MALAK SINGH ETC. vs STATE OF PUNJAB & HARYANA & ORS

The Supreme Court held that the prevention of crime is a primary duty of the police under Section 23 of the Police Act, 1861, and that surveillance of suspected habitual offenders is permissible under the Punjab Police Rules. However, such surveillance must not infringe on the fundamental rights to personal liberty under Article 21 and freedom of movement under Article 19(1)(d) of the Constitution. The Court ruled that the maintenance of a surveillance register is lawful, provided it adheres to the prescribed limits and does not allow public access, thus upholding the confidentiality of the information contained within it.