NARCO-ANALYSIS AND

BRAIN MAPPING

Project Report on Forensic Science

Submitted to: Submitted by:

Dr. Ajay Ranga Sehej Sandhawalia

B.A. LL.B. (Hons)

9th Semester

Section-B

272/14
Narco-Analysis and Brain Mapping

ACKNOWLEDGEMENT

I would like to express my special thanks of gratitude to my teacher Dr Ajay

Ranga who gave me the opportunity to do this wonderful project on the topic
Narco-Analysis and Brain Mapping. The project helped me in doing a lot of
Research and made me aware on various aspects of the law.

Thanking You

Sehej Sandhawalia

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Narco-Analysis and Brain Mapping

INDEX

1. Introduction……………………………………………………………..4

2. Usage of tests in India…………………………………………………..5

3. Narco-Analysis…………………………………………………………..6

4. Brain mapping…………………………………………………………..9

5. Global Perspective……………………………………………………..11

6. Admissibility in India………………………………………………….13

7. Bibliography……………………………………………………………16

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Narco-Analysis and Brain Mapping

INTRODUCTION

The legal procedure in India is mainly based on the Constitution of India, Indian Evidence
Act, Code of Criminal Procedure, Code of Civil Procedure and Indian Penal Code. Cases are
decided in India on the basis of adduced evidence. Crime detection, discovery, identification
and analysis of criminal evidence are the means of law enforcement. The prosecution has to
prove the guilt of accused beyond reasonable doubt. It is the responsibility of the law
enforcing agencies to detect crime, apprehend perpetrators and to provide such evidence,
which results in the conviction of the criminal. India has enough legislation on various crimes
but it is not the latest.

With the introduction of computers, mobile phones, internet services, etc. crime is increasing
to a greater extent also, in addition to it nevertheless in most of the parts of India, climatic,
infrastructure and functional shortcomings create special difficulties in crime-detection

In the last few decades, the infusion of technology in crime investigation has been a major
breakthrough in the process of advancement of criminal justice. Police utilize scientific tools
and techniques to detect a crime, reconstruct the crime scene, identify the alleged offender
and establish vital links; the courts, on the other, take account of these physical evidences,
otherwise infallible, and determine with enhanced accuracy the innocence or guilt of the
offender. Somewhere, the efficiency and effectiveness of the criminal justice functioning has
come to be intertwined with the extent of use of technological tools in crime investigation.

What is Forensic Science?

The field of forensic science draws from a number of scientific branches, including physics,
chemistry, and biology, with its focus being on the recognition, identification, and evaluation
of physical evidence. It has become an essential part of the judicial system, as it utilizes a
broad spectrum of sciences to achieve information relevant to criminal and legal evidence.
Forensic science may prove the existence of a crime, the perpetrator of a crime, or a
connection to a crime through the:

 Examination of physical evidence

 Administration of tests
 Interpretation of data
 Clear and concise reporting
 Truthful testimony of a forensic scientist

Forensic science has become an integral part of many criminal cases and convictions, with
objective facts through scientific knowledge serving both defense and prosecution arguments.
The testimony of forensic scientists has become a trusted component of many civil and
criminal cases, as these professionals are concerned not with the outcome of the case; only
with their objective testimony based purely on scientific facts.1

1
https://www.crimesceneinvestigatoredu.org/what-is-forensic-science/

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Narco-Analysis and Brain Mapping

USAGE OF TESTS IN INDIA

 Polygraph test conducted on Nithari’s serial killing accused. — In Nithari, Noida

(U.P.), a businessman Mohinder Singh Pandher and his domestic help SurinderKoli
were accused of murdering 30 missing children. In scientific tests suspected killer
admitted serial killing of missing children. In this case the investigating agencies used
polygraph, brain mapping and narcoanalysis tests on both of them and also on a
female servant who allegedly lured children who were killed by the duo.2

 Ijju Sheikh’s case—In the Mumbai Serial Blasts case in 1993 RDX was used which
was smuggled from Gujarat coast to Mumbai. On 28th April, 2006 one Ijju Sheikh, an
aide of Dawood Ibrahim, an Underworld Don, was arrested from Mumbai. Ijju Sheikh
had smuggled RDX from Gujarat to Mumbai. He had given certain information to the
police and the police would make him face-to-face with another Dawood aide Umar
Miyan Bukhari who was deported to Mumbai from Dubai in December, 2005 and
who was subjected to narcoanalysis and brain fingerprinting tests at Gandhinagar,
Ahmedabad.3

