Comparative Study of Police Systems:

1. Saudi Arabia: Saudi Arabia is a typical model of centralized 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 [5] .

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 [6] .

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 [7] .

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 [8] .

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 [9] .

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.