Case Name: Santosh Kumar Singh v. State through CBI
Citation: (2010) 9 SCC 747
Case No.: Criminal Appeal No. 87 of 2007
Appellant: Santosh Kumar Singh Respondent: State Through CBI
Bench: Justice Harjit Singh Bedi and Justice Chandramauli Kr. Prasad
Today, crime is perpetrated through increasingly sophisticated and organised means. Furthermore, new sorts of crime are always emerging. Investigation authorities rely on systematised and scientific investigative approaches to effectively address such circumstances. Following the pioneering work of Professor Sir Allec Jeffreys at Lichester University in London in 1985, DNA technology has become one of the investigative instruments in recent times. Prior to the 1980s, DNA was solely utilised for scientific study and scientific purposes. It is now playing an important role in forensic science. Forensic science, as a scientific approach operating within the confines of the legal system, provides guidance to civil and criminal investigations while also providing reliable information on all the attendant elements of criminal identification.
The development of DNA technology elevates forensic science from a passive to an active important role in the administration of justice. Deoxyribonucleic acid, or DNA, is the genetic blueprint of every human being. Each person’s chemical component of DNA in their cells is unique. The pattern of the molecules that comprise an individual living being’s DNA governs that individual’s development. DNA is the same in every cell in the body, whether it is a skin cell, sperm cell, or blood cell. Except for genetically identical twins, this is the only decisive factor in distinguishing one from another. DNA analysis, also known as DNA profiling, studies DNA contained in tangible evidence such as blood, hair, and sperm to see if it can be linked to DNA from particular persons. In criminal prosecutions, DNA analysis has become a regular kind of evidence. When biological evidence is retrieved at a crime scene, the invention of the stated science may be utilised to identify offenders with extraordinary precision. At the same time, it may be used to exonerate those who have been wrongfully charged or convicted of crimes. As a result, DNA technology is regarded as the most effective in determining the truth.
Forensic DNA analysis is typically employed to discover criminal activity, but it is also utilised in civil action, notably in situations requiring paternity identification. In Maryland v King noted that- “the discovery of DNA technology is one of the most momentous scientific achievements of our day.” The entire potential of genetic markers for use in health and research is still being investigated, but the value of DNA identification in the criminal justice system is undeniable. Since the initial use of forensic DNA analysis to identify a rapist and murderer, courts have recognised DNA testing’s unparalleled capacity to both exonerate the wrongfully accused and identify the guilty. It has the ability to vastly improve the criminal justice system as well as police investigation techniques.
In his book “Law in the Scientific Era,” former Justice Markendey Katju stated, “Science has, without a doubt, existed since ancient times.” However, in the past, science (the study of nature’s laws) and technology (the application of these laws to produce socially valuable things) were almost autonomous endeavours with no interconnection. Engineering evolved primarily independently of science at the period, led by experience and tradition. Science and technology have just recently been more tightly intertwined, and the gap between them has reduced. Scientific discoveries and technological advancements hasten the fast progress of science and technology, as well as the profound alteration of society. Furthermore, subjective information based on experience has been substantially supplanted in the present scientific period by objective experimental deterministic knowledge that eliminates chance and probability components and ensures certainty in our lives.”
Santhosh Kumar Singh, the appellant, was convicted by the High Court for rape and murder of Priyadarshini Mattoo based on forensic evidence, documents, and witness accounts. He had often harassed, followed, and threatened the deceased, and various police stations had received complaints in this respect. A police constable was assigned to the deceased’s personal protection ,who discovered her strangled to death in her bedroom when all of her family members were gone. Medical evidence and a forensic examination on the deceased’s body, as well as her post-mortem report, proved that the appellant raped her. Smashed glass fragments discovered near her body matched the broken visor of the appellant’s helmet. Some of the witnesses claimed to have seen him around the scene of the murder a few minutes before her body was discovered. The appellant’s right hand had a new fracture. However, the trial court ruled in favour of the appellant, acquitting him of all charges brought against him. The CBI was accused of concealing evidence and fabricating it in front of the court. It further slammed the Delhi Police for favouring the accused during the trial and investigation since the appellant was the son of a high-ranking police official. The Delhi High Court removed this “benefit of doubt” by finding the appellant guilty of the crimes he committed. As a result, this Criminal Appeal.