 Narcoanalysis conducted in Aarushi Talwar murder case. - The body

of Aarushi Talwar was found in her bedroom on the night of 15-16.5.2008. In the
first information report Dr. Rajesh Talwar, her father pointed the needle of
suspicion at Hemraj, a domestic help in the household of the Talwars. On
17.5.2008 the dead body of Hemraj was recovered from the terrace of the same
house, where Aarushi’s murder had also allegedly been committed. No concrete
evidence could be collected even after conducting the narco-test of the Talwar
couple that could help in further investigations in the case. The test was conducted
to find out if Nupur Talwar or Rajesh Talwar knew anything about the case, but
they knew nothing different about the murder of the teenage girl.

2
Retrieved from www.indlaw.com; www.dnaindia.com. visited on 20th October,2017

3
Retrieved from www.outlookindia/pti_news.asp?id=296155, visited on 20th October ,2017

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Narco-Analysis and Brain Mapping

NARCO-ANALYSIS

Supreme Court recognized the requirement, the necessity of scientific investigation in

SomPrakash v. State of Delhi.4Law Commission also emphasized on the need of training
of Police officers in using scientific methods of investigation.5

Narcoanalysis has become an increasingly, perhaps most common term in India. It refers
to the process of psychotherapy conducted on a subject by inducing a sleep like state with
aid of drugs. A person is able to lie by using his imagination. In this test, the subject’s
inhibitions are lowered down by interfering with his nervous system at the molecular
level. In sleep-like state efforts are made to obtain “probative truth” about the crime as in
sleep like state, it becomes difficult though not impossible for him to lie. It is believed that
if a person is administered a drug which suppresses his reasoning power without affecting
his memory and speech, he can be made to tell the truth. Narcoanalysis is a form of
psychotherapy and an effective aid to scientific interrogation. It is a process whereby a
subject is put to sleep, or into a semi-somnolent state by means of chemical injections and
then interrogated while in a dream like state.

It is believed that if a person’s way of thinking can be restrained without any affect on
his memory. He can speak freely without any manipulations under the influence of
drugs Some drugs have been found to create this ‘twilight state” in some persons 6 and
with the use of these drugs investigating agencies try to arrive at the truth.

Procedure

Drugs used for the tests are commonly known as Truth Serum. Generally, the drug called
“Barbiturates” or “Sodium Pentothal” is used for conducting narco- analysis test. It is also
known by the name of “Penthol Sodium” or’ Thiopental” or “Thiopentone.

Important things involved in the tests are:

(i) Video recording

(ii) Tape recorder

(iii) Disposable syringe

(iv) Distilled water

(v) Prescribed truth drug

Every test is video graphed. How the subject was given dosage, what questions were put to
him, what was his response, each and every minute detail is recorded while conducting the
test. Along with the video the whole procedure is also recorded on an audio tape.
4
AIR 1974 SC 983
5
14TH Law Commission Report
6
Joshi, Nayan, “Medical Jurisprudence and Toxicology”, New Delhi:Kamal Publishers,2008.p267

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Narco-Analysis and Brain Mapping

Disposable syringe and distilled water is used for the purpose of conducting the test. The
drug which is to be used while conducting test is to be mixed with distilled water.

Dosage of Truth Serum (i) The dose depends upon the suspect’s sex, age, health and physical
and mental condition. (ii) In normal condition 3gm of Truth drugs of barbiturate class like
sodium pentothal, sodium Amytal etc. is required for the test. (iii) 3gm of the drug is
dissolved in 3000ml of distilled water. When the mixture (solution) becomes ready it is
administered intravenously along with 10% of dextrose on interval of 3 hours to the suspect
accused.

Presence of Authorities At the time of performing test, presence of following person is

necessary:

(i) Physician
(ii) Neurologist
(iii) Cardiologist
(iv) Anesthetist
(v) Lawyer

Precautions and Guidelines

The following precautions should be taken for fruitful result of test:

(i) The test should be conducted in a well-lit room which is otherwise quiet.
(ii) Prior consent of the subject has to be obtained and the person subjected to the test
should be given an option if he or she wishes to avail the test.
(iii) Consent should be recorded and it should be done before a judicial magistrate.
(iv) The physical and emotional implication along with the legal implications of the test
should be explained to the subject by the lawyer accessing him or her or by the police
that he or she submits himself or herself to the test voluntarily.
(v) The person subjected to the test should be made clear during the hearing that his or
her statements so made shall not be a “confessional statement” to the magistrate but a
statement to the police.
(vi) The entire process should be videotaped.
(vii) The drug should be diluted at 8.66% and should be injected showing at intervals
throughout the interview.
(viii) The drug should be administrated so that a state between sleep and wakefulness is
maintained.
(ix) Caffeine should be used to prevent the subject from going into deep sleep.
(x) The interview should not exceed one hour of time;
(xi) The actual recording of test shall be done in the pressure of a lawyer.
(xii) Manner of information received must be completely narrated in full medical and
factual terms and must be recorded;
(xiii) In India the test should be conducted as per norms of the NHRC of India.
(xiv) Narco analysis cannot be conducted without the consent of the subjected and order of
the court.

