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Searching Case Laws & Precedent on Legal Query.....!
Analysing the retrieved Case Laws
Scanned Judgements…!
Foresic Science Report Not Submitted with Final Police Report - In several cases, courts have noted that the police did not submit forensic science reports (FSL) along with the final reports under Section 173 CrPC, affecting the court’s assessment of evidence and the prosecution's case. For example, in Yelamoni Bhasker Mudiraj vs The State of Telangana - 2025 Supreme(Online)(TEL) 4060 - 2025 Supreme(Online)(TEL) 4060, the court observed that sending documents for fingerprint or signature verification would cause delays, and thus, the court dismissed petitions challenging this. Similarly, in ASHIK Vs STATE OF KERALA - Kerala, a final report was filed without the forensic signatures being sent to FSL, but the court accepted the report due to the absence of criminal antecedents and the completion of investigation references: Yelamoni Bhasker Mudiraj vs The State of Telangana - 2025 Supreme(Online)(TEL) 4060 - 2025 Supreme(Online)(TEL) 4060, ASHIK Vs STATE OF KERALA - Kerala.
Legal Consequences of Not Submitting Forensic Reports - Courts have emphasized that the absence of forensic reports at the final stage does not necessarily invalidate the police report or the prosecution’s case, especially when investigation is complete and no criminal record exists. However, the failure to obtain or submit forensic evidence can impact the strength of the case, and courts may reject final reports if they find material to suggest incomplete investigation (INDINDRAJ00000044468, IND02500112850).
Court Authority to Accept or Reject Final Reports - Courts retain the authority to accept, reject, or call for further investigation of final reports under Section 173 CrPC. For instance, in INDINDRAJ00000044468, the court rejected the final report due to insufficient evidence, and in IND01400037202, the court did not accept the final report because of procedural lapses, such as non-appearance of police officers references: INDINDRAJ00000044468, IND01400037202.
Impact of Non-Submission of Forensic Evidence on Legal Proceedings - The non-submission or delayed submission of forensic reports can lead to delays in trial, affect bail considerations, and influence the court’s decision on whether to proceed with cognizance or to quash cases. For example, in R.Mani vs The State Rep. by the Inspector of Police, T2, Ambattur Estate Police Station, Ambattur Estate, Chennai - 2025 Supreme(Online)(Mad) 25180 - 2025 Supreme(Online)(Mad) 25180, timely filing of forensic reports was mandated to ensure expeditious investigation and trial, while courts have rejected final reports lacking forensic confirmation (R.Mani vs The State Rep. by the Inspector of Police, T2, Ambattur Estate Police Station, Ambattur Estate, Chennai - 2025 Supreme(Online)(Mad) 25180 - 2025 Supreme(Online)(Mad) 25180).
Legal Consequences for the Accused - The absence of forensic evidence does not automatically lead to acquittal; courts assess the entire investigation and evidence. If the police fail to submit forensic reports, it may weaken the case but does not necessarily preclude prosecution unless the evidence is crucial. Courts may also consider whether the investigation was properly conducted and whether the final report is supported by sufficient material. In cases where forensic evidence is integral, its absence may lead to case dismissal or further investigation (INDINDRAJ00000044468, IND02500112850).
Analysis and Conclusion:The legal system recognizes the importance of forensic science reports in criminal investigations and trial proceedings. While courts have the discretion to accept or reject final reports based on procedural compliance and evidentiary sufficiency, the non-submission of forensic evidence can adversely impact the case’s strength and delay justice. Proper procedural adherence, including obtaining necessary forensic reports before submitting final reports, is crucial. Failure to submit such evidence can result in court rejection of reports, delays, or case quashing, but does not automatically absolve or convict the accused without considering the totality of evidence references: all sources.
