themselves, the extent of custodial deaths is often significantly  undercounted.²⁸ The Law Commission, in its 273rd Report (2017), noted that from 2001 to 2016,  barely 0.6% of custodial death cases ended in conviction.²⁹ Even more telling, the NHRC remarked  in 2023 that not a single custodial death case had seen full accountability or conviction in the past 

²⁵ Re: Inhuman Conditions in 1382 Prisons, (2016) 3 S.C.C. 700, 705–06 (issuing directions on CCTV installation  and prisoners’ rights).

²⁶ See Prakash Singh v. Union of India, (2006) 8 S.C.C. 1, 14–18 (directing creation of Police Complaints Authorities);  Commonwealth Human Rights Initiative, Police Reforms Scorecard 2024 (2024) (finding that only around 12 states  had functional PCAs).

²⁷ National Crime Records Bureau, Crime in India (2019–2023); National Human Rights Commission, Annual  Reports (2019–2023).

²⁸ V. Venkatesan, Why NCRB Data Underreports Custodial Crimes, The Hindu (Oct. 14, 2021) (explaining  structural undercounting in NCRB reports).

²⁹ Law Comm’n of India, Report No. 273: Implementation of “United Nations Convention Against Torture”  18–19 (2017) (stating conviction rate of 0.6% in custodial death cases from 2001–2016).

five years.³⁰ These numbers show how the system protects itself far more effectively than it  protects the people in its custody.

The stark gap between the number of violations and the number of convictions reveals a deep  justice deficit, a space where the law may exist on paper, but its legitimacy breaks down in  practice.³¹

III. Criminological and Socio-Legal Dimensions

1. Institutional Anomie and Police Culture

Criminological theory suggests that when institutional goals, such as securing convictions or  meeting performance targets, begin to outweigh normative commitments to rights and legality,  deviant practices gradually become normalized. This condition is known as institutional anomie.³² In the Indian context, a policing culture that still heavily relies on confessions ends up encouraging  coercive interrogation methods as “investigative shortcuts.”³³

The National Police Commission (1980) reported that nearly 60% of police interrogations relied on “third-degree methods.”³⁴ More than forty years later, the situation has hardly improved. The  lack of proper forensic training and modern investigative tools continues to push officers toward  using torture as what many call the “poor man’s investigation.”³⁵

2. Social Stratification and Impunity

A PUCL study 2022 showed that more than 70% of custodial death victims belonged to the  Scheduled Castes, the Scheduled Tribes, or the Other Backward Classes.³⁶ This pattern makes it  clear that caste and class vulnerability often overlap with custodial abuse.

³⁰ National Human Rights Commission, Annual Report 2023–24, at 45–47 (2024) (noting absence of conviction in  custodial death cases for five consecutive years).

³¹ Upendra Baxi, The Crisis of the Indian Legal System 147–48 (1982) (discussing legitimacy deficits when  enforcement mechanisms fail).

³² Steven F. Messner & Richard Rosenfeld, Institutional Anomie Theory, in Theoretical Criminology 12–15 (5th  ed. 2018).

³³ Jinee Lokaneeta, The Truth Machines: Policing, Violence, and Scientific Interrogations in India 34–36 (2020) (explaining confession-driven policing cultures).

³⁴ Nat’l Police Comm’n, Second Report 31–32 (1980) (documenting widespread use of third-degree methods). ³⁵ Pratiksha Baxi, Police Torture and the Poor Man’s Investigation, 55 Econ. & Pol. Wkly. 10, 12–14 (2020). ³⁶ People’s Union for Civil Liberties (PUCL), Who Are the Victims? A Study of Custodial Deaths in India 22–25  (2022).

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This kind of “socio-legal intersectionality” reveals that custodial violence is not simply about  maintaining discipline; it frequently becomes a means of asserting domination over those who are  already socially marginalized.³⁷

1. International and Comparative Law Perspectives

India is a party to the International Covenant on Civil and Political Rights (ICCPR, 1966), whose Article 7 clearly prohibits torture and all forms of cruel or degrading treatment.³⁸ Yet,  despite signing the UN Convention Against Torture (UNCAT) back in 1997, India has still not  ratified it.³⁹ In 2021, the UN Human Rights Committee expressed concern, observing that India’s  continued failure to formally criminalize torture weakens its credibility on the global human rights  stage.⁴⁰

Comparatively, the United Kingdom’s Police and Criminal Evidence Act (PACE), 1984, established independent custody officers and made video recording of interrogations compulsory,  ensuring transparency at every stage.⁴¹ In the United States, the Miranda doctrine goes even  further by excluding coerced confessions altogether.⁴² India, however, lacks this level of statutory  rigor. Embedding similar procedural safeguards into the BNSS could strengthen evidentiary  integrity and offer far better protection against custodial abuse.

