Encounters, or extrajudicial killings, have been a long-standing issue in India. The use of encounters by law enforcement agencies as a means of dealing with criminal activity has often been criticized for being unconstitutional and violative of human rights. In response to this, the Indian judiciary has intervened in a number of cases to ensure that the use of encounters is regulated and brought under the purview of the law. This article will provide an analysis of the provisions and case laws surrounding judicial intervention in encounters in India in 2023.

Provisions:
The Indian Constitution guarantees the right to life and liberty to every citizen, and the use of encounters is seen as a violation of this right. Additionally, the Criminal Procedure Code (CrPC) and the Indian Penal Code (IPC) provide for the regulation of the use of force by law enforcement agencies. The CrPC also provides for the establishment of an independent body, the National Human Rights Commission, to investigate instances of human rights violations by law enforcement agencies.

Case laws:
Over the years, the Indian judiciary has intervened in a number of cases to regulate the use of encounters by law enforcement agencies. One of the most significant of these cases was the encounter of Sohrabuddin Sheikh, a criminal who was killed by the police in 2005. The Supreme Court of India took suo moto cognizance of the case and ordered a CBI investigation into the encounter. The court also established guidelines for the use of encounters by law enforcement agencies, including the requirement for an independent investigation into the encounter and the filing of a First Information Report (FIR).

Another significant case was the encounter of 19-year-old Ishrat Jahan in 2004. The Gujarat police had claimed that Jahan was a terrorist, and had killed her in an encounter. However, the Gujarat High Court ordered an investigation into the encounter and found that Jahan had been killed in a fake encounter. The court ordered compensation to be paid to Jahan's family and ordered the investigation to be handed over to the CBI.

In 2023, the Indian judiciary continued to intervene in encounters by law enforcement agencies. One of the most significant cases was the encounter of Vikas Dubey, a notorious criminal who was killed by the police in 2020. The Supreme Court of India ordered a CBI investigation into the encounter and found that Dubey had been killed in a fake encounter. The court also ordered compensation to be paid to Dubey's family, and established guidelines for the use of encounters by law enforcement agencies.

Analysis:
The intervention of the judiciary in encounters is a positive step towards ensuring that the use of encounters is regulated and brought under the purview of the law. However, there are concerns that the guidelines provided by the courts are not being followed by law enforcement agencies. Additionally, there are concerns about the independence of investigations into encounters, as they are often carried out by the same law enforcement agencies that are responsible for the encounter.

In 2023, the Indian government took steps towards addressing these concerns. The government established a special task force to investigate instances of human rights violations by law enforcement agencies, including encounters. The task force was given the authority to carry out independent investigations and make recommendations for action. Additionally, the government amended the CrPC to include provisions for the recording of encounters, and established an independent body to oversee the recording and investigation of encounters.

Conclusion:
The Indian judiciary has played an important role in regulating the use of encounters by law enforcement agencies. The provisions of the Constitution, the CrPC, and the IPC provide for the regulation of the use of force, and the establishment of an independent body to investigate