The 4 key issues with which I will deal and describe here are essential to put light on where an abuse of authority by the highest court of the nation took place & the commutation of death penalty to life imprisonment was awarded.
- Should the lack of fairness on the part of the CBI warrant such a negative response to the proof by presumption of law?
- Whether a DNA test was able to prove beyond a reasonable doubt that the accused was guilty?
- Whether the accused’s guilt and the circumstantial evidence can be shown beyond a reasonable doubt before he may be found guilty of the crime committed?
- Are the mitigating factors in favour of the appellant a sufficient reason to reduce the death sentence? Is life imprisonment inadequate in this scenario?
The main contentions on behalf of the appellant (Santosh Kumar Singh) were as follows:
- On behalf of the respondent, distinguished Counsel argued persuasively that the trial court erred in deciding that the accused’s harassment of the deceased constituted a motivation or that the harassment itself was proven.
- He contended that a careful study of the evidence finds nothing to imply that the accused’s behaviour is anything more than a desire for a deeper relationship with the deceased. His desire to befriend the deceased cannot be justified as a reason for rape, let alone murder.
- Learned Counsel cited a Supreme Court judgement in G.B. Patel and Anr. v. State of Maharashtra to support his allegation that Kuppuswami is not a trustworthy witness. He said that Kuppuswami’s statement is untrustworthy and was planted by the Investigating Officer, as was attempted with Jaideep Singh Ahluwalia.
- Counsel claims that the trial court erroneously applied Section 6 of the Evidence Act by treating the deceased’s mother, Smt. Rajeshwari Mattoo’s, suspicion that the accused was involved in the event as a material fact. Her suspicion was that the accused was somehow involved in the incident.
- Prosecution’s attempt to show that the alleged injury was recent is only marginally supported by the evidence, since Dr. G.K. Chaubey testified that swelling and bleeding can continue for up to two weeks after a fracture. Blood has accumulated in the hematoma, resulting in soreness that will remain until the swelling subsides.
- In terms of rape and sexual activity, the defence stated that Inspector Lalit Mohan testified that there was no evidence on the scene indicating that the deceased had been raped. The results of the CFSL examination of the objects collected from the accused’s residence do not link the accused to any of the tests.
- Counsel argued that the evidence was all exhibits, including the deceased’s underwear, a bundle of clothes formed by the doctor during the post mortem examination, the allegedly tampered-with vaginal swab and vaginal slide, and blood samples from the accused. He claims that, despite the fact that the accused’s blood type is indisputably O+, the underwear recovered from him demonstrates that A Group semen was there.
The main contentions on behalf of the respondents (State through CBI ) were as follows:
- According to the learned ASG, the learned trial judge was certain that the accused was the only person who had committed the victim’s murder, but he still gave him the benefit of the doubt on the ill-conceived grounds that the CBI had been unfair to the accused by withholding crucial evidence gathered during the investigation when nothing was concealed.
- Learned ASG also contested the trial court’s decision that the deceased’s underwear was stain-free, despite the fact that the CCMB’s analysis suggested there was a stain. Counsel responded that the findings are obviously incorrect because the post mortem examination was performed by doctors with their naked eyes, whereas the DNA test was performed by doctors with an instrument called an ultraviolet trans illuminator, which was specifically designed for the purpose and can identify stains that are otherwise invisible to the naked eye
- The accusation of unfair play, according to ASG, is unreasonable because the CBI legitimately recorded the medical testimony on which the accused sought to rely. Furthermore, the CBI cannot be blamed for the disappearance of Varinder Prasad, the deceased’s servant, because they made every attempt to locate the witness but were unable; in fact, Const. Shyam was interrogated for the same reason.
