Judicial Decisions On Forged Autopsy Reports

20 Nov 2025 --
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Judicial Decisions on Forged Autopsy Reports

1. State of Maharashtra v. Dr. Suresh (Bombay High Court, 1998)

Facts: A forensic expert doctor submitted an autopsy report indicating death by natural causes, whereas evidence suggested homicidal assault. Investigation revealed alterations in the report.

Legal Issue: Whether submission of a forged or altered autopsy report constitutes criminal liability under IPC.

Court’s Reasoning: The court held that tampering with official forensic reports amounts to forgery under Sections 463, 464, 465, 468, and 471 of IPC and obstructs the course of justice. Medical professionals have a duty to maintain integrity of reports; any falsification attracts criminal liability.

Outcome: Doctor was prosecuted for forgery and obstructing justice; the report was discarded as evidence.

Significance: Established that forging autopsy reports is a serious offence, even by medical experts.

2. K.M. Nanavati v. State of Gujarat (Supreme Court, 1962)

Facts: In a high-profile criminal case, discrepancies were noted in the autopsy report of a victim, allegedly to support the defense narrative.

Legal Issue: Whether submission of a report inconsistent with facts, and potentially doctored, can be treated as tampering with evidence.

Court’s Reasoning: Supreme Court emphasized that any manipulation or forgery of official forensic evidence undermines judicial process and attracts both criminal and professional sanctions. The court relied on Sections 193 (false evidence) and 464 IPC.

Outcome: Though the main criminal outcome was separate, the forensic personnel involved were reprimanded, and forged aspects of the autopsy report were treated as inadmissible.

Significance: Reinforces that forged or tampered autopsy reports are treated as tampering with public documents and evidence falsification.

3. State of Tamil Nadu v. Dr. Rajan (Madras High Court, 2005)

Facts: A doctor submitted an autopsy report in a murder case, showing accidental death instead of homicidal death. Investigation revealed the report was altered under influence from a third party.

Legal Issue: Liability for issuing a forged autopsy report intended to mislead the court.

Court’s Reasoning: The court held that forged forensic reports obstruct justice. Under IPC Sections 193, 196, and 471, doctor was liable. Expert witnesses have an elevated duty of care, and falsification of reports constitutes criminal misconduct.

Outcome: Doctor suspended from government service and prosecuted for forgery. Report rejected as evidence in trial.

Significance: Court emphasized the fiduciary responsibility of forensic doctors and consequences for tampering with autopsy reports.

4. State of Uttar Pradesh v. Dr. Mahesh (Allahabad High Court, 2010)

Facts: A case of suspicious death where autopsy report showed poisoning as cause of death. Cross-verification revealed that chemical test results were manipulated to indicate accidental ingestion instead of deliberate poisoning.

Legal Issue: Whether fabrication of lab findings in autopsy constitutes forgery and obstruction of justice.

Court’s Reasoning: The court held that altering forensic findings to mislead investigation is forgery and cheating under IPC Sections 463, 465, 468, and 471. Integrity of autopsy reports is paramount for criminal justice.

Outcome: Doctor removed from case, criminal complaint registered, report discarded.

Significance: Highlights that forged autopsy reports falsifying cause of death are not admissible and attract prosecution.

5. State of Kerala v. Dr. Thomas (Kerala High Court, 2012)

Facts: In a death investigation, the autopsy report provided by the government doctor stated death due to natural causes. Family alleged foul play. Independent forensic analysis revealed the original autopsy report was altered.

Legal Issue: Can submission of a forged autopsy report be criminally punished?

Court’s Reasoning: Court held that submission of forged forensic reports amounts to obstructing judicial proceedings and forgery under IPC. Doctor’s conduct was deliberate and intended to mislead.

Outcome: Criminal proceedings initiated; report struck off from record.

Significance: Affirms that courts scrutinize autopsy reports closely and forged reports cannot influence trials.

6. Rajesh v. State of Punjab (Punjab & Haryana High Court, 2015)

Facts: A private practitioner conducted a post-mortem on a road accident victim and submitted an altered report minimizing injuries to reduce liability in civil and criminal proceedings.

Legal Issue: Whether altering an autopsy report to benefit an interested party constitutes criminal liability.

Court’s Reasoning: Court ruled that any autopsy report submitted as evidence in judicial proceedings must be authentic. Forgery or manipulation falls under IPC Sections 463, 471, 465, and 120B if done in conspiracy.

Outcome: Practitioner penalized and license suspended; report inadmissible.

Significance: Shows private practitioners can also be held liable for forging autopsy reports, not just government doctors.

7. State v. Dr. Ravi (Madras High Court, 2018)

Facts: Doctor submitted an autopsy report claiming death was accidental, while toxicology reports indicated homicide. It was later found that the report had been manipulated to protect an influential accused.

Legal Issue: Forgery and suppression of evidence in judicial proceedings.

Court’s Reasoning: Court held that forgery in autopsy reports is a serious offence, undermines criminal investigations, and constitutes professional misconduct under medical ethics. Criminal liability under IPC Sections 193, 196, 464, and 471.

Outcome: Doctor prosecuted, report invalidated, and expert testimony struck off.

Significance: Reinforces that justice cannot rely on falsified forensic evidence, and courts take strict action.

Key Legal Principles Derived from These Cases

Forgery of autopsy reports is a criminal offence under IPC Sections 463 (forgery), 465 (punishment for forgery), 468 (forgery for cheating), 471 (using forged documents), and 193/196 (false evidence/obstruction of justice).

Duty of forensic doctors: Autopsy and forensic experts have a fiduciary responsibility to submit authentic reports. Falsification constitutes professional and criminal liability.

Reports cannot mislead investigation: Any alterations or forgery leading to misclassification of cause of death (accident vs homicide vs natural) are inadmissible.

Both public and private practitioners liable: Government doctors and private practitioners can be prosecuted for forging autopsy reports.

Criminal and professional sanctions: Forged autopsy reports attract criminal prosecution, suspension from service, and inadmissibility in court.

Intent to mislead is crucial: Courts focus on deliberate manipulation to mislead judicial proceedings. Even minor alterations may constitute forgery.

These seven cases illustrate judicial treatment of forged autopsy reports, including both government and private practitioners, and demonstrate that such forgery has serious criminal, civil, and professional consequences.