DNA Chain-of-Custody Failures: Supreme Court Acquits Two in 2012 Child Rape-Murder

On 26 August 2025, a three-judge bench of the Supreme Court — Justices Vikram Nath, Sanjay Karol and Sandeep Mehta — allowed appeals in Putai v. State of Uttar Pradesh and set aside convictions in a 2012 rape-murder of a 12-year-old girl.

Putai (sentenced to death by the trial court) and co-accused Dileep (given life imprisonment) were acquitted because the prosecution “fell woefully short” of proving guilt beyond a reasonable doubt; the Court held that the forensic proof, particularly the DNA material, was irretrievably compromised. The Court described the investigation as “a classic example of lacklustre and shabby investigation” and held that, without credible chain-of-custody documents, the DNA reports were “a piece of trash paper.”

This ruling is a stark reminder that scientific evidence — powerful when properly handled — can be fatal to the prosecution when the procedures that impart it credibility are ignored.

Where the prosecution failed: chain of custody and expert proofing

The Court’s reasoning focused on two linked defects:

• No documentary proof of sample collection. The prosecution did not produce contemporaneous documents showing the procedure, date or time of drawing blood samples from the accused. Without those entries, the Court said, it was impossible to establish an “unbroken chain of safe custody” for the biological material sent for DNA comparison.

• Improper admission of a supplementary DNA report. The first DNA report was inconclusive; a supplementary report dated 2 December 2014 was subsequently produced via affidavit in the High Court. The Supreme Court held that a DNA report — being a substantive piece of evidence — could not be proved by affidavit and that the prosecution should have recalled and examined on oath the scientific expert who issued the report (Dr. Archana Tripathy). The Court emphasised that the report was never put to the accused under Section 313 CrPC, and the affidavit evidence was therefore legally inadequate.

Taken together, these defects meant that the DNA material could not be treated as a reliable corroboration of the circumstantial case.

The legal principle reaffirmed: circumstantial cases and proof beyond a reasonable doubt.

The Court reiterated a well-settled rule of criminal jurisprudence: in cases resting primarily on circumstantial evidence, the incriminating circumstances must point exclusively to the guilt of the accused and be inconsistent with any reasonable hypothesis of innocence.

The Bench observed that even if incriminating articles (chappals, underwear, a water canister) were recovered from a field cultivated by Putai, the prosecution failed to exclude the possibility of third-party access to the open fields or to call nearby witnesses who could have seen activity during the relevant hour.

In short, the evidentiary distance between “may be proved” and “must be proved” was not crossed.

Systemic consequences: labs, accreditation and procedure

The judgment will inevitably rekindle debate on institutional forensic capacity:

• Laboratory protocols and accreditation. Forensic Science Laboratories (FSLs) must follow standard operating procedures; courts and litigators will increasingly look for proof of chain-of-custody, sample handling, laboratory accreditation (e.g., NABL) and quality control documentation.

• Training and SOPs for police. The ruling underlines the need for police training in evidence-handling — particularly in sexual-offence investigations where timely and correct collection of biological evidence is decisive.

• Courtroom practice. Trial courts must be alert to the admissibility rules governing scientific evidence (including the need to examine scientific witnesses) and to ensure that Section 313 CrPC procedures are observed when forensic findings are relied upon.

Broader jurisprudential significance

The Court’s decision does not denigrate DNA as a tool; rather, it reinforces that scientific certainty in the abstract is insufficient — the State must prove the provenance and integrity of samples.

This aligns with prior judicial concerns about forensic admissibility and the chain-of-custody rule, and it demonstrates the Court’s insistence that procedural safeguards be observed even in the pursuit of heinous crimes.

The ruling is also a sober reminder of the constitutional balance: while the judiciary recognises the seriousness of sexual crimes against children, the fundamental fairness of the trial process and the requirement of proof beyond a reasonable doubt remain paramount. When institutional lapses are identified, the Court will not allow finality to rest on evidence the record cannot sustain.

What to expect next

• Prosecutorial reforms and supervisory interest. Expect renewed administrative focus on FSL functioning, police SOPs for biological evidence and perhaps court-led directions where systemic lacunae are evident.

• Defensive litigation strategy. Where convictions rest on forensic material, defence teams will increasingly scrutinise the chain of custody and the procedural propriety of experts’ testimony.

• Legislative and policy conversations. The ruling may feed into policy debates on forensic infrastructure, accreditation and a centralised framework for handling DNA evidence in criminal investigations.

Conclusion

Putai v. State of Uttar Pradesh is a clarion ruling: scientific evidence can convict but only when its provenance, handling and proof meet the exacting standards the law demands.