How low can the paparazzi go? The lower the better, in the case of the "upskirt" shot beloved of the bottom reaches of the tabloid press. There's an incredible scene in a Channel 4 documentary about the Sunday Sport in which the paper hires a dwarf photographer for exactly this purpose, and he still had to lie on the floor to get the required amount of groin in the frame. (At his job interview, the tact and sensitivity you'd expect from a paper that ran the headline "Rose West ate my guinea pig" was on full display. "Can we call you Phil the Mighty Midget?" asked one of the journalists. "I'm not a midget," Phil replied, stonily. He was eventually named the "Dynamo Dwarf".)

On Fleet Street, the "paps" have long been regarded as the wildest tribe of all - hunting as a pack, spending weeks camped outside celebrities' houses, or employing ever more unwieldy lenses to capture the unwary in an unflattering bikini. A hand-held 300mm camera can provide decent pictures at more than 100 metres, but if you've got a bigger lens, a teleconverter, a tripod and a bit of patience, you can record the special moment an American reality TV star pulls her knickers out of her bum crack from more than a quarter of a kilometre away.

Back to pap

Even as the rest of Fleet Street has been sobering up and practising its "contrite face", the role of the paparazzi has been ignored. It's as if, having had our fit of guilt in the wake of Diana's death, we've used up our quota of outrage. But the paps are still using many of the tactics that troubled us then. There's a photo of the day of Amy Winehouse's funeral, with a knot of photographers wobbling on stepladders, the better to get a shot over the wall of Golders Green Crematorium.

In his evidence to the Leveson inquiry into press standards on 21 November, Hugh Grant has written of the experience of Tinglan Hong, the mother of his baby. He says that photographers "besieged" her house, "ringing repeatedly at her door". As he said: "I asked them if there was anything I could do or say to make them leave a new and frightened young mother in peace. They said: 'show us the baby'. I refused."

After trying the Press Complaints Commission - it circulated a warning to editors, which apparently deterred some, but not all, of the photographers - Grant successfully applied for an injunction against them.

The NS's legal correspondent, David Allen Green, speculated that while the PCC ruling might have made newspaper editors call off the hunt, it was unlikely to have the same effect on photo agencies and freelance paparazzi: "the intrusions - and risks - are effectively outsourced on a commercial basis by the tabloids".

It is worth noting that the impetus for the Leveson inquiry - phone-hacking at the News of the World - was also caused by a paper "outsourcing" legally and ethically dubious tactics, in this case to private investigators. Any press reform must tackle not just the sitting targets of Fleet Street, but the shifting, quicksilver world of those they pay to do their dirty work for them.