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Narco-Analysis and Brain Mapping

Narco analysis test is carried out by an expert GABA (A neurotransmitter inhibitor) is a

chemical that occurs naturally in his body. Truth drug binds GABA forming a complex at the
B site which exerts pressure over the permeability of chloride ions into neutral membrane.
Leading to the stage of disinhibition truth drugs cut to increase the action of GABA in the
brain, thereby decreasing nerve activity nerve activity hi the brain which results in sleepiness.
3 grams of drug is dissolved in 3000ml of distilled water and this mixture along with 10% of
dextrose is injected intravenously to antecubital vein in the body of the subject over a period
of 3 hours with the help of an experienced anesthetist. It is injected in normal conditions 0.5
to 1 ml per minute till the subject becomes sedative. The drug depresses central nervous
system (CNS) and makes the heart boat slower and blood pressure also lowers down. When
the person’s speech becomes slurred and he or she behaves in a co-operative manner and also
becomes more talkative it may pressure that he or she is under full control of the patient. The
examiner satisfies himself by testing the subject’s eye-muscles with his fingers. Needle is left
in the vein of the subject as different person need different dosages of the drug and also for
continued narcotic state further administration of drug is necessary. Care is taken that only so
much drug is administered which may keep the subject in semi-awake state and he does not
go in deep sleep rate.In this hypnotic state the questions are asked and answers are audio and
video-recorded.

The drug acts as a catalyst for catharsis. The following effects occur under the influence of
truth drugs :

(1) After administration of truth drug suspect’s body becomes relaxed, his or her features
slacken and full of excitement and few become silly and giggly.
(2) The drug blocks the impulses that usually pass through certain nerves and most
subjects fall asleep which emerges later in disoriented semi-wakefulness.
(3) Under the influence of truth drugs the suspect, may be he or she, becomes incapable
of telling a lie, and he or she will necessarily share any information that is asked of
them.

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BRAIN MAPPING

Brain Mapping is one more valuable scientific tool for investigation of crimes. Brain
Mapping is also known as Late Positive Complex or P3 or P300. It is a component of
averaged brain potentials. In this test no questions are asked from the accused. He is
made to sit in evoked potential recording machine and is shown objects relating to crime
scene or is made to hear sounds pertaining to crime site. The sensors from his head pick
the event related potentials in the form of Brain Mapping only if the person has been at
the site of crime.

Brain Mapping is a response of the brain to a stimulus which is shown to the subject. In
1965, scientists were working on the research of Event Related Potentials and it was
discovered by Sutton and his colleagues. It is very robust Event Related Potential. As
soon as it recognizes the stimuli it sends the reaction within 300 milliseconds of seeing
the stimuli. If the person is attentive to the stimuli its response would be the fastest. If
more time is taken for making decision the more time is spent for the responses of P300.
Its latency shows the amount taken by it in arriving at a decision. When the brain
recognizes a person or a sound, it generates a particular type of electric wave which is
called P300.7

In this test sensors are attached to the head of the subject and the subject is seated before
a computer monitor. The sensors catch the electrical activity in the brain and register
P300 wave, which are generated only if the subject has some connection with the pictures
shown to him and the sounds which he is made to hear.

Through Brain fingerprinting it can only be known that the person was present or not at
the place of occurrence. Only proof of his presence, inferences cannot draw that he has
committed the alleged offence. The person may be present on the place of occurrence for
some legitimate reason, e.g., for saving the victim. He may reach at that place as a
stranger. “Information present” does not always mean that suspect is guilty. It is possible
that the subject has been a witness to the crime or he or she has already read details in
newspaper or seen in media which has been imprinted in his or her mind.