In criminal investigations, forensic science reports play a pivotal role in establishing evidence linking the accused to the crime. But what happens when the original forensic science report is not submitted alongside the police final report to the court? This question—Forensic Science Report Original Not Submitted with Police Final Report to the Court Legal Consequences for Accused—raises critical concerns under Indian law, particularly Section 173 of the CrPC, which governs the submission of police reports.
The absence of such crucial evidence can create procedural hurdles, weaken the prosecution's case, and potentially benefit the accused. This blog post explores the legal implications, drawing from key case laws and principles. Note: This is general information and not specific legal advice. Consult a qualified lawyer for your case.
Under Indian criminal procedure, the police must submit a complete final report (chargesheet) under Section 173 CrPC, including all relevant documents and evidence. Forensic science laboratory (FSL) reports are often essential for proving the nature of seized materials, signatures, fingerprints, or other scientific links to the crime.
Courts scrutinize the admissibility of scientific evidence. Without the original FSL report, the prosecution may struggle to meet the burden of proof. In N.P. Jharia v. State of M.P., the court stressed the need for proper investigation and submission of forensic reports to substantiate charges. STATE THROUGH CENTRAL BUREAU OF INVESTIGATION VS HEMENDHRA REDDY - Supreme CourtShyamal Ghosh VS State of West Bengal - Supreme Court
The lack of forensic evidence raises doubts about reliability. For instance, if drugs or substances are seized but not chemically verified via FSL, the chain of evidence breaks. In State v. Jitendra, non-production of seized drugs and absent forensic evidence undermined the case. Jitendra VS State Of M. P. - Supreme Court
Failure to include the FSL report constitutes a procedural lapse. Courts have vitiated proceedings for such omissions. In Bhagwant Singh v. State of Punjab, the Supreme Court highlighted flaws in accepting final reports without proper notice or documents. Union Public Service Commission VS S. Papaiah - Supreme Court
From additional judicial observations, courts note that while FSL reports are vital, their delayed or non-submission doesn't always invalidate the entire report if the investigation is otherwise complete. However, in cases like one where the Forensic Science Laboratory report was not submitted to the court or not, it is not forthcoming, this absence questions the prosecution's claims, such as whether seized ganja was properly identified. Vikram VS State Of Karnataka - 2020 Supreme(Kar) 947 - 2020 0 Supreme(Kar) 947
Another example: But the Forensic Science Laboratory report was not submitted before the Trial Court. This lends support to the case of the defence that it is a case of accidental burns. State of Karnataka VS K. Nagaraja - 2015 Supreme(Kar) 979 - 2015 0 Supreme(Kar) 979
The prosecution must prove guilt beyond reasonable doubt. Missing FSL reports create gaps:- Reasonable Doubt: Courts apply the benefit of doubt principle if key evidence is absent. Rajendra Pralhadrao Wasnik VS State of Maharashtra - Supreme Court- Incomplete Investigation: Judges can reject final reports under Section 173 CrPC if materials suggest incompleteness. For example, If the court is of the opinion that the materials collected by the police in the report submitted under section 173 of Cr. Shailesh Kumar S/o A. Janardhan Achar VS Nisha S. Kumar W/o Shailesh Kumar - 2024 Supreme(Kar) 274 - 2024 0 Supreme(Kar) 274
In Yelamoni Bhasker Mudiraj vs The State of Telangana - 2025 Supreme(Online)(TEL) 4060 - 2025 Supreme(Online)(TEL) 4060, the court considered an FSL opinion on signatures dated 13.05.2014, stating the person who wrote the red enclosed signatures marked S1 and S58 also wrote the... but noted delays in submission. Yelamoni Bhasker Mudiraj vs The State of Telangana - 2025 Supreme(Online)(TEL) 4060
