Comparative Study of Policing Models
Policing is one of the most important of the functions undertaken by the every sovereign government. For the state machinery, police is an inevitable organ which would ensure maintenance of law and order, and also the first link in the criminal justice system. On the other hand, for common man, police force is a symbol of brute force of authority and at the same time, the protector from crime. Police men get a corporate identity from the uniform they wear; the common man identifies, distinguishes and awes him on account of the same uniform. The police systems across the world have developed on a socio cultural background, and for this reason alone huge differences exist between these police systems. From the singular coordinated centralised system of police in Saudi Arabia organised under the Ministry of Interior to the 42000 odd police forces that exist in USA, policing mainly rests on either of the two broad principles: (1) Policing by consent and (2) Policing by law.
This paper tries to examine the various police systems that exist in the world, taking Saudi Arabia, China, France, Spain, United Kingdom, the United States of America and India, as examples of various types of policing models. The paper takes cue from these systems, their positives and negatives, and tries to find out how the Indian System, can be understood in the light of these policing models.
“The modern police service is a varied, multi-layered, responsive institution working to ensure the safety of Citizens" – UK Home Office  .
The role of a modern police organisation is laid down succinctly in the above quote appearing in the web page of UK Home Office.The first idea that comes to our mind when we hear the term “Police" is the idea of a dominant personality who symbolizes the power of the State and criminal justice administration system. On the one hand people view police as a protector of civil liberties and on the other hand police is viewed as a symbol of brute force of state which oppresses the legitimate protests with force.
Dictionaries define Police as the governmental department charged with the regulation and control of the affairs of a community, now chiefly the department established to maintain order, enforce the law, and prevent and detect crime.
Significance of Police in Social life:
Represents the presence of civil body politic in everyday life.
Conveys a sense of power or sacredness that lies at the root of political order.
Represents the means by which the political authorities maintain status quo.
Represent the capacity of state to deter citizens from committing acts that threaten the order they are believed to symbolize.
Gives a corporate identity to the police men. 
Basic goals of Policing:
Protect civil rights, liberties
Role of Police:
The role of police is to address all sorts of problems when and in so far as their solutions do or possibly require the use of force at the point of their occurrence. Manning remarks that “...policing is an exercise in symbolic demarking of what is immoral, wrong and outside the boundaries of acceptable conduct. It represents the state, morality and standards of civility and decency by which we judge ourselves  . “
Police is viewed as fulfilling the following roles in social life:
A Law Enforcer
A Service Provider
Authority of Police:
The authority of police comes from the people- their laws and institutions. Police agencies are not only part of the community but also part f the government, which determine their formal base of authority and of criminal justice system, which determines society’s course in deterring lawbreakers and rehabilitating offenders. In a Constitutional system, the ultimate authority springs from the Constitution itself. The authority of police in every jurisdiction is derived from the sovereign authority- it could be either the Constitution which gives the elected government executive authority over the subjects or the “grund norm" which gives the sovereign authority over its subjects devoid of any written constitution.
Different Models of Policing:
The organisation of police in different countries is primarily rooted on the socio-cultural and historic background of the country. For example in UK which has long tradition of parliamentary democracy, policing works on the principle of consent by the population, where as in most other countries, policing power is vested on state by law.
As such the police organisations have nothing in common in many countries except their basic goals(in some jurisdictions even these goals do not match!). However criminologists have tried to bring out common features in police structures world over on the basis of certain features, the most prominent of them being the command architecture.
1. Classification based on legitimacy or legal backing of police function:
Policing by consent
Policing by law
2. Classification based on Command structure  :
In this model classification is based on two dimensions:
A. Number of forces to be commanded: If the entire police force in the country is organised as a single force under a single commander, the model is called Singular model, and if in a single country, there are a number of police forces, like in India, it is called “Multiple model". Inside the multiple model, if the polices forces have well defined territories of functioning and their functions do not overlap each other, the model is called Multiple Coordinated, if the case is reverse as in India, where many agencies can have overlapping jurisdictions, it is called Multiple Uncoordinated.