- The learned ASG contended that the trial court erred in ruling that the prosecution’s evidence supporting the DNA testing was inadmissible and rejecting it. He claimed that the DNA tests were rejected by the trial court because the chain of custody of the material sent for testing shows the possibility of tampering, the test procedure is unfair and unlawful, and the experts are unqualified to conduct the tests. It was contended that the evidence on record contradicts the trial court’s determination that the material sent for a DNA test may have been tampered with.
- He claimed that the trial court erred in failing to take into account the fact that Head Constable Rajender Singh, who had been designated as the deceased’s personal security officer, testified affirmatively that he saw the Respondent wearing the helmet with a visor at the College in the morning. Due to this, kuppuswami’s testimony on the Respondent’s helmet-wearing appearance in front of the deceased person’s residence has more credibility. Furthermore, the Respondent agrees that the helmet belongs to him and that he had never denied ownership of it. It should be noted that the trial court’s judgement that the prosecution had neglected to submit the helmet for inspection was incorrect.
- It was argued that the trial court had already stated that the prosecution is not liable for neglecting to interrogate Virender Prasad. Furthermore, it was contended that the learned trial court’s decision to rule against the prosecution while possessing evidence supporting their case should be overturned as being wholly perverse.
- Ramalal Bhogilal Shah v. V.K. Guha1973 AIR 1196
The Supreme Court ruled that protection only applies when a person is forced to testify against himself. It does not imply that he is not required to provide information, nor can he oppose a DNA test if it is carried out in accordance with the Order and supervision of the individual courts.
- Nalini v. Union of India 1999 5 SCC 253
In 1991, during a general election campaign in Tamil Nadu, the ex-Prime Minister of India, Late Sri Rajiv Gandhi, was blasted with a human bomb. Victims were shattered by the blast. The DNA profiling not only aided in the identification of the victim, but also established the identities of the offenders, mostly through the belt seized from the site of the crime, which included scant bodily flesh remains. On similar grounds, the killing of Punjab Chief Minister Late Mr. Beant Singh in an explosion was uncovered utilising DNA technology.
- Patingi Balaram Venkata Ganesh v. State of Andhra Pradesh 2003 CriLJ 4508
The accused and a co-accused were accused of firing at the deceased. Witnesses said the assailant was wearing a pink shirt and that the accused was hurt during the shooting. The handgun and the blood soaked pink blouse were retrieved, and the blood detected on the garment matched the accused’s blood according to DNA. The court judged him guilty based on all available evidence, including DNA evidence.
- Banarsi Dass v. Teeku Dutta (Mrs) And Another 2005
The trial court should have allowed the parties to prove their respective arguments using the evidence provided during the trial rather than inventing evidence by ordering a DNA test, as it was observed that the scope of the investigation was relatively limited.
- State vs Sushil Sharma on 19 February, 2007CriLJ 4008
The first criminal case in India to be resolved with the use of forensics was this one. In this instance, Shusil Sharma fatally shot his wife Naina Sahni at home with three rounds. He killed his wife because he thought she was having an affair with a fellow congressman and classmate, Matloob Karim. After killing his wife, Sharma drove her corpse to the Bagiya restaurant where he and Keshav Kumar, the manager, attempted to burn her in a tandoor. Sharma’s gun and blood-stained clothing were found by police, who then transported them to the forensic lab on Lodhi Road. Also transported to Hyderabad for a DNA test were Sahni’s parents, Harbhajan Singh and Jaswant Kaur, whose blood was taken. The blood samples that the doctor saved while doing the post-mortem and the blood stains on two leads removed from the deceased Naina’s head and neck are both of the “B” blood group, according to the lab report. The DNA result said that the tests “show beyond a reasonable doubt that the charred body is that of Naina Sahni who is the biological offspring of Mr. Harbhajan Singh and Jaswant Kaur,” confirming that the body was Sahni’s. Finally, Mr. Shusil Sharma was determined to be guilty using forensic evidence.