Institutional and Legal Responses

1. Judicial Oversight and Compensation

Indian courts have often used writ jurisdiction to award compensation in cases of custodial abuse.  In Bhim Singh v. State of J&K (1985), the Supreme Court directed the state to compensate the 

³⁷ Asha Kowtal, Caste, Violence, and Policing, 56 Econ. & Pol. Wkly. 12, 15 (2021) (discussing caste-based  vulnerability and systemic domination).

³⁸ International Covenant on Civil and Political Rights art. 7, Dec. 16, 1966, 999 U.N.T.S. 171. ³⁹ U.N. Treaty Collection, Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or  Punishment, Status of Treaties (India) (showing India as a signatory but not a ratifying state). ⁴⁰ U.N. Human Rights Comm., Concluding Observations on the Fourth Periodic Report of India, U.N. Doc.  CCPR/C/IND/CO/4 ¶ 21 (2021).

⁴¹ Police and Criminal Evidence Act 1984, c. 60 (U.K.).

⁴² Miranda v. Arizona, 384 U.S. 436, 476 (1966) (requiring exclusion of statements obtained without proper  warnings).

victim for his illegal detention,⁴³ and in Nilabati Behera, it went a step further by treating such  compensation as a constitutional remedy.⁴⁴ Yet, compensation remains a largely retrospective  measure; it offers relief after the harm has already occurred, but does little to act as a genuine  deterrent or prevent future violations.

2. NHRC and Police Complaints Authorities

The NHRC’s 2010 Guidelines require every custodial death to be reported within 24 hours and  insist on independent post-mortems to prevent cover-ups.⁴⁵ However, the Commission’s powers  are recommendatory rather than binding, which means states often ignore or delay compliance.⁴⁶ State Human Rights Commissions are in an even weaker position; many operate with limited  staff, inadequate budgets, and virtually no enforcement authority.⁴⁷

3. Lack of Enforcement

The MHA’s 2023 compliance report acknowledged that barely 40% of police stations had fully  functioning CCTV cameras, despite repeated court directions.⁴⁸ Judicial inquiries required under  Section 176(1A) of the CrPC are also frequently delayed for months, diluting their effectiveness.⁴⁹ This persistent administrative inertia creates an environment where accountability is easily avoided  and impunity becomes the norm.⁵⁰

⁴³ Bhim Singh v. State of J&K, (1985) 4 S.C.C. 677, 680–81.

⁴⁴ Nilabati Behera v. State of Orissa, (1993) 2 S.C.C. 746, 754–55.

⁴⁵ National Human Rights Commission, Guidelines on Custodial Deaths ¶¶ 1–4 (2010) (requiring reporting of  custodial deaths within 24 hours and mandating independent post-mortems).

⁴⁶ Gautam Bhatia, The Promise and Limits of the NHRC, 45 Econ. & Pol. Wkly. 15, 17 (2010) (noting the non binding nature of NHRC directions and weak compliance).

⁴⁷ Asian Centre for Human Rights, National & State Human Rights Commissions: Performance Report 2021 18– 22 (2021) (highlighting structural weaknesses of SHRCs).

⁴⁸ Ministry of Home Affairs, Status of Compliance Report on CCTV Installation in Police Stations 6 (2023) (noting  only about 40% compliance nationally).

⁴⁹ See Code of Criminal Procedure, 1973, § 176(1A) (India); Commonwealth Human Rights Initiative, Stalled  Reforms: Custodial Deaths and Judicial Inquiries 9–11 (2022) (documenting delays in judicial inquiries). ⁵⁰ Justice A.P. Shah, Impunity and Police Reform in India, 12 Indian J.L. & Just. 1, 8–10 (2021) (explaining how  administrative inertia entrenches custodial impunity).

Reform Agenda: From Law to Enforcement

1. Statutory Codification of D.K. Basu Guidelines

The D.K. Basu safeguards should be incorporated directly into the BNSS, 2023, with clear  penalties for officials who fail to follow them.⁵¹ Turning these principles into statutory  requirements would shift them from being moral expectations to enforceable legal duties.