B. Type of forces: If the police forces in a country is highly organised and having a centralised command, it is called Coordinated Centralised police force, and if the police forces in a country do not have an apparent centralised command structure, it is called “decentralised command structure".
Comparative Study of Police Systems:
1. Saudi Arabia: Saudi Arabia is a typical model of centralised coordinated police force with a singular line of command emanating from the King. Both Minister of Interior and Director of Public Safety are appointed by the King and both are usually senior members of the King’s family itself. The Police known as Public Security police is responsible for general policing throughout the country and derives its authority from Executive Orders and the Shariah. Public Security Police is divided into Regular Police and Special Investigative Police (SIP) known as “Mubahit". Regular Police is directly under the control of Ministry of Interior, and is run by Director of Public Safety. SIP works under the control of General Directorate of Investigation (GIP) and is responsible for criminal investigations and manages domestic security and counter intelligence functions. In addition to the Public Security Police, there is also a religious police called Mutawwiun, which is directly under the King, and whose main duty is enforcement of Islamic Shariah, Since Mutawwiun generally takes the form of a religious band, and is not responsible for any general law and order maintenance functions, they are more a religious sect, than a police force. Except the Mutawwiun, police force is organised as a single unit in Saudi Arabia.
While this is the general picture of policing in Saudi Arabia, there are jurisdictional pockets of tribal authority in Saudi Arabia, which is beyond the reach of even the King’s justice. In the tribal pockets, the tribal elders are a law unto themselves and they do not entertain the interference of any external authorities. So law and order or criminal investigation issues in these pockets are undertaken by the tribal elders themselves, with the regular police giving tactical support wherever required.
One important feature of Saudi Police System is that the line distinguishing the Saudi Regular Armed forces and Police is very narrow and many a times the policing functions are amply supported by Saudi National guard and the armed forces  .
2. China: China is another model of Singular Coordinated Centralised police force. The Ministry of Public Security (MPS) is a functional organization under the State Council in charge of public security work nationwide. Public security departments are set in provinces and autonomous regions; metropolitan public security bureaus are set in direct municipalities; public security bureaus or divisions are assigned to cities and prefectures; sub-bureaus are set in sub-regions of cities, under the direct leadership of their superior public security agencies; public security bureaus are set in counties and banners, under the leadership of their respective local government and superior public security agencies. Dispatched police stations are directly subordinate to their superior public security bureaus and sub-bureaus in counties and banners.
3. France: France is a typical example of a police force with Multiple Coordinated centralised force.
France has two national law enforcement agencies:
Police Nationale, formerly called the Sûreté- a civilian force; primary responsibility in urban areas; run under the Ministry of the Interior)
Gendarmerie Nationale, a gendarmerie; primary responsibility in rural areas and military installations; run under the Ministry of Defence and under operational control, for most purposes, of the Ministry of the Interior).
Apart from these two, there are other agencies like:
Direction générale des douanes et droits indirects, a civilian customs service more commonly known as the “Douane", under the Minister of Budget, Public Accounting and Civil Servants.
French municipalities may also have a local police called the Police municipale, Garde municipale or Garde champetre, with restricted powers: they can only enforce the municipal by-laws  .
4. United Kingdom: United Kingdom (UK) which comprises of England, Scotland and Northern Ireland is the world oldest democracy and policing in UK also grown from the principle of “policing by consent". Even though the basic premise of policing in UK is by consent, the British Police system as it exists now is more a reverse process of investing more power in people by law, than policing by consent. As such, the policing in UK has now become policing by law, but a law which mandates a police which is accountable to public.
UK is a typical example of Multiple Coordinated Decentralised police force. UK does not have a national police service, but a network of 43 individual police forces responsible for policing specific counties, cities or areas, excluding the forces with special jurisdiction. These 43 forces are formed of more than 140,500 police officers, 14,000 volunteer special constables and 13,400 community support officers.
UK has a three-way system of responsibility ensures forces run smoothly:
Home Office funds the police and has the overall responsibility as overseer and coordinator of the police forces.
Police Authorities make sure local forces operate efficiently and effectively.
Chief Police Officers have responsibility for the direction and control of regional forces.
