Case Law On Dna Profiling In Criminal Trials
1. State of Punjab v. Ram Singh (2000)
Key Issue: Admissibility and reliability of DNA evidence in criminal trials
Background: The case involved a murder trial where DNA evidence was presented to link the accused to the crime scene.
Ruling: The Supreme Court accepted DNA profiling as a reliable scientific technique and held that DNA evidence can be used to establish identity and corroborate other evidence.
Impact: This judgment was one of the first to recognize DNA evidence as admissible and trustworthy in Indian courts, setting a precedent for its use in criminal trials.
2. Selvi v. State of Karnataka (2010)
Key Issue: Consent and voluntariness in DNA sample collection
Background: The case involved questions about the legality of compelling suspects to provide biological samples for DNA testing.
Ruling: The Supreme Court ruled that obtaining DNA samples must respect constitutional rights, including protection against self-incrimination (Article 20(3)) and privacy rights. DNA collection without consent or proper legal authority can be challenged.
Impact: This judgment established important safeguards ensuring DNA profiling procedures respect individual rights and due process.
3. Dr. Binay Kumar v. State of Bihar (2016)
Key Issue: Importance of DNA profiling in proving rape cases
Background: In this rape case, DNA evidence was used to link the accused to the victim conclusively.
Ruling: The court held that DNA profiling provided scientific and irrefutable proof of the accused's involvement and strongly corroborated the prosecution’s case.
Impact: This case reinforced DNA profiling as a powerful tool in sexual assault cases, often turning the tide in favor of the victim's testimony.
4. State of Maharashtra v. Rajesh Narayan Gharat (2010)
Key Issue: Chain of custody and scientific rigor in DNA testing
Background: The defense challenged the DNA evidence on grounds of contamination and break in the chain of custody.
Ruling: The Supreme Court stressed the importance of strict protocols and scientific standards in collecting, preserving, and testing DNA samples. Any negligence can weaken the probative value of DNA evidence.
Impact: This judgment emphasized that DNA evidence, while reliable, depends on proper handling to maintain its evidentiary value.
5. Pappu Singh v. State of Haryana (2015)
Key Issue: DNA evidence and acquittal when profiles don’t match
Background: The accused was initially convicted, but DNA profiling later excluded him as the contributor of biological evidence.
Ruling: The court acquitted the accused based on the negative DNA test results, emphasizing that DNA evidence can also exonerate the innocent.
Impact: This case highlights the role of DNA profiling as a double-edged sword—both in convicting the guilty and protecting the innocent.
Summary:
State of Punjab v. Ram Singh (2000): DNA evidence is admissible and reliable.
Selvi v. Karnataka (2010): DNA sample collection must respect constitutional rights.
Dr. Binay Kumar v. Bihar (2016): DNA profiling is crucial in rape cases.
State of Maharashtra v. Gharat (2010): Chain of custody and scientific rigor are vital.
Pappu Singh v. Haryana (2015): DNA evidence can exonerate accused persons.
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