Similarly, in cases where permission was sought from civil courts for original deeds before FSL analysis, non-submission affected charge sheets: Apart from this, it is also clear from the record that before sending the alleged forged deed for the FSL report, permission to obtain the original deed was received... Virat Pachauri VS State of Uttar Pradesh - 2023 Supreme(All) 1093 - 2023 0 Supreme(All) 1093
Courts may order further investigation or accept reports if no cognizable offense is evident, as in negative final reports: negative final report was submitted by the SHO... DR VINAY SUREN Vs. STATE OF RAJASTHAN AND ANR - 2025 Supreme(Online)(Raj) 13812 - 2025 Supreme(Online)(Raj) 13812
The non-submission often favors the accused:- Potential Acquittal: If the case relies heavily on forensics, lack of report leads to acquittal due to insufficient evidence. Dayal Singh VS State of Uttaranchal - Supreme Court- Benefit of Doubt: Prosecution fails to establish a prima facie case. Rajendra Pralhadrao Wasnik VS State of Maharashtra - Supreme Court- Grounds for Appeal: Convictions despite omissions provide appeal grounds on procedural irregularities. P. Gopalkrishnan @ Dileep VS State of Kerala - Supreme Court
However, absence doesn't guarantee acquittal; courts assess totality of evidence. In INDRESH RAMBACHAN NISHAD V/s NATIONAL INVESTIGATION AGENCY - 2024 Supreme(Online)(Guj) 27801 - 2024 Supreme(Online)(Guj) 27801, examination was limited to case diary and final report, even without full forensics. INDRESH RAMBACHAN NISHAD V/s NATIONAL INVESTIGATION AGENCY - 2024 Supreme(Online)(Guj) 27801 - 2024 Supreme(Online)(Guj) 27801
Other impacts include:- Bail Considerations: Weak evidence strengthens bail pleas.- Trial Delays: Courts may direct FSL submission, as in On receipt of the forensi.... R.Mani vs The State Rep. by the Inspector of Police, T2, Ambattur Estate Police Station, Ambattur Estate, Chennai - 2025 Supreme(Online)(Mad) 25180- Report Rejection: Magistrates can reject incomplete reports, e.g., in the Final Report by not accepting the Final Report... Ikbal Bahar Hussain S/o Abdul Noor vs State of Assam - 2025 Supreme(Gau) 1267 - 2025 0 Supreme(Gau) 1267
In Velutha VS Sub-Inspector of Police - 2016 Supreme(Ker) 823 - 2016 0 Supreme(Ker) 823, a final report was deemed inadmissible due to investigation by non-empowered officers, compounded by missing forensics: This legal infirmity... was not considered... therefore the final report is not admissible. Velutha VS Sub-Inspector of Police - 2016 Supreme(Ker) 823 - 2016 0 Supreme(Ker) 823
Defense counsel should:1. Highlight the omission during arguments.2. Argue for discharge or quashing under Section 227/239 CrPC.3. Seek benefit of doubt.
Courts exercise discretion: Filing of subsequent supplementary challan... would not affect the status of earlier filed Final Police Report. Mere recital... Report of the Forensic Science Laboratory had to be obtained, would not... make the Police Challan... incomplete. Chatnaya SB (Captain) VS State Of J. &K. - 2008 Supreme(J&K) 426 - 2008 0 Supreme(J&K) 426
In R.Saravanan vs The Inspector of Police - 2024 Supreme(Online)(MAD) 14473 - 2024 Supreme(Online)(MAD) 14473, police filed final reports post-investigation, resisting quashing. R.Saravanan vs The Inspector of Police - 2024 Supreme(Online)(MAD) 14473 - 2024 Supreme(Online)(MAD) 14473
Non-submission of original forensic science reports with police final reports can significantly weaken prosecutions, offering the accused avenues like acquittal, appeals, or discharge. While not always fatal—especially if other evidence suffices—it underscores procedural rigor under CrPC.
Key Takeaways:- Always demand FSL reports in defense.- Courts may reject incomplete reports or order supplements.- Totality of evidence matters; forensics are crucial but not sole deciders.