Procedure

When any information is given to an individual, which corresponds to prior knowledge or

information in his brain about the activity or event it will emit responses in the shape of
p-300 waves. It has also been possible to observe stimulus response up to 800 mili
seconds. P-300 is an electrically positive component and has a peak literacy of about 300
to 800 mili seconds at the midline partial area of the head. The familiarity reaction of
brain towards the activity or events is recorded in MERMER (Memory and Encoding
Related Multifaceted Electroenceptalographic response) apparatus. For measuring EEG
(Electro Encephalograph) from several place of scalp a special head band equipped with
electronic sensors, is attached to the scalp and the test is presented with a series of
7
Bimaldeep Singh, “Scientific Techniques of Obtaining Evidence”, Law Journal of Guru Nanak Dev University,
Vol. XVII p 92.

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Narco-Analysis and Brain Mapping

relevant and irrelevant words, pictures, signs, Bounds etc. and responses of the two
different types of stimuli is measurable to know whether the relevant material is known
to the brain or not. If the brain is confronted with the stimuli, which is already in its store
it will emit p-300 at the rate of 300 mili seconds. Since, those responses are recorded
EEG signals no question has to be answered by the test. The apparatus works not on
emotions but on Cognitive Brain responses.

The brain fingerprinting detects the presence of crime. If a person is not present at that he
has committed the crime or present at the place of commission of crime. The act of crime
is imprinted in the brain of the subject. This test only ensures that the subject is present at
the place of occurrence. However, it does not ensure that the person concerned has
committed that crime. He may be present at that place for any other purpose. Brain finger
printing is a boon for investigating agencies. In a planned commission of crime the
physical evidences may vanish or made to vanish and sometimes it happens that no clue
of the criminal acts is found. The investigating agencies have to grope in dark in order to
catch a suspect. In such a case, the brain finger printing has prevented to be a boon in that
regard. In commission of crime the brain of the preparer is always with him while
planning, exciting and committing the crime. By this technique it is measured as to
whether there is crime related information stored in the brain of the suspect or not.

CRITICISM

This test has its own limitations.

1.The test is conducted by a human being and it is possible that they fail to fully and
truthfully analyze the brain wave.

2.An innocent person who has not committed the crime but has only witnesses of wound
also react to the stimuli. Similarly, a person may be aware of the crime due to details
published in media and the brain may store it. In that case also there chance is that the
innocent can also be found guilty. Therefore, this tests utility is only to imprint the
subject’s brain, which makes it clear that the subject is innocent.

3. This technique is also criticized on the ground that it is violation of brain privacy. By
this a person loses his right to keep his thought to himself This is also not useful in case
of a person who loses his memory, e.g., old people easily lose memory and therefore can
brain mapping on an old man accurately work? Similarly, a person suffering from
deficiency in memory can exit normal p-300 brain waves?

5. The six-member committee headed by National Institute of Mental Health and Neuro
Sciences concluded that Brain Mapping is unscientific and should not be used as an tool
of investigation and an evidence adduced through brain mapping should be made
inadmissible in Courts. There is requirement of a methodical, systematic and meticulous
examination of the procedure as it lacks ascertained principles.

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A GLOBAL PERSPECTIVE

Almost every country of the world has the provisions of scientific developments for the
benefit and welfare of their citizens and nations. There are provisions contained in the
constitutions across the world that talk about scientific research and developments. The
principle of criminal justice system is to protect the innocent from wrongly conviction and
punishment of culprit. All this is possible only if the truth is searched by the investigating
authorities. There is no doubt that constitutions of various countries speak about scientific
advancements but when it come to applying scientific techniques in interrogation, across
the globe, every nation hesitates. Worldwide, rights of accused persons are advocated.
Doubts are raised regarding the capability and reliability of scientific techniques of
investigation.

The Universal Declaration of Human Rights, 1948 in Article 11.1 declares that accused is
to be presumed innocent until proved guilty according to the law in a trial.

Also, the International Covenant on Civil and Political Rights, 1966 provides protection
against testimonial compulsion under Article 14 (3) (g). Presumption of innocence is also
enshrined under Article 6(2) of the European convention for the protection of Human
Rights and Fundamental Freedoms.

CONSTITUTIONAL PRIVILEGES AVAILABLE TO THE ACCUSED ACROSS THE

GLOBE:

CANADA - The Constitution of Canada contains elaborate provisions regarding legal

rights, personal integrity, fair trial and equality. Every person has a right to life and liberty
and these rights cannot be curtailed except in accordance with the procedure established by
law. The constitution also provide right against self incrimination under Article 13. Any
witness testifying before the court of law has the right not to give self- incriminatory
statements that may be used against him in that any other proceedings. Also, no cruel
punishment can be awarded to the accused. Accused cannot be subjected to any cruel or
unusual treatment.Every accused person has a right to fair trial. He has to be tried within
reasonable time. Accused is presumed to be innocent until proven guilty by a tribunal which
is independent and impartial. Accused cannot be compelled to be a witness against himself.
Every person is equal before the law and entitled to equal protection and benefit of law so
these rights are available to all whether that person is citizen or non-citizen.

