Complainu before the Commission violated. The police records, on the other hand, stated that he was arrested on 14 November and released on the same day after execution of a personal bond. From the investigation by the NHRC team, it became clear that the police had manipulated the documents and records to cover their misdeeds. Since the police arrest of Rama Rao was both illegal and malafide, the Commission expressed deep distress at the manner in which the police had violated the constitutional rights of Rama Rao, an innocent law abiding person, who was illegally confined and tortured. The Commission recommended that the Government of Andhra Pradesh pay Rs. 25,000/- as immediate interim compensation to Rama Rao, and that they initiate departmental proceedings against the police officials and take such other appropriate action against them as may be necessary. The Commission has received a compliance report from the Government of Andhra Pradesh with regard to the payment of compensation. COMMENT Article 9 of the Universal Declaration of Human Rights, as well as Article 9 of the International Covenant on Civil and Political Rights, emphasise that no one shall be subjected to arbitrary arrest, detention or exile. In the above case, there is a violation of the fundamental right guaranteed in Ardcle 21 of the Constitution, which stipulates that no one shall be deprived of his life or personal liberty, except according to procedure established by law. Arrest involves restriction of liberty of a person arrested, and therefore, infringes the basic human rights of liberty. Nevertheless, the Constitution of India, as well as International human rights laws, recognise the power of the State to arrest any person as a part of its primary role of maintaining law and order. The Constimtion requires a just, fair and reasonable procedure established by law under which alone such deprivation of liberty is permissible. Article 22(1) of the Constitution provides that every person placed under arrest shall be informed as soon as may be of the grounds of arrest and shall not be denied the right to consult and be defended by a lawyer of his choice; and Section 50 of the Code of Criminal Procedure, 1973, requires a police officer arresting any person to 'forthwith communicate to him full particulars of the offence for which he is arrested or other grounds for such artist'. However, in acmal practice, these requirements are observed more in the breach. Likewise, the requirement of prompt production of the arrested person before the court is mandated both under the Constitution [Article 22(2)] and the Cr.PC (Section 57), is also not adhered to strictly. A large number of complaints pertaining to human rights violations are in the area of abuse of police powers, particularly those of arrest and detention. Therefore, with a view to narrowing the gap between law and practice, the Commission found it necessary 115