The Allahabad High Court has expressed serious concern over the inadequate infrastructure and staffing levels at Forensic Science Laboratories (FSLs) in Uttar Pradesh, observing that deficiencies in forensic analysis are resulting in rape and murder accused securing bail due to the absence of conclusive scientific evidence.
The single-judge Bench of Justice Arun Kumar Singh Deshwal made the observations while granting bail to an accused in a rape and murder case. The Court noted that it was compelled to extend the benefit of bail because crucial forensic evidence could not be conclusively established owing to shortcomings in the State’s forensic infrastructure.
Justice Deshwal directed that a copy of its order be forwarded to the office of the Chief Minister of Uttar Pradesh, Yogi Adityanath, through the Chief Secretary for appropriate consideration. The Bench expressed the expectation that the State Government would take immediate steps to strengthen forensic facilities by providing modern high-end equipment and ensuring adequate staffing in forensic laboratories.
The Court observed that it had dealt with several cases involving allegations of rape followed by murder, where vaginal swabs and DNA samples of accused persons were sent for forensic examination. However, in a large number of such cases, the FSL reports revealed that the source of DNA found in the samples could not be determined because of incomplete generation of DNA profiles. According to the Court, this recurring issue has significantly affected the quality of criminal investigations and the prosecution’s ability to establish guilt through scientific evidence.
The observations were made while hearing the bail application of a man accused of raping and murdering a woman last year. According to the prosecution, the victim had gone missing and was later found dead near a river. A witness had allegedly seen the accused proceeding towards the area where the victim’s body was subsequently recovered.
Seeking bail, counsel for the accused argued that the forensic report supported his defence, as the DNA profile obtained from the vaginal smear of the deceased did not match his DNA. It was further submitted that there was no other incriminating material connecting him to the alleged offence, that he had been falsely implicated, and that he had remained in judicial custody since November 21, 2025.
While considering the submissions, the High Court noted that the absence of a DNA match in the present case could not automatically be treated as proof of innocence because the forensic report itself indicated that a complete DNA profile had not been generated. The Court observed that outdated equipment and inadequate forensic infrastructure were major reasons behind the inability to obtain conclusive scientific results.
The Bench remarked that it was constrained to grant bail despite the gravity and heinous nature of the allegations because the investigation lacked reliable scientific evidence linking the accused to the offence. The Court stated that the failure to generate a complete DNA profile represented a significant anomaly in both the investigation process and the functioning of forensic laboratories.
The Court further recorded that it had recently been informed by the Director of the Uttar Pradesh Forensic Science Laboratory that many forensic laboratories across the State were suffering from acute shortages of personnel and infrastructure. According to the Bench, these systemic deficiencies were adversely affecting the administration of criminal justice and weakening the evidentiary foundation of serious criminal prosecutions.
Justice Deshwal observed that no one could be held responsible for the failure in the present case except the State Government, which had failed to provide adequate infrastructure and modern technological support to forensic laboratories. The Court noted that the continued use of outdated machinery and insufficient facilities was directly contributing to inconclusive forensic reports in serious criminal cases.
Emphasising the importance of scientific evidence in the investigation and prosecution of offences such as rape and murder, the Court said it was granting bail to the accused with a “heavy heart” because of the lack of reliable medical and forensic evidence. The Bench reiterated that unless substantial improvements are made to forensic infrastructure, similar situations may continue to arise, where courts are left with no option but to extend the benefit of bail despite the seriousness of the allegations.
The Court ultimately granted bail to the accused while simultaneously highlighting the urgent need for systemic reforms in Uttar Pradesh’s forensic science infrastructure to ensure effective criminal investigations and proper administration of justice.
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