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2008 2 Supreme 226 : The document states that in cases involving blood-stained articles, it is necessary for the Investigating Officer (I.O.) to send the blood-stained articles along with blood samples of the victim or accused to a Forensic Science Laboratory (FSL) for determination of blood group. It further directs that the Police Manual be amended to incorporate this procedure for mandatory compliance in the protocol of investigation. This indicates that FSL reports are mandatory in such forensic investigations involving blood group analysis, particularly in cases of alleged forgery or violence where blood evidence is relevant. Although the document does not explicitly use the term ''''forgery'''', it establishes that FSL reports are mandatory for scientific corroboration in criminal cases involving blood evidence, which may be relevant in forgery cases where biological evidence (e.g., blood on forged documents) is involved.Checking relevance for Sanjay Dubey VS State of Madhya Pradesh...
Checking relevance for Jayantibhai Mohanbhai Patel (Padaria) VS State of Gujarat...
2018 0 Supreme(SC) 2065 : The FSL (Forensic Science Laboratory) report is not mandatory for proving forgery. In the case analyzed, the FSL report was used to create reasonable doubt regarding the accused''''s guilt in a rape case, leading to acquittal on the basis of benefit of doubt. This indicates that while an FSL report may be valuable evidence, its absence does not automatically invalidate a conviction, and it is not a legal requirement for establishing forgery or other criminal charges. The court emphasized that the burden of proof beyond reasonable doubt must be met regardless of whether an FSL report is available.Checking relevance for DOLA @ DOLAGOBINDA PRADHAN VS STATE OF ODISHA...
Checking relevance for State Of Rajasthan VS Sahi Ram...
2019 0 Supreme(SC) 1082 : The FSL (Forensic Science Laboratory) report is not mandatory for conviction in forgery cases under the NDPS Act, but its absence can significantly affect the prosecution''''s case. The court held that while the non-production of contraband material before the court is not by itself sufficient to grant acquittal, the prosecution must still establish the seizure and identity of the material through cogent evidence. In the absence of the FSL report, the prosecution must rely on other evidence such as panchnamas and oral testimony, but such evidence may not be sufficient to discharge the heavy burden of proof, especially when the FSL report is awaited or not produced. The court emphasized that the best evidence would be the actual seized material, and the failure to produce it, along with the absence of the FSL report, raises serious doubts about the prosecution''''s case. However, the court did not rule out conviction without the FSL report if other evidence is strong enough, indicating that the report is not strictly mandatory but highly critical to the prosecution''''s burden.Checking relevance for Jamnalal vs State of Rajasthan...
Checking relevance for Virat Pachauri VS State of Uttar Pradesh...
2023 0 Supreme(All) 1093 : The document establishes that a Forensic Science Laboratory (FSL) report is not mandatory for the prosecution of forgery under Section 467, 468, or 471 of the Indian Penal Code. It clarifies that while an FSL report can serve as prima facie evidence of forgery—particularly regarding disputed signatures—the Investigating Officer is not required to obtain prior permission from a Magistrate to send a document for FSL examination. The court held that sending a document to FSL for signature verification is permissible during investigation without seeking prior direction under Section 311-A Cr.P.C., which only applies when a person must be directed to provide specimen handwriting or signature. Thus, while an FSL report strengthens the case, it is not legally mandatory for initiating or proving a forgery charge.Checking relevance for Parmeet Singh Anand vs Subhash Chand Aggarwal...
Checking relevance for KHILAN SINGH S/o KODU SINGH VS STATE OF MADHYA PRADESH...
2022 0 Supreme(MP) 490 : The court held that the non-filing of the Forensic Science Laboratory (FSL) report with the challan does not entitle the applicant to default bail under section 167(2) of the Criminal Procedure Code. This indicates that while the FSL report may be important for the prosecution''''s case, its absence does not automatically make bail mandatory or trigger default bail provisions. Therefore, the FSL report is not mandatory for the purpose of triggering mandatory default bail in cases involving forgery or similar offences under the NDPS Act, as the failure to file it does not vitiate the challan or entitle the accused to bail under section 167(2) CrPC.