Use Of Dna And Scientific Evidence In Verdicts
Use of DNA and Scientific Evidence in Verdicts
DNA and scientific evidence have transformed criminal investigations by providing highly reliable and objective proof of identity and events. Modern courts rely on such evidence alongside traditional testimony.
Scientific Evidence Includes:
DNA profiling and matching
Fingerprint analysis
Bloodstain pattern analysis
Ballistics and firearms examination
Toxicology reports
Digital forensic analysis
Legal Framework (India):
Indian Evidence Act, 1872 – Sections 45 (opinion of experts) and 293 (court may rely on expert reports).
DNA Technology (Use and Application) Regulation Bill, 2019 – Regulates collection, storage, and use of DNA profiles in criminal justice.
CrPC – Police powers to collect biological samples under Sections 53 and 164.
Principles for Using Scientific Evidence:
Collection and Preservation: Proper procedures for sample collection to prevent contamination.
Chain of Custody: Documentation of sample handling from collection to laboratory.
Analysis in Accredited Labs: Evidence must be processed in certified laboratories.
Expert Testimony: Courts require experts to explain findings and probability of match.
Admissibility: Must be relevant, reliable, and obtained legally.
Case Law Analysis
Here are six detailed cases illustrating the use of DNA and scientific evidence:
Case 1: State of Punjab v. Gurmit Singh (1996)
Facts:
The accused was charged with murder. DNA analysis of blood stains was conducted to link him to the crime scene.
Court Decision:
Punjab & Haryana High Court relied on DNA profiling as corroborative evidence.
Emphasized the probabilistic nature of DNA evidence but accepted it as scientifically reliable.
Significance:
Early Indian case recognizing DNA evidence as admissible under Section 45 of the Evidence Act.
Highlighted the importance of laboratory certification and expert testimony.
Case 2: State of Maharashtra v. Mohd. Arif (2010)
Facts:
A murder case where DNA extracted from the victim’s clothes matched the accused.
Court Decision:
Bombay High Court considered DNA evidence as conclusive when corroborated with other facts.
Noted that chain of custody and integrity of samples were properly maintained.
Significance:
Reinforced that DNA evidence strengthens circumstantial evidence, leading to conviction.
Case 3: Mukesh v. State for NCT of Delhi (2017) – Nirbhaya Case
Facts:
Brutal gang rape and murder in Delhi. DNA evidence from the accused matched semen and biological samples recovered from the victim.
Court Decision:
Delhi High Court and later Supreme Court relied heavily on DNA results to establish identity and participation of the accused.
DNA corroborated eyewitness testimony and confessional statements.
Significance:
Landmark case demonstrating DNA evidence as crucial for convictions in sexual assault cases.
Highlighted integration of DNA evidence with other scientific and testimonial evidence.
Case 4: State of Karnataka v. Dr. K.M. Mohammed (2002)
Facts:
Involved a medico-legal case concerning suspected poisoning. Scientific toxicology analysis identified lethal chemicals in the victim’s system.
Court Decision:
Karnataka High Court held toxicology reports as admissible scientific evidence, even without eyewitnesses.
Court relied on expert reports to establish cause of death and intent.
Significance:
Demonstrated that scientific evidence can stand independently in proving elements of a crime.
Case 5: Selvi & Ors. v. State of Karnataka (2010)
Facts:
Case involved polygraph, narcoanalysis, and brain-mapping tests used during investigation.
Court Decision:
Supreme Court ruled that such tests cannot be forced on accused and are admissible only if consented.
DNA and toxicology reports, being objective, remain admissible, but coercive scientific tests are unconstitutional.
Significance:
Clarified the limits of scientific evidence in criminal trials, emphasizing voluntary consent.
Distinguished DNA and objective evidence from coercive procedures.
Case 6: State of Uttar Pradesh v. Rajesh Gautam (2007)
Facts:
Murder case where DNA samples from the crime scene were compared with accused.
Fingerprint analysis and ballistic evidence were also used.
Court Decision:
Allahabad High Court relied on DNA match and fingerprint evidence to secure conviction.
Noted that scientific evidence is highly reliable when combined with proper procedural safeguards.
Significance:
Reinforced principle that scientific evidence corroborates investigative findings, making prosecution stronger.
Key Takeaways from These Cases
DNA Evidence is Highly Probative: Courts accept it as a reliable means to link accused to crime.
Procedural Compliance is Critical: Improper collection or chain of custody breaches can render DNA inadmissible.
Complementary Role: DNA often corroborates eyewitness testimony, confessions, or circumstantial evidence.
Expert Testimony is Essential: Courts rely on expert interpretation and certification from accredited labs.
Consent Matters for Certain Scientific Tests: Coercive tests (polygraph, brain-mapping) require voluntary consent.
Global Practice Alignment: Principles of collection, preservation, and analysis mirror international standards.
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