- Premjibhai Bachubhai Khasiya v. State of Gujarat and Anr 2009 CRI. LJ 2888:
The High Court had to decide whether the DNA analysis may serve as the only foundation for proving the accused’s guilt of rape in the lack of any other evidence. According to the strength and calibre of the supporting evidence, the Court decided that a positive DNA finding can have a significant impact in cases where there is such evidence. It cannot, however, fix the identification if it is the only piece of evidence. If the assessment is unfavourable, the accused would be categorically cleared of the accusation. The Court stated that probability theory is the basis for the DNA science and report. When the accused and foetus’ profiles match, a likelihood as determined by the Random Occurrence Ratio is displayed. When Random Occurrence Ratio is unavailable, that cannot be used as the only basis for conviction in a criminal case and should not be taken as conclusive evidence.
The Indian Penal Code, 1860
Section 302 :
The Indian Penal Code, 1860, Section 302 specifies that a person who commits murder shall be subject to the death penalty or a life sentence in prison as well as a significant fine. Under the IPC, no one is immune from the crime of murder.
Any person who assaults or uses illegal force on a woman with the aim to offend or knowing that doing so will likely violate her modesty is penalised by imprisonment up to two years, a fine, or both.
Those who commit rape, excluding those covered by paragraph (2), are liable to penalties and imprisonment of any type for a period not less than seven years but not less than life or a term not exceeding 10 years. If the victim of the rape is the offender’s wife and she is not under the age of twelve, he or she faces imprisonment of any kind for up to two years. With the caveat that the court may issue a sentence of imprisonment for a term of less than seven years if there are substantial and distinct grounds specified in the judgement.
The Code of Criminal Procedure, 1973
Section 313: Power to examine the accused–
1. In every inquiry or trial, for the purpose of enabling the accused personally to explain any circumstances appearing in the evidence against him, the Court-
2. may, at any time and without prior notice to the accused, ask him any questions the Court deems relevant;
3. shall, after the prosecution’s witnesses have been examined and before he is summoned to testify in his defence, interrogate him broadly about the case: Provided, however, that in a summons-case, when the Court has waived the accused’s personal appearance, it may likewise waive his examination under clause (b).
4 The accused should not subject himself to punishment by refusing to answer such questions or providing false answers.
5. The accused’s replies may be considered in such inquiry or trial, and may be used as evidence for or against him in any subsequent enquiry into, or trial for, any other offence which such answers may tend to demonstrate he has committed.
The Indian Evidence Act, 1872
Section 6: Facts that, while not in dispute, are sufficiently connected to a fact in dispute to form a component of the same transaction are relevant, regardless of whether they occurred at the same time and location or at other periods and locations.
On October 6,2010 a two-judge bench comprised of Justice Harjit Singh Bedi and Justice Chandramauli Kr. Prasadissued a decision.
The defendant’s case was appealed to the High Court, which overruled the trial court’s ruling and condemned him to death. On October 17, 2006, the Delhi High Court declared Santosh Kumar Singh guilty of rape and murder under sections 376 and 302 of the Indian Penal Code and sentenced him to death. The conclusion of the Court was based on various strong grounds. The Court also reprimanded the Delhi Police for being sluggish and prejudiced in supporting Mattoo when she filed a complaint against Singh as his father; J.P. Singh was the Delhi Police’s then-senior IPS officer and Director General at the time. Santosh Singh was convicted by the High Court and sentenced to death.
