 Let us look at some of the evidence from the past. Consider police organisations in liberal democracies such as the USA. The influential Report on Lawlessness in Law Enforcement from the National Commission on Law Observance and Enforcement, also know as the Wickersham Commission, in 1931 found that the use of the third degree was widespread throughout police organisations in the USA (National Commission on Law Observance and Enforcement 1931, 4). More recently, we have the Rampart Reports documenting extensive police brutality – including extra-judicial killings (Parks 2000, 87–109; Rampart Independent Review Panel 2000, 11–14)  – and, in the wake of the Rodney King beating, the report of the “Christopher Commission” into the Los Angeles Police Department which found that a significant number of LAPD officers “repetitively use excessive force against the public and persistently ignore the written guidelines of the Department regarding force” (Independent Commission on the Los Angeles Police Department 1991, 9–12). In India – another liberal democratic state, albeit one at an earlier stage of economic development – police brutality is institutionalised. According to a recent Human Rights Watch Report (Human Rights Watch 2009: 14), “police violence and misconduct are … widespread and rooted in institutional practice”. Arvind Verma, an authority on policing in India, states that “Misuse of force, false-encounter killings (execution by police) and routine use of torture in extorting confessions are common with the police departments” (Verma 2011: 5).