Recently, the Supreme Court has expressed its skepticism regarding the admission of DNA reports as conclusive evidence in criminal cases. In the case of Rahul v. the State of Delhi, Ministry of Home Affairs (2022), the Court raised concerns about the collection and sealing of the samples that were sent for examination. The Court pointed out that these processes were not free from suspicion. It criticized both the Delhi High Court and the trial court for failing to examine the underlying basis of the findings in the DNA reports and for not assessing the reliability of the techniques used by the expert.
In this particular case, despite the DNA analysis yielding a ‘match’ result and other supporting evidence, the Supreme Court acquitted all three individuals accused of rape and murder. The Court’s decision was primarily based on the failure of the lower courts to properly scrutinize the DNA reports and ensure the accurate application of the techniques by the expert. The Court emphasized the need for a thorough examination of the scientific methods employed in DNA analysis.
In another case, Manoj v. State of Madhya Pradesh (2022), the Supreme Court also expressed concerns about the likelihood of contamination in the DNA analysis. Although the expert explained the technique used, the Court highlighted the omission of mentioning the ‘random occurrence ratio’ during the presentation of evidence. The Court noted that this omission raised doubts about the possibility of contamination, particularly since one of the reference samples was collected from an open area.
Given these recent judgments, it is crucial for the first responder at the crime scene to follow proper procedures when handling biological samples for DNA analysis. The responder must ensure that the biological sample is dried under room temperature and sealed in a paper bag rather than a plastic one. This precaution aims to prevent any potential contamination that could compromise the integrity of the sample.
Moreover, the responder should be cautious about avoiding any actions that could introduce external DNA sources to the crime scene. This includes refraining from touching areas where DNA may exist, as well as taking measures to prevent talking, sneezing, or coughing over the evidence. To minimize the risk of contamination, no other human contact should be allowed, and stained articles must be packed separately.
These recent judgments by the Supreme Court reflect a growing awareness of the importance of critically examining DNA evidence in criminal cases. The Court’s emphasis on the proper collection, handling, and analysis of DNA samples is crucial to ensure the accuracy and reliability of forensic evidence. By scrutinizing the underlying basis of DNA reports and evaluating the techniques employed by experts, the Court seeks to uphold the principles of justice and prevent the possibility of wrongful convictions based on flawed or contaminated DNA evidence.
The recent judgments of the Supreme Court demonstrate its critical stance on admitting DNA reports as clinching evidence in criminal cases. The Court’s concerns about the collection, sealing, and analysis of DNA samples highlight the need for meticulous scrutiny and reliable application of scientific techniques. By raising these issues, the Court aims to enhance the integrity and credibility of DNA evidence in the Indian judicial system.