According to UK Home Office, this system prevents political interference in policing and avoids giving any single organisation power over the entire police service. In addition there is an independent Police Complaints Authority and an Inspectorate of Constabulary. While the Police Complaints Commission examines the complaints against the police officials, the Inspectorate of Constabulary acts as an audit wing for the police which examine and assess the efficiency of police. The Police Reforms Act, 2002 requires the Home Secretary to prepare a annual Policing Plan and to place it before the legislature. The budgetary control of each police force rests with the Police Authority, which consists of at least 17 members. There is representation for local elected representatives, judiciary and common men, In every police authority, such representation includes nominations from the Home Office as well as members selected through an open recruitment process. All bodies like Inspectorate of Constabulary, Independent Police Complaints authority and Police Authorities function as independent bodies with separate corporate identity, distinct from that of police  .
5. Spain: Spain is a typical example of a multiple Uncoordinated Centralised police force. As in almost all European Countries, policing is based on the principle of “Policing by law". The system is called Multiple Centralised uncoordinated force since, there is more than one police force in the country, but at the top both these forces report to the same authority. The authority of these forces overlaps in many places.
In conformity with the Constitution, the organic law on law enforcement bodies defines the structure of public safety in Spain.
Under the Spanish constitution, public safety is the responsibility of the State alone and national Government's role to maintain security. Autonomous communities and local corporations may participate through their own security forces in the law and order maintenance and crime investigation functions of police. Spain has a National Police, which is a civilian force and operates basically in urban areas. The Guardia Civil (Civil Guard), which is a military force and operates mainly in rural areas. Local communities have either units of police forces attached to their executives or their own police forces  .
6. United States of America: There’s no national police force in the US, where policing is organised on a state and local basis. The country has around 500,000 police officers and a total of 40,000 separate police forces, over half of which are simply one or two-man sheriffs’ offices in small towns. In addition to regular full-time police officers, many towns have auxiliary, part-time police officers, special duty and volunteer sheriff’s posses (which assist sheriffs’ offices in some areas).
Law enforcement in the United States is decentralized. Federal authorities deal with violations of federal law that fall within their specific jurisdictions. There are approximately 65 different federal police agencies. At the local level, each of the 50 sovereign states has its own state legislature that enacts criminal statutes under their state constitutions. Most of the U.S. States have police at all levels - municipal, county and state level.
Specific Organisational features of police vary greatly from small informally organised departments with 2-3 employees to highly organised metropolitan departments with numerous sub divisions and thousands of employees.
Police structures vary greatly among and within the federal, state and local levels. Primary responsibility of policing is at local level. State level officials have only specific duties  .
7. Police in India: India tops the number of Police men in the world countries with 1,032,960 police personnel. USA has the second largest police force in the world with 941,139 police officers. UK and France come 9th and 10th respectively. However considering the population of the country, India has only 0.956207 per 1,000 people and comes 47th in the world countries, while, UK with 2.04871 per 1,000 people stands at 34th position.
Indian model of police organisation is an example for a multiple unorganised decentralised policing. In sharp contrast to the British principle of policing by consent, India follows policing by law. Each state has its own police force, whose top echelons are filled by officers of Indian Police Service, which is a central service. Many analysts have commented that the Indian Police Act, 1861, which was brought into force immediately after the First War of Indian Independence in 1857 was based on distrust of Indian officials and was aimed at ensuring strict control over the Indian population. Even after attaining independence, successive governments did not try to change this basic character of Indian Police force. Though the framers of the Indian Constitution envisaged police as a state subject, vide Article 246 read with entries I & 2 of List II of Seventh Schedule of Indian Constitution, most Indian states opted to adopt the Indian Police Act, 1861 without any change, while the very few states, including Kerala which opted for Police Act of its own, modeled its statute broadly based on the Indian Police Act, 1861 itself. Even the model Police Act, 2008 does not have any basic difference from the philosophy of Indian Police Act, 1861.
While we can broadly classify the Indian Police organisation as a multiple, un coordinated, decentralised model, the presence of IPS officers at the top ranks of most police forces create an oblique Centralised control.