CHINA - The Constitution of China contains provisions regarding personal freedom and
dignity. These provisions are however, are applicable only on the citizen of China.
Constitution provides that personal dignity and freedom cannot be violated except according
to the law. A person may be arrested according to the procedure established by law and
unlawful arrest or detention is prohibited. Insult, libel, false change against citizens of China
is prohibited. Unlawful search of person of a citizen is also unconstitutional. Under
clause(4) of Article 33 of the Constitution of China, it is specifically provided that China
respects and preserves human rights.

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Narco-Analysis and Brain Mapping

GERMANY - The Constitution of Germany is known by the name of 'Basic Law for federal
Republic of Germany', the Constitution of Germany commences with the basic rights
available dealing with human dignity in Article 1. It regards human rights invincible. It is
the duty of state authorities to respect and protect human rights furthermore, under Article 3
equality before law is guaranteed. The state promotes equal rights for men and women.
Right to privacy of correspondence, posts and telecommunications is also provided under
Article 10 of the constitution.

JAPAN-The constitution of Japan recognizes right against self-incrimination and custodial

torture, the torture inflicted by any officer is absolutely forbidden. It also states that no
person shall be forced to give any statement that may be exposing him to any punishment. It
the only evidence available is the confession of accused, such confession cannot form the
basis of conviction. Also, any confession that is made under compulsion, or torture or threat
or it is made where detention is prolonged it shall not an admissible piece of evidence. The
right of speedy trial is also recognized under the Japanese constitution. Article 37 provides
that it is the right of every accused to get speedy and public trial in all criminal cases by an
impartial tribunal.

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ADMISSIBILITY IN INDIA

Admissibility of scientific evidence has attracted a serious debate in India especially post
Selvi v. State of Karnataka8 case wherein Hon’ble Supreme Court has held that Narco-
analysis, Brain-mapping and polygraph tests cannot be conducted without the consent of
accused person. There are various provisions if given interpretation keeping in mind at
changed scenario would make scientific evidence admissible in court of law without any
amendment.

The first principle of interpretation is that the words of an enactment should be given their
ordinary and natural meaning because whatever was the intention of legislature, has been
expressed by it through words. If the language of a statute is plain, the only duty of court is
to given effect of to it.9In this regard legal maxim, ut res magisvaleat quam pereat, is also
worth mentioning. According to this maxim where alternate constructions are possible the
court must give effect to that interpretation which will help in smooth working of the system
rather than that construction which will be responsible for putting unnecessary hindrances in
the way of statute for which it has been exacted.

It has been specifically held by the Supreme Court in Shreenath v. Rajesh,10that where two
views are possible, especially while interpreting a procedural law, the one which curtails the
procedure without eluding justice should be adopted because procedural law is always
subservient to and is in aid to justice. Noscitur a sociis, also provide similar provision.
When two or more words are put together, they are to be understood in their cognate sense.
Associated words explain and limit each other.

In State of Maharastra v. Indian Hotel And Restaurants Association,11Hon’ble Supreme

Court observed “it must be presumed that the legislature understand and correctly appreciates
the need of its own people, that its laws are directed to problems made manifest by
experience”. In the light of this statement of Supreme Court it can be safely construed that
every provision of law must be interpreted keeping in mind the problem of general public.

ARTICLE 20(3) SELF – INCRIMINATION

8
AIR 2010 SC 1974

9
T. Bhattacharyya, “The Interpretation of Statutes”, Allahabad: Central Law Agency, Sixth Edition, 2006, p. 10.

10
AIR 1998 SC 1829.

11
2013(2) RCR (civil) 859.

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Narco-Analysis and Brain Mapping

Clause (3) of Article 20 of Indian Constitution talks about self-incrimination. It provides

“No person accused of any offence shall be compelled to be a witness against himself”.
This clause is based on the legal maxim nemo tenetur prodere seipsum accussare , which
means that no man is bound to accuse himself. The scope of this immunity has, prima
facie, been widened by our Supreme Court by interpreting the word ‘witness’ to comprise
both oral and documentary evidence which is likely to support a prosecution against him.
Such evidence however should be in the nature of communication. This protection is
available against testimonial compulsion. This protection cannot be claimed by a person if
at the time of making the statement he was not an accused.