2. Independent Custodial Death Investigation Authority (ICDIA)

India should create an autonomous body within the NHRC that has its own forensic and  prosecutorial authority, modeled on the UK’s Independent Office for Police Conduct, to ensure  that investigations into custodial deaths are genuinely independent and free from police  influence.⁵²

3. Criminalization of Torture

India should revive the Prevention of Torture Bill, 2010, and update it to reflect UNCAT  standards, clearly defining torture, ensuring strong protections for victims and witnesses, and  allowing for universal jurisdiction so that accountability cannot be avoided.⁵³

4. Technological and Medical Oversight

Policymakers should mandate continuous CCTV surveillance, digital arrest memos, and  mandatory medical check-ups every 12 hours for people in police custody. Tampering with  evidence must be made a distinct, punishable offence.⁵⁴

5. Judicial Monitoring

High Courts should set up dedicated Custodial Justice Benches to carry out quarterly reviews of  how well states are complying with Section 176(1A) of the CrPC and the directions issued by the 

⁵¹ D.K. Basu v. State of W.B., (1997) 1 S.C.C. 416, 427–30 (laying down binding arrest and detention guidelines);  Bharatiya Nagarik Suraksha Sanhita, 2023 (India).

⁵² Independent Office for Police Conduct, Statutory Guidance (U.K. 2020) (describing independent investigative  powers); cf. National Human Rights Commission, Functions and Powers, nhrc.nic.in. ⁵³ Prevention of Torture Bill, 2010 (India) (lapsed); U.N. Convention Against Torture and Other Cruel, Inhuman  or Degrading Treatment or Punishment, Dec. 10, 1984, 1465 U.N.T.S. 85; Law Comm’n of India, Report No.  273 (2017) (recommending criminalization of torture).

⁵⁴ Supreme Court of India, Re: Inhuman Conditions in 1382 Prisons, (2016) 3 S.C.C. 700, 705–06 (mandating  CCTV installation and monitoring); Code of Criminal Procedure, 1973, § 54 (India) (medical examination of  arrested persons)

NHRC.⁵⁵

6. Cultural and Educational Reform

Police academies should integrate human rights training, psychological counseling, and modern  forensic interviewing techniques into their curriculum.⁵⁶ Genuine reform will only take root when  the policing mindset shifts away from punitive instincts and aligns itself with a deeper  constitutional ethos.⁵⁷

VII. Transformative Constitutionalism: From Text to Justice

Transformative constitutionalism views the Constitution as a living document designed to  challenge and reshape unequal power structures. As Justice D.Y. Chandrachud noted in Navtej  Johar v. Union of India (2018), “the Constitution exists to convert moral aspirations into social  realities,”⁵⁸ reminding us that its true purpose lies in creating meaningful change in people’s  everyday lives.

Seen through this lens, custodial reform is not just an administrative fix; it is a moral obligation  tied to the very promises of the Indian Constitution. Every custodial death thus diminishes the  Constitution’s legitimacy,⁵⁹ while every step that prevents such tragedies brings us closer to  realizing its true spirit.⁶⁰

Conclusion

Custodial deaths are not accidental; they are the foreseeable outcome of an environment where  impunity has been allowed to take root through years of neglect. India possesses the legal  framework to prevent such abuses, but what is missing is the moral commitment and administrative 

⁵⁵ Code of Criminal Procedure, 1973, § 176(1A) (India); National Human Rights Commission, Guidelines on  Custodial Deaths ¶¶ 1–4 (2010) (mandating reporting and inquiry procedures).

⁵⁶ Jinee Lokaneeta, The Truth Machines: Policing, Violence, and Scientific Interrogations in India 112–15 (2020) (advocating human rights training and scientific interrogation in police academies).

⁵⁷ Amod Kanth, Police Ethics and Democratic Policing in India, 62 J. Indian L. Inst. 45, 50–52 (2021) (discussing  shifts from punitive policing to constitutional policing).

⁵⁸ Navtej Singh Johar v. Union of India, (2018) 10 S.C.C. 1, 122–23 (Chandrachud, J., concurring). ⁵⁹ Upendra Baxi, The Crisis of the Indian Legal System 84–86 (1982) (linking state violence to decline in  constitutional legitimacy).

⁶⁰ Sujit Choudhry, Transformative Constitutionalism and the Indian Constitution, 5 Nat’l L. Sch. India Rev. 23,  28–30 (2013) (explaining the connection between constitutional morality and institutional reform).

resolve to enforce it. Real change requires independent investigations, stricter and binding  oversight, and ratification of international human rights standards. ⁶¹

Ultimately, the struggle against custodial violence is a struggle to protect the Constitution itself.  As the Supreme Court observed in Francis Coralie Mullin, the right to life is not merely the right  to survive but the right to live with dignity. ⁶²

A state that cannot safeguard dignity within its own custody weakens the very foundation of  democracy. Ending custodial deaths, therefore, is not just about reforming policing; it is about  restoring faith in the Republic.⁶³

⁶¹ Law Comm’n of India, Report No. 273: Implementation of “United Nations Convention Against Torture”  37–40 (2017) (recommending ratification of UNCAT and strengthening oversight).