The quasi-federal character of the Indian polity, with specific provisions in the Constitution, allows a coordinating and counseling role for the Centre in police matters and even authorizes it to set up certain central police organisations.
The head of the police force in each state is the Director General of Police (DGP) -responsible to the state government for the administration of the police force in each state, and for advising the government on police matters. The DGP represents the highest rung in the police hierarchy.
The hierarchical structure of the police in India follows a vertical alignment consisting of senior officers drawn, by and large, from The Indian Police Service (IPS) who do the supervisory work, the "upper subordinates" (inspectors, sub-inspectors, and asst. sub-inspectors) who work generally at the police station level, and the police constabulary who are delegated the patrolling, surveillance, guard duties, and law and order work. The constabulary accounts for almost 88% of total police strength.
Section 3 of the Police Act, 1861 vested the superintendence of the state police force in the state government.
A system of dual control at the district level is introduced under Sec.4 of Indian Police Act, 1861. It places the police forces under the District Superintendent of Police, but subject to the “general control and direction" of the District Magistrate. The draft Police Act, 2008 apparently tries to change this dual control.
Lessons Learned from Comparative Study:
An analysis of various models brings out the following lessons:
Popular consent on policing is a very uncertain concept and policing by law and by consent has now become almost intertwined.
Most countries, irrespective of the model they follow, give importance to public consultations and local help in the policing activities- though sometimes not formally.
In almost all these sample jurisdictions, with the exception of China, there is clear separation of crime investigation from law and order maintenance duties.
Lessons from developmental history of Indian Police Structure:
At this juncture, it is pertinent to look at the ancient system of policing that was prevalent in India. A vivid picture of the ancient police system is available in various ancient texts, including Arthasastra by Kautilya(Chanakya)  .
Ancient Police system in India was based on the principle of local responsibility and mutual cooperation. In the village, security and peace was a matter of collective responsibility and shared by every resident of the village. One of the villages, called, gramneta or village watchman is responsible to protect the village from the criminals while the body corporate of the village was bound to make good the loss due to crime committed within the village limits, except in cases where they were able to trace the offenders or succeeded in fixing responsibility of crime upon neighboring villages.  This village level responsibility continues, though in its rudiments, even today, which is seen embodied in section 40 of Code of Criminal Procedure, 1973, which imposed a duty on officers employed in connection with the affairs of a village and each person residing in a village to communicate to the nearest magistrate or to the officer in charge of the nearest police station certain information.
“Regulations for the Police of Collectorships of Bengal Bihar and Orissa", known as Regulation No XXII of 1793 of Lord Cornwallis, made the Police in the country the exclusive charge of the Government and who may be specially appointed to that trust. 
Police commission of 1860, whose recommendations culminated in the Indian Police Act, 1861, recommended that Police under each local government or administration shall constitute one force and be under the officer to be styled Inspector General of Police, in whom should be vested the control over the organization, the responsibility of maintaining it in a state of efficiency by proper attention to its training and discipline, internal economy and its general rearrangement through its own officers. It was also inter alia recommended that the office of Village watchman should be retained, being an ancient institution of India, since village watchman was “a man of village but not enough an official to be alien or obnoxious to the villagers, but only an official to be amenable to systems and reliable for duty on behalf of the police." 
Thus it can be seen that the British how much so ever they were contemptuous of the integrity of local people, were convinced that the policing would not be successful without a tolerably reliable agency in the villages.
The Indian Police Act, 1861 did not come into force automatically in all the provinces since there was a provision in it, which stipulated that the Act would be applicable to any province only when so notified by Governor General in Council. The Act was never applied in Provinces of Madras, Bombay and Sind, which had separate Police Acts. (Police Act of 1859 in Madras and Bombay District Police Act II of 1867 in Bombay, were almost similar to Indian Police Act, 1861 with certain changes based on local conditions).
The Police Commission of 1902 recommended setting up separate Criminal Investigation Department in each province for collecting and distributing information regarding criminals and organized crimes and for assisting in the investigation of complicated cases. It also recommended establishing an organization under Inspector General of Police, for the whole of India in the line of Police Organisation for Provinces. It also contained an important recommendation outlining the paramount importance to develop and foster the existing village agency for police work.
