DNA Evidence Held Unreliable
DATE :- 06-09-2025
Case Details
Case Title: Putai & Anr. v. State of Uttar Pradesh
Citation: 2025 INSC 1042
Court: Supreme Court of India, Criminal Appellate Jurisdiction
Bench: Justice Mehta
Date: September 2025
Background of the Case
In September 2012, a 12-year-old girl went missing from her village in Lucknow district. The following morning, her body was discovered in a nearby field. The police recovered certain belongings of the victim, including footwear, a water canister, and undergarments, allegedly from a field cultivated by accused Putai. A comb, later linked to co-accused Dileep, was also seized.
The trial court convicted both accused under Sections 302 (murder), 376(2)(g) (gang rape), and 201 (causing disappearance of evidence) IPC. Putai was sentenced to death, while Dileep received life imprisonment. The Allahabad High Court confirmed the convictions in 2018.Both accused challenged the verdict before the Supreme Court.
Defence Arguments
The conviction was based solely on circumstantial evidence without an unbroken chain of proof. DNA reports were contradictory: the first report (2014) was inconclusive, while the supplementary report (2014) was introduced belatedly without proper procedure. No reliable documentation established the safe custody or transmission of forensic samples.
Witness testimonies contained contradictions and exaggerations, particularly regarding the alleged “suspicious conduct” of the accused.
State’s Position
The victim’s belongings were recovered from fields connected with the accused, shifting the burden of explanation on them under Section 106 Evidence Act.
Witnesses had no motive to falsely implicate the accused. Minor contradictions in testimony should not overshadow the gravity of the crime.
Supreme Court’s Analysis
The Supreme Court examined the evidence in detail and found major flaws in the prosecution case:
Unreliable Forensic Evidence: The chain of custody for DNA samples was not proved. The supplementary DNA report was introduced without recalling the expert or confronting the accused under Section 313 CrPC.
Contradictory Witness Testimonies: Accounts regarding the recovery of articles, colour of the comb, and the conduct of the accused varied significantly.
Planted Recoveries: The Court noted strong suspicion that the recovery of certain items, including the victim’s underwear, was fabricated to strengthen the prosecution case.
No Direct Evidence: The case rested entirely on circumstantial evidence, which did not conclusively establish guilt beyond reasonable doubt.
Verdict
The Supreme Court set aside the convictions, holding that the prosecution failed to prove the case with the degree of certainty required in criminal trials. Both appellants, Putai and Dileep, were acquitted of all charges.
Significance of the Judgment
This decision underscores the judiciary’s consistent stance that:
Convictions in serious crimes must rest on unimpeachable evidence.
DNA reports must be supported by a clear chain of custody and proper examination of experts.
Suspicion, however grave, cannot replace proof in criminal jurisprudence.
Keywords
Supreme Court acquittal 2025, Lucknow minor rape case judgment, DNA evidence reliability in India, circumstantial evidence criminal law, IPC Section 302 and 376 judgments, Indian Supreme Court latest case law
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