When examining DNA evidence, the Court stated that a judge cannot substitute their own judgement for that of an expert, especially in a science like DNA profiling. Two scientists concluded that the DNA from the deceased’s sperm stains, as well as the swabs and slides, came from “a single source, and that source was the appellant.” The Trial Court delivered negative judgments on the correctness of the DNA examination by resorting to a huge number of textbooks, ignoring the subject’s complexity and technical character. The Trial Court was not justified in rejecting the DNA result because there was nothing negative to be found against the two specialists who submitted it. As a result, the Court determined that the DNA report was “scientifically precise and exact science.” Nonetheless, it reduced the death punishment to life imprisonment by concluding that additional reasons favoured the applicant. The Bench argued that “the balance sheet was in favour of Santosh Kumar Singh, and the goals of justice would be served if Santosh Kumar Singh’s death sentence were reduced to life imprisonment.”
- While the Apex Court acknowledged that purpose alone cannot be a persuasive cause, in this case, it forges the extensive chain of surrounding circumstances when read together. It supported the High Court’s decision to intervene in the case, overturning the Trial Court’s erroneous ruling that favoured the appellant despite the apparent evidence against him.
- The Court determined that when deciding between a death sentence and life imprisonment, the philosophy behind the “rarest of the rare” standard merely requires the implementation of a lower punishment. The Bench emphasised the change in appellant’s familial position, the death of his father, the difficulty he has endured for fifteen years, and other mitigating reasons in order to lower the death sentence to life imprisonment under Section 302 of the IPC.
- The poor investigation and tampering with evidence hampered the prosecution’s case in court. The DNA test revealed that rape had occurred. The fractured visor of Santosh’s helmet and the fracture in his head, along with the 19 injuries to Mattoo’s body, eventually settled the conflict in favour of the prosecution; thus, Mattoo’s multiple reports to the police also revealed the motive and eyewitness accounts that Santosh had been seen outside Mattoo’s house a few minutes before the murder. The Trial Court acknowledged in its judgement that the accused had a motive for the crimes claimed to have been perpetrated by him, which was clear given the accused’s persistent abuse and personal circumstances.
- The Trial Court’s ruling on the admission of the DNA test was not legally binding since the Court should have given full and equal weight to the expert testimony in the CBI case. The Delhi High Court declared that the Patiala House Trial Court found the CBI liable for operating in an unreasonable and unjust way. There was no attempt by the CBI to conceal any significant facts from the trial. As a result, the High Court of Delhi excluded the accused from the Trial Court’s broad norm of “benefit of the doubt.” It is claimed that life is a gift from God. No one, even the state, has the authority to end a person’s life.
- Beccaria has argued against the death sentence, stating that the state has the authority to execute a person since the individual’s life was not granted as part of the social contract. When the current scenario is considered, the allegations advanced by those who oppose the execution of the death sentence are false. The brutality with which Santosh Kumar Singh killed and raped her. The heinous act perpetrated by the accused was such that the death sentence was entirely acceptable, and any other punishment is simply insufficient. The Supreme Court’s conversion of the death penalty to life imprisonment is also completely unfair and discriminatory.
- Delhi High Court Justice R.S. Sodhi stated, “If the Supreme Court believes that this is not the rarest instance, this is it.” While delivering justice, I received the impression that this was a severe matter and that, based on the facts, this girl had been plagued for years. She went to every police station she could find and was ultimately arrested. But he didn’t care about the law; he simply barged into her home, raped her, and murdered her. “I thought this was the end.” In the cases of Bachan Singh (Bachan Singh vs. State of Punjab 1980) and Machhi Singh, the balance sheet of aggravating and mitigating elements was explained (Machhi Singh vs. State of Punjab 1983).
When it comes to the four issues which are identified:
- Despite too many factors in favour of the prosecution, the Trial Court acquitted the accused, claiming that the CBI had failed on numerous counts, including concealing evidence from the court, fabricating photographic evidence on behalf of the accused, failing to follow an official DNA check protocol, and depriving the court of the opportunity to review it judicially. In actuality, the prosecution case left no space for doubt. Finally, after seven years, the Delhi High Court did an admirable job in imposing the death penalty on Santosh Kumar Singh, restoring public trust in the judiciary. The Delhi High Court observed that the Trial Court’s judgments were perverse.