A comparative study of the policing across the models examined, undertaken by Nation Master  shows that of the models examined, the percentage rate of public confidence in policing is as follows:
United Kingdom: 77%
USA : 73%
France : 67%
The other countries including India are not even featuring in the sampling. This can give rise to an assumption that multiple police forces instill more confidence in the public about the policing, as they have more reach than a singular system as followed in Saudi Arabia or China, but this conclusion should be taken only against the caution that the sampling may not even have included these countries.
Assimilation of Lessons:
While as a democracy, India should be striving towards an inclusive policing, where the policing functions are carried out on the basis of popular consent, accountability and transparency is also required and in this the British models of making police accountable to the public is worth emulation. In fact, the Police Complaints Authority (PCA), which is already brought in force in many states in India as an aftermath of Prakash Singh judgment,  is nothing but a copy of the English model.
While the emphasis of the UK model is participatory management of the police system, it appears that emphasis of the Indian models is to vest more discretion on the executive authorities.
It is also sad to note that there are no suggestions in the existing reform recommendations  to augment the existing system of village level cooperation in policing. S 72 of the draft Kerala Police Act, 2008 for example provides for a system of community policing, which perhaps is the sole proposition in the whole of the draft statute that calls for community consultations. However, there are no provisions which make the recommendations of the Community Liaison Group mandatory and this would make the community policing an exercise to create informants rather than participants in the policing process.
Even the Police commissions appointed by successive governments which formed the basis of the guidelines issued by the Supreme Court  in this regard, did not give as much thrust to the democratization as to the independence of the police force from the governmental intervention.
Conclusion & Suggestions:
On the basis of the analysis of the police systems across countries, the following suggestions are made:
There is a need to amend the various Police Acts in the country to bring in more accountability and transparency in the functioning of police.
Instead of governmental functionaries, independent personnel having wide experience and knowledge in law, management, accounting, social service etc, should be appointed as members of the bodies which make appointments and handle complaints against police.
As pointed out in Prakash Singh judgment  , there should be independent Police Complaints Authority to handle complaints against police men and independent State Security Commission to handle appointment of top officials of police. The members of these bodies should be selected through an open recruitment process, and the selection committee can comprise of the members mentioned currently as members of State Security Commission. At least 1/3rd of the members of the State Security commission and Police Complaints Authority shall be drawn from judiciary/legal academicians in consultation with the Chief Justice of High Court.
Functions of State Security Commission should also include a general supervision of the investigative functions, including providing facilities for crime investigation, though it is not desirable to give the Commission any powers to interfere in case to case investigation.
State Security Commission as envisaged by National Police Commission draft is also an appellate authority to whom complaints regarding illegal or irregular orders from superiors is to be made. A proper avenue for venting such complaint and more importantly for recording the same, would create a sense of independence in the police psyche which is essential to ensure a free and fearless police force.
The Police Complaints Authority should be given the powers to record all sorts of complaints against the police officers and to publish the details there of in the website for public scrutiny. This would help a greater accountability in the police.
There should be a proper enforcement mechanism for the findings of Police Complaints Authority. The findings of the Authority should be final and the Police Complaints Authority should be designated as the sole disciplinary authority over the police officials, failing with the exercise of Police Complaints Authority in discharge of their duties would go waste
In conclusion, it must be said that if the policing in India has to imbibe the true spirit of community participation and become a role model for the policing, then the emphasis on executive discretion should give way to participatory policing and there administration of police should be made more transparent and participatory. It should be borne in mind that in a modern democracy police has a great role in keeping the social fabric together and ensuring the continuance of democracy. Hence it is important to modify the negative perception about the police that is deep rooted in the commoners psyche as an instrument of torture by the power wielders, and to create a feeling of comity in the public mind that police is their friend and guide and the representative of common men in combating crime, who is accountable to public for their deeds and misdeeds. Equally important is the feeling of comfort in the minds of police men who should be freed from arbitrary interference from powers-that-be in discharge of their duties to ensure their allegiance to cause of common men and to uphold the scepter of justice entrusted to them by law in a just and equitable manner, acceptable to common man.