Author: Shanmayie Natchiyar M
University: Symbiosis Law School, Nagpur
BA.LLB
I. Introduction
The Indian criminal justice system, similar to the majority of those globally, tries to make sure that justice is not only served but that it is perceived to be served. The inclusion of forensic science within the legal system over the last few decades has helped fundamentally to increase the effectiveness and reliability of criminal investigations. Forensic science offers scientific and objective evidence that helps the courts determine the innocence or guilt of alleged offenders. Among the several milestone cases that underscore the value of forensic evidence, Santokh Singh v. State of Punjab is a strong example.
In this instance, forensic science, and more specifically ballistic examination, was instrumental in establishing the accused person’s guilt. The judgment highlights the judiciary’s increasing dependence on scientific procedure as an essential aid to the dispensation of justice. This commentary discusses the circumstances of the case, the forensic details in question, the court’s judgment, and the implications of the case for the use of forensic techniques in Indian jurisprudence.
II. Background and Facts of the Case
The case of Santokh Singh v. State of Punjab concerned a charge under Section 302 of the Indian Penal Code (IPC) of murder. The accused Santokh Singh was said to have shot the deceased dead in a scuffle. The case against him was proved through a mix of eyewitness evidence and ballistic forensic evidence.
The prosecution alleged that Santokh Singh had fired a revolver at the victim, killing the latter. The bullet was extracted from the dead body, and a revolver was recovered from the accused person. The pivotal issue was whether the bullet extracted from the dead body could be traced scientifically to the weapon held in the hand of Santokh Singh.III. Legal Issues Raised
The case raised a number of legal issues at the heart of the application of forensic science to criminal conviction:
1.Would the ballistic report conclusively prove that the bullet responsible for the fatal wound was discharged from the revolver that was retrieved from the accused?
2.Was the forensic evidence reliable and conclusive enough to be used for a conviction?
3.How should the court balance forensic evidence against eyewitness testimony and circumstantial evidence?
IV. Forensic Science and Ballistic Evidence
Ballistics is a forensic science that deals with the examination of firearms, bullets, and trajectory paths of projectiles. For this purpose, the prosecution presented a forensic report prepared by a ballistic expert who analyzed the bullet extracted from the victim and the revolver recovered from the suspect. The ballistic expert determined that the rifling marks on the bullet matched those of the recovered revolver. Rifling marks are unique patterns left on a bullet as it passes through the barrel of a gun. These impressions serve as a sort of “fingerprint” that can link a bullet to a particular weapon. The evidence proved forensic that the bullet which inflicted the fatal wound was, in fact, discharged by the accused revolver.
The court’s reasoning and judgment
The conviction of Santokh Singh was affirmed by the Supreme Court. The court held that the ballistic evidence constituted a solid, objective basis for corroborating the eyewitness testimony. The forensic report categorically linked the bullet to the revolver of the accused, so as not to leave any doubt as to the weapon used in committing the crime.
The court highlighted that forensic science, in this case ballistic analysis, played the most important role in determining the accused beyond a reasonable doubt. The scientific character of the evidence eliminated the chance for human mistake or prejudice that would contaminate eyewitness testimony. The decision showed expanding judicial appreciation of the probative value of forensic evidence in criminal trials.
VI. Importance of Forensic Evidence in Criminal Justice
The judgment in Santokh Singh is a milestone in the development of forensic science within India’s criminal justice framework. It highlights several important points:
1.Objectivity: Forensic science introduces an element of neutrality and objectivity into criminal investigations that traditional evidence cannot match. Scientific examination is not subject to emotions or biases.
2.Corroboration: In numerous situations, forensic evidence can strengthen or disprove eyewitness accounts, adding another level of confirmation.
3. Credibility: Courts are increasingly acknowledging the credibility of scientific evidence, particularly when offered by competent experts using established protocols.
4. Technological Advancement: The case underlines the requirement for consistent investment in forensic facilities and training to aid in accurate and timely analysis.
VII. Broader Implications and Comparative Perspectives
Increased use of forensic proof in India is a mirror of trends worldwide. Forensic science has been a part of criminal investigations in countries such as the United States and the United Kingdom for a long time. The Indian legal system, though initially lagging behind in this respect, is catching up slowly.
Examples such as Santokh Singh set the stage for more stringent evidence gathering and analysis. They also highlight the need for keeping the chain of custody intact and for safeguarding forensic labs from outside interference. The introduction of Criminal Procedure (Identification) Act, 2022, adds to the enhancement of the role of science in policing through wider collection of biometric and forensic information.
Furthermore, the case highlights the significance of interdisciplinary cooperation between the legal and scientific fields. Judges, attorneys, and law enforcement personnel need to have an operational understanding of forensic principles in order to properly interpret and challenge scientific evidence.
VIII. Related Case Laws
To better clarify the increasing use of forensic science in India, it is helpful to review other significant decisions:
1.State of Maharashtra v. Damu, (2000) : In this case, DNA analysis was instrumental in identifying the rapist and murderer. The Supreme Court placed special emphasis on the reliability of DNA evidence.
2. Selvi v. State of Karnataka, (2010) : In this case, the issue of admissibility of narco-analysis, polygraph tests, and brain mapping was addressed. The Court held that the methods were violative of Article 20(3) unless consent is taken, reiterating the importance of voluntary and ethical forensic procedures.
3.Mukesh & Anr v. State for NCT of Delhi, (2017) 6 SCC 1 (Nirbhaya Case): In the well-publicized case, forensic analysis involving DNA, fingerprints, and bite mark were crucial in obtaining convictions.
The foregoing cases cumulatively demonstrate how forensic techniques are being successfully utilized in India’s criminal justice system, although issues relating to procedure, ethics, and expert availability persist.
IX. Challenges in Forensic Science Implementation in India
Though promising, forensic science in India has several challenges:
1. Lack of Infrastructure: States are short of well-equipped forensic labs and even these are overworked.
2. Shortage of Experts: Forensic scientists and technicians are in extremely short supply.
3. Delays in Reports: Delays in receiving forensic reports cause investigations and trials to be delayed due to backlogs.
4.Awareness Among Legal Professionals: There is a need for greater awareness and training among judges, prosecutors, and defense lawyers regarding the interpretation of forensic evidence.
X. Conclusion
The Santokh Singh v. State of Punjab case is a milestone in the shift in the Indian judiciary’s stance on forensic science. By placing heavy importance on ballistic evidence, the Supreme Court established the significance of science in revealing the truth and dispensing justice. As India goes about upgrading its criminal justice system, forensic science will inevitably play a much more critical role.
The case is a strong precedent for future use of scientific techniques in the investigation and prosecution of criminal cases. But to be able to fully realize the potential of forensic science, there needs to be improvement in infrastructure, training, as well as ethical standards on a systemic level. Only then can forensic science actually live up to its potential as the foundation of a just, accurate, and efficient criminal justice system in India.
