Yes, both the NCPCR and the SCPCRs can move on their own, suo moto, without any one specifically filing a complaint. As per Model Rule 25, SCPCRs shall set up child help lines, accessible by SMS, telephone and letter for receiving and registering complaints.

The problem at present (April 2010) is that the NCPCR is in the process of being reconstituted, and only five states have constituted their SCPCRs, that too with varying capacities. The exact rules and procedures for redressal shall have to be worked out by the NCPCR when it again becomes properly functional, and it will have to assist the SCPCRs to do the same. The reconstituted NCPCR is expected to carry forward its earlier initiatives of linking and networking with civil society organizations for monitoring, appointing state commissioners for the enforcement of the Act (on the lines of Supreme Court Commissioners for Right to Food), networking with other Commissions like the one’s for Human Rights, Women and Minorities, set up helplines and set up a separate division for enforcing the Right to Education.

The Model Rules provide that in states that do not have SCPCR at present (which is set up by the Women and Child department), the education department shall constitute a Right to Education Protection Authority (REPA) till the SCPCR comes into force.