In Dinesh Dalmia v. State of Maharashtra,12 the Madras High Court ruled that “Narco-
analysis testimony was not by compulsion because the accused may be taken to the
laboratory for such tests against his will, but the revelation during such tests is quite
voluntary”. The Indian Courts seem to be trying to keep limited the scope of Article 20(3)
on the basis of "Minimal Bodily Harm Doctrine". This approach is reflected in the
Bombay High Court verdict in Ramchandra Reddy and Ors. v. State of
Maharashtra13which upheld the legality of the use of P300 or Brain finger-printing, lie-
detector test and the use of truth serum or Narco analysis. Another thought provoking
decision is rather that of Rojo Gorge v. State of Kerala,14 in which the petitioner was
willing to undergo both Brain mapping and Polygraph test, and but he did not want to
subject himself to Narco-analysis, alleging it to be an unscientific test. However, J.
Padmanabhan Nair relaying on KathiKallu’s case15 rationale refused to grant the petition.

In the case of NandiniSathpathy v. P.L. Dani16it was held that no one could forcibly extract
statements from the accused that have the right to keep silent during the course of
interrogation or investigation. However, Art. 20(3) can be waived of by a person himself.

In People’s Union for Civil Liberties v. Union of India17Supreme Court held that a person
becomes witness only when he makes oral or written statements in or out of court relating to
any person who is accused of an offence. The giving of any sort of identification as for
instance impression of thumb or foot or palm or fingers or giving of specimen of hand-
writing is not at all covered under Article 20(3).

12
Cr. L.J. (2006) 2401.

13
Cr. W.P (c) No. 1924 of 2003.

14
1979 KLT 337.

15
The Apex Court in KathiKaluOguhadcase AIR 1961 SC 1808, limited the scope of Article 20 (3) by observing
that the self incriminatory information is admissible if there is no compulsion.

16
(1978) 2 SCC.

17
AIR 2004 SC 456.

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Narco-Analysis and Brain Mapping

In State of U.P v. Boota Singh,18Apex Court held that if directions are issued to the accused
to give his specimen signatures and handwriting that does not amount to testimonial
compulsion similar is the case with scientific evidence because accused is just directed to
undergo a test not to give a specific statement.

Furthermore, Medical Examination of the accused is not barred under Article 20(3)19 even
drawing of blood samples, pubic hair etc. in the offence of rape, where prosecution has to
establish the guilt of accused beyond reasonable doubt is not held to be violative of Article
20(3)20 because right to fair investigation is a fundamental right, 21 that no victim should be
derived to especially in a criminal case.

Similarly, Punjab and Haryana High Court held that subjecting an accused to DNA test does
not violate Article 20(3). It is out of question that any infringement of right against
testimonial compulsion occurs if the court requires a person male or female to submit to
DNA,22 the courts can do so validly. The question arises that when courts can compel an
accused for DNA tests; to give specimen signatures, hand, palm, foot impressions, there
should be no hesitation in subjecting accused to Narco-analysis, polygraph and brain
mapping tests as these techniques would help in efficient investigations and inquiries by
authorities.

BIBLIOGRAPHY

18
AIR, 1978 SC 1770

19
State v. NavjotSandhu (2005) 11 SCC 600.

20
Halappa v. State of Karnataka, 2011(7) RCR (Criminal) 29 Karnataka.

21
Virbhadr Singh v. State of H.P 2011(1) RCR (Criminal) 396 (Ho.)

22
HarjinderKaur v. State of Punjab, 2013(2) RCR (Criminal) 146 (P and H).

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BOOKS REFERRED:

 T. Bhattacharyya, “The Interpretation of Statutes”, Allahabad: Central Law Agency, Sixth

Edition, 2006, p. 10
 Bimaldeep Singh, “Scientific Techniques of Obtaining Evidence”, Law Journal of Guru Nanak
Dev University, Vol. XVII p 92.
 Joshi, Nayan, “Medical Jurisprudence and Toxicology”, New Delhi, Kamal Publishers, 2008.
p267

WEBSITES REFERRED:

 https://www.crimesceneinvestigatoredu.org/what-is-forensic-science/

 www.indlaw.com; www.dnaindia.com. visited on 20th October,2017

 www.outlookindia/pti_news.asp?id=296155, visited on 20th October ,2017

 www.legalservicesindia.com
 www.scconline.com

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