The Andhra Pradesh government informed the High Court that strict DGP-level guidelines already prohibit police from publicly parading accused persons, and that disciplinary action has been taken against violators. Satisfied with the state's submission, the High Court closed the PIL challenging the practice. The case revives attention to the constitutional and custodial rights of accused persons — a core area tested in CLAT PG through landmark Supreme Court precedents on police accountability.

Public parading of accused persons — where police display handcuffed or restrained suspects before media or crowds before conviction — violates multiple constitutional and statutory protections. The Supreme Court has consistently treated this as a breach of Article 21 (right to life and personal dignity), Article 20(3) (protection against self-incrimination), and the presumption of innocence.

The landmark case directly on point is Joginder Kumar v. State of UP (1994), where the Supreme Court laid down strict guidelines on arrest and custody, holding that arrest must not be used as a tool of harassment. The Court emphasised that the power of arrest must be exercised with restraint and that the dignity of the accused cannot be violated during investigation.

D.K. Basu v. State of West Bengal (1997) extended this framework comprehensively, issuing binding guidelines on custodial conduct — including that the accused must not be subjected to degrading treatment. These guidelines were subsequently codified: Section 41B of the CrPC (now mirrored in the BNSS) requires that the arrested person not be subjected to unnecessary restraint or public display.

International law adds another layer: Article 10 of the ICCPR (to which India is a party) mandates humane treatment of detainees. India has signed but not ratified the UN Convention Against Torture (CAT, 1984), a fact specifically tested in CLAT PG 2021.

The AP High Court closing the PIL on the strength of executive guidelines — rather than issuing fresh judicial directions — signals that institutional compliance, when demonstrated, can satisfy constitutional courts. However, the underlying rights remain enforceable independently under Article 32 or Article 226.