⁶² Francis Coralie Mullin v. Adm’r, Union Territory of Delhi, (1981) 1 S.C.C. 608, 618 (“The right to life includes  the right to live with human dignity…”).

⁶³ Pratap Bhanu Mehta, The Burden of Democratic Institutions, 57 Econ. & Pol. Wkly. 22, 25–27 (2022) (arguing  that state violence erodes democratic legitimacy).

Bibliography

1. Books

• Jinee Lokaneeta, The Truth Machines: Policing, Violence, and Scientific Interrogations in India (2020).
• Steven F. Messner & Richard Rosenfeld, Institutional Anomie Theory, in Theoretical Criminology (5th ed. 2018).
• Pratiksha Baxi, Public Secrets of Law: Rape Trials in India (2014).
• Upendra Baxi, The Crisis of the Indian Legal System (1982).
• Sujit Choudhry, Transformative Constitutionalism and the Indian Constitution (2013). • A.P. Shah, Impunity and Police Reform in India (2021).
• Amod Kanth, Police Ethics and Democratic Policing in India (2021).

1. Government Reports, Commission Reports & Official Publications

• Law Commission of India, Report No. 273, Implementation of UN Convention Against Torture (2017).
• National Crime Records Bureau, Crime in India (2019–2023).
• Ministry of Home Affairs, Status of Compliance Report on CCTV Installation in Police Stations (2023).
• National Human Rights Commission, Guidelines on Custodial Deaths (2010). • National Human Rights Commission, Annual Report (2023–2024).
• National Police Commission, Second Report (1980).
• Commonwealth Human Rights Initiative, Police Reforms Scorecard (2024).
• Commonwealth Human Rights Initiative, Stalled Reforms: Custodial Deaths and Judicial Inquiries (2022).
• Asian Centre for Human Rights, National & State Human Rights Commissions: Performance Report (2021).
• People’s Union for Civil Liberties (PUCL), Who Are the Victims? A Study of Custodial Deaths in India (2022).

1. Journal Articles & Periodical Sources

• Gautam Bhatia, The Promise and Limits of the NHRC, 45 Econ. & Pol. Wkly. 15 (2010).
• Pratiksha Baxi, Police Torture and the Poor Man’s Investigation, 55 Econ. & Pol. Wkly. 10 (2020).
• Asha Kowtal, Caste, Violence, and Policing, 56 Econ. & Pol. Wkly. 12 (2021).
• Pratap Bhanu Mehta, The Burden of Democratic Institutions, 57 Econ. & Pol. Wkly. 22 (2022).

1. International Instruments & UN Documents

• International Covenant on Civil and Political Rights, Dec. 16, 1966, 999 U.N.T.S. 171.
• Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, Dec. 10, 1984, 1465 U.N.T.S. 85.
• U.N. Human Rights Committee, Concluding Observations on the Fourth Periodic Report of India, U.N. Doc. CCPR/C/IND/CO/4 (2021).

1. Cases (Indian & Foreign)

Indian Supreme Court Cases

• D.K. Basu v. State of W.B., (1997) 1 S.C.C. 416.
• Nilabati Behera v. State of Orissa, (1993) 2 S.C.C. 746
• Maneka Gandhi v. Union of India, (1978) 1 S.C.C. 248.
• Francis Coralie Mullin v. Adm’r, Union Territory of Delhi, (1981) 1 S.C.C. 608. • Prakash Singh v. Union of India, (2006) 8 S.C.C. 1.
• Re: Inhuman Conditions in 1382 Prisons, (2016) 3 S.C.C. 700.
• Navtej Singh Johar v. Union of India, (2018) 10 S.C.C. 1.
• Bhim Singh v. State of J&K, (1985) 4 S.C.C. 677.

United States

• Miranda v. Arizona, 384 U.S. 436 (1966).

1. Statutes (India & Foreign)

• India Const. arts. 20(3), 21, 22.
• Code of Criminal Procedure, 1973 (India).
• Protection of Human Rights Act, 1993 (India).
• Bharatiya Nyaya Sanhita, 2023 (India).
• Bharatiya Nagarik Suraksha Sanhita, 2023 (India).
• Prevention of Torture Bill, 2010 (India) (lapsed).
• Police and Criminal Evidence Act 1984 (U.K.).

1. Online News & Media Sources

• Jacob Koshy, Tuticorin Custodial Deaths Spark Nationwide Outrage, The Hindu (June 27, 2020).
• V. Venkatesan, Why NCRB Data Underreports Custodial Crimes, The Hindu (Oct. 14, 2021).
• Abhinav Sekhri, Missed Chances in the New Criminal Codes, The Wire (Aug. 2023).