The Chhattisgarh High Court has held that a DNA report cannot be discarded merely because the defence claims there was a break in the chain of custody. The Court observed that such an objection must be supported by credible evidence showing that the samples were actually tampered with, contaminated, or improperly handled. A vague or unsupported allegation is not sufficient to weaken reliable scientific evidence.
Background of the Case
The case arose from a criminal appeal challenging the conviction of the accused in a serious sexual offence. During the trial, the prosecution relied heavily on forensic evidence, particularly DNA profiling, to establish the accused’s involvement.
The defence questioned the reliability of the DNA report. It argued that the prosecution had failed to maintain an unbroken chain of custody while collecting, preserving, transporting, and examining the biological samples. According to the defence, this alleged break rendered the DNA evidence unreliable.
The High Court examined these objections in detail before deciding whether the forensic evidence could safely be relied upon.
What Was the Defence’s Argument?
The accused primarily contended that:
- The chain of custody of the biological samples had not been properly established.
- Because of this alleged procedural lapse, the DNA report should not be treated as reliable evidence.
- The prosecution had failed to prove that the samples remained intact throughout the investigation.
The defence, however, did not produce any material showing that the samples had actually been substituted, contaminated, or tampered with.
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High Court’s Observations on Chain of Custody
The High Court rejected the defence’s challenge.
It observed that merely raising a theoretical possibility of a break in the chain of custody is not enough to invalidate scientific evidence. A party challenging forensic evidence must place some material before the Court indicating that the integrity of the samples was compromised.
The Court noted that:
- The investigation records showed that the biological samples were collected and forwarded for forensic examination.
- The witnesses connected with the collection and examination of the samples were cross-examined.
- Their testimony did not reveal any significant inconsistency regarding the handling of the samples.
- No evidence was produced suggesting substitution, contamination, or manipulation of the exhibits.
In these circumstances, the Court held that the DNA report retained its evidentiary value.
Bald Allegations Cannot Defeat Scientific Evidence
The High Court made it clear that courts cannot ignore scientifically reliable evidence solely because an accused makes a general allegation regarding the chain of custody.
According to the Court, before a DNA report is discarded, there must be convincing evidence showing that:
- the samples were mishandled,
- the seals were broken,
- contamination occurred,
- substitution took place, or
- the integrity of the evidence was otherwise compromised.
Without such proof, the Court cannot presume that forensic evidence has become unreliable.
Importance of DNA Evidence
The Court described DNA profiling as one of the most reliable forms of scientific evidence available in criminal investigations when proper procedures have been followed.
It observed that in the present case:
- the DNA profile of the accused matched the biological material recovered during investigation;
- the forensic findings directly connected the accused with the offence; and
- the DNA evidence strongly corroborated the prosecution’s overall case.
The Court found that the scientific evidence remained unshaken throughout the trial.
Corroboration with Other Evidence
The High Court further explained that the conviction was not based solely on the DNA report.
Instead, the forensic findings were considered together with other evidence available on record. When viewed collectively, the evidence formed a complete chain pointing towards the guilt of the accused.
The DNA report therefore acted as an important corroborative circumstance that strengthened the prosecution’s case rather than standing in isolation.
Legal Significance of the Ruling
This judgment reinforces an important principle governing forensic evidence in criminal trials.
The ruling makes it clear that:
- Scientific evidence cannot be rejected merely because the defence raises speculative objections.
- A challenge to the chain of custody must be backed by concrete facts demonstrating possible tampering or contamination.
- Courts will continue to place significant reliance on DNA evidence when its collection, preservation, and examination appear reliable and no genuine infirmity is established.
The decision also underscores that speculative doubts cannot override credible forensic evidence supported by the record.
Conclusion
The Chhattisgarh High Court reaffirmed that DNA evidence remains highly persuasive when there is no credible proof that the samples were tampered with. Simply alleging a break in the chain of custody, without substantiating the claim through evidence, does not justify discarding a DNA report.
Accordingly, the Court upheld the evidentiary value of the forensic reports and held that unsupported objections regarding the chain of custody cannot defeat otherwise reliable scientific evidence in a criminal trial.