- The DNA test proved beyond a reasonable doubt that the accused was guilty since there were some shattered bits of the visor stuck to the helmet, which were subsequently discovered to have blood on it. The helmet was in horrible form when evaluated by the Center Forensic Science Laboratory (CFSL) at the time, most likely because the accused had struck the dead with significant force, as evidenced by the body’s 19 injuries. This was accompanied by three fractured ribs. The deceased woman was discovered in her residence at 5:40 p.m. Due to these favourable prosecution findings, there was limited opportunity to apprehend the defendants. In reality, when the offender was checked by a doctor after the trial for injuries to his right hand—injuries he said he had sustained on January 14—his tests revealed that they were likely recent in nature, contradicting the false claim Santosh Singh had earlier made. According to the Law of Evidence, the accused is required to refute the conclusions of the prosecution drawn from medical testimony that the person was injured. However, because the respondent was unable to do so because the injury was only 48 hours old, the inference of the prosecution regarding the injury had to be viewed favourably by the Trial Court.
- The accused’s guilt and circumstantial evidence must be proven beyond a reasonable doubt before he can be found guilty of the crime committed. Because no eyewitnesses were present at the time of the incident, the prosecution relied on circumstantial evidence presented through oral and documentary evidence. The court observed that the accused’s prolonged surveillance of the dead despite police reports proved his complete disregard for the law. The court then considered the circumstances and determined that, on January 23, 1995, the appellant was observed riding a motorcycle in the University Campus Law Centre while wearing a helmet with an intact visor, and that, later that day, in the afternoon, Sh. Kuppuswami had observed him at the gate of the deceased’s home carrying a helmet fitted with a visor in his hand.
- The culprit was accused of ruthlessly strangling the victim with a heat convector tube. The heinous nature of the murder is obvious from the post-mortem report, as well as the signs of scratches on the deceased’s mouth, neck, and chest, as well as the blood that seeped out of her, as observed by Inspector Lalit Mohan on the day of the incident. The death penalty was really deserved, and in my opinion, the Supreme Court erred in changing the death sentence imposed by the High Court into a life sentence. There were no mitigating reasons in favour of the condemned. The Supreme Court’s decision may now serve as a guideline for future instances in which rape and murder defendants may be sentenced to life in prison.
Santosh Kumar Singh should receive the death punishment due to the horrendous way Priyadarshini was murdered. In the case of Nirmal Singh (State of Haryana v. Nirmal Singh, 1998), it was decided that the death sentence was appropriate because the case fell into the rarest category. They must have been extremely vicious and depraved beings without any human emotions, as evidenced by the wounds.
The death sentence in Lalrinawas (the State of Mizoram vs. Lalrinawma 2000) was converted to life in prison since the accused admitted to the crime and was steadfast in his confession. Santosh Kumar Singh hasn’t taken any steps in the current situation that would suggest remorse of any type. On the contrary, it routinely false admissions and fabricated innocence, which further adds to the balance sheet’s deterioration. In addition to this, the balance sheet has a number of other aggravating elements. The first and foremost is Santosh Kumar Singh’s continuous abuse of the victim and his illegal activities, which were brought to the public’s knowledge. The cops have done so countless times. Keeping in mind his father’s prominent position, he landed confidently in killing the victim, and his subsequent behaviour likewise permits no mitigating. To quote the Supreme Court, the appellant would definitely have had ample time to reflect on the events of the previous 15 years and on the situation he is currently in. Despite the fact that his father passed away a year after his incarceration and his young children may lead terrible lives, there is no reason to believe that he won’t change. The only logical conclusion that can be drawn in light of the aforementioned allegation and in the absence of any overt victim intervention over this behaviour is that a 15-year period is, of course, a long time to reflect on one’s wrongdoings.
Is it enthusiastically practised in an uneven and unjust manner?
The most notable feature of the death penalty, and the one that it contains at its highest perfection, is the removal of the offender’s ability to inflict further harm. Whatever is captured, whether by compulsion or the perpetrator’s ingenuity, vanishes instantly. If the death penalty is abolished, society’s massive cost of keeping incorrigible convicts for the rest of their natural lives would be reduced. Because it is the most terrible, a death sentence has a higher deterrent effect on future criminals than any fine. It is also the most effective type of deterrence. As a result, harmful elements of society are permanently eliminated. According to prominent political philosopher Garofalo, the abolition of criminals constituted a form of moral fight for the welfare of society. According to Lombroso, a political thinker, capital punishment should be a good deterrent to the typical and incorrigible. The utilitarian viewpoint is similar. The hopeless offender should be eliminated painlessly rather than being kept by the state indefinitely. So why should the State pay the burden of retaining an accused who did not think twice before committing such a heinous crime? He did not beg forgiveness from the Priyadarshini family, nor did he join any social movement for rape and sexual assault victims.
It may be concluded that forensic science plays a critical part in crime investigation. Crime has risen in modern times, and the type and technique of crime has also evolved and improved as technology has. As a result, it is critical that the police and investigative machinery employ forensic science to identify crime and keep up with the evolving technologies and varied types of crime. Intelligent criminals have been fast to harness science for their illegal deeds, while police investigators can no longer rely on their traditional intelligence art. Barbaric and brutal tactics of criminal investigation have no place in a civilised society. As a result, forensic science must be applied in criminal investigations to examine the nature, kind, and detection of the crime. With little openness, Indian courts have emerged as the world’s most powerful. However, every institution, including the courts, is failing. The judiciary is made up of humans, and as humans, they are occasionally driven by factors other than an objective perspective of law and justice. It would be naïve to say that none of them, at any point in time, were motivated by personal ideas, connections, predilections, biases, and maybe even nepotistic and immoral factors. However, courts cannot agree to make conclusions based on ethical or moral considerations; rather, the justification must be completely lawful. A judge’s responsibility is not to look between the lines, but to give a fair, reasonable, and rational explanation of the legal matter at hand. “Justice must not only be done, but it must also appear to be done.” “Therefore, the court must strive to provide justice in all situations without fear, favour, attachment, or malice as a fillip to the country.”
- Andrei Semikhodskii, Dealing with DNA Evidence: A Legal Guide, published by Routledge-Cavendish; 1st Edition 2007.
- Bhuvaneshwar Singh, Scientific Investigation of Death Cases (A MedicoLegal Investigatiion relating to unnatural deaths-Bhuvan’s), Prayag Publishing company, Faisal Warsi, Allahabad, 1st Edition 2008.
- Dinkar.V.R, Justice in Genes (Evidential Facets of Forensic DNA Fingerprinting), Asia Law House, Hyderabad, 1st Edition 2008.
- Jothirmoy Adikari, DNA Technology in the Administration of Justice, Lexis Nexis Butter Worths, 2007.
- Mahindra P.Singh, V. N. Shukla, Constitution of India, Eastern Book Company, 11th Edition 2010.
- Ambika Singh & Tanya Aggarwal, ―The Double Helix Unravelled : Evidentiary aspects of DNA Fingerprinting , Criminal Law Journal, Volume 1, 2006.
- Dr. Paramjit Kaur, ―DNA Fingerprinting and its Evidentiary Value‖, Criminal Law Journal, Volume 2, 2006.
- Dr. Rao.G.V, ―Deposing Evidence as a DNA Expert Witness‖, Criminal Law Journal, Volume 2, 2010.
 133 S.Ct. 1958 (2013).
Tavleen hails from University of Petroleum and Energy Studies, Dehradun and spends most of her time researching on various laws and updates in the legal industry. For any clarifications, feedback, and advice, you can reach us at [email protected]