Legal practitioners must ensure meticulous evidence collection. For personalized guidance, consult an expert. References include Manoj VS State of Madhya Pradesh - Supreme CourtMathew Alexander VS Mohammed Shafi - Supreme CourtSTATE THROUGH CENTRAL BUREAU OF INVESTIGATION VS HEMENDHRA REDDY - Supreme CourtPravin Chandra Mody VS State Of A. P. - Supreme CourtChandrama Tewari VS Union Of India (Through General Manager, Eastern Railways) - Supreme CourtVADLA CHANDRAIAH VS STATE OF ANDHRA PRADESH - Supreme CourtUnion Public Service Commission VS S. Papaiah - Supreme CourtJitendra VS State Of M. P. - Supreme CourtShyamal Ghosh VS State of West Bengal - Supreme CourtDayal Singh VS State of Uttaranchal - Supreme CourtSau Saraswatibai VS Lalitabai - Supreme CourtP. Gopalkrishnan @ Dileep VS State of Kerala - Supreme Court and other cited sources.
#ForensicEvidence #CriminalLawIndia #LegalConsequences
Learned counsel for respondent No.2 submitted that the Assistant Director, Andhra Pradesh Foresic Science Laboratories, upon examining the documents in C.C.No.130 of 2010 rendered her opinion on 13.05.2014, stating that “the person who wrote the red enclosed signatures marked S1 and S58 also wrote the ... Having regard to the submissions of both the learned counsel and upon perusal of the copy of the expert opinion dated 13.05.2014 rendered....
It is now submitted that following investigation into the matter a final report has already been filed in the matter and since no criminal antecedents are reported against the petitioner, the petitioner may be directed to be released on bail. ... The learned counsel for the petitioner submits that the petitioner is a 20 year old boy who has been in custody for nearly 100 days and his continued detention is not necessary as....
It was further submitted that after lodging FIR, investigation was conducted by the police authorities and as no cognizable offence was found to be proved against the petitioner, hence, negative final report was submitted by the SHO, Police Station Sodala, District Jaipur on 14.12.2007. ... It is further submitted that after filing of negative final #H....
Apart from this, it is also clear from the record that before sending the alleged forged deed for the FSL report, permission to obtain the original deed was received from the concerned civil court and after seeking permission from the civil court where the suit filed by the applicants was pending, same ... It was also submitted that the sole basis for submitting the charge sheet is the FSL repor....
of the final report. ... v) If the court is of the opinion that the materials collected by the police in the report submitted under section 173 of Cr. ... iii) If the court is of the opinion that the ‘B’ Summary Report submitted by the Police has to be rejected, then by expressing its judicious opinion, after apply....
Filing of final report by police and complaint by other investigation agencies. ... (9) System generated final report filed by the police manually or electronically shall be accepted by the Court. ... On such matters, the accused cannot claim an indefeasible legal right to claim every document of the police file or even....
in the Final Report by not accepting the Final Report. ... Notice was thereafter, sent to the Officer In-Charge, Karimganj Police Station for a hearing on the Final Report submitted by the I.O. The Officer In-Charge, Karimganj Police Station despite being summoned, did not appear before the learned ....
BNSS , to direct the respondent Police to file a Final Report in Crime No.535 of 2024 on the file of the respondent Police within stipulated time. ... seeking a direction to the respondent police to file the final report in Crime No.535 of 2024 pending on the file of the respondent police, within a stipulated period. ... (ii) On receipt of the forensi....
Side) appearing for the first respondent police would contend that the police after conducting proper investigation filed the final report and therefore, there is no good ground to quash the same. He therefore prayed for dismissal of the present Criminal Original Petition. ... report in C.C.No.461 of 2020 on the file of the Judicial Magistrate Court No.I, Nagercoil, Kan....
1.1 Examine if, prima facie, the alleged 'accusations' make out an offence under Chapter IV or VI of the UAP Act 1.2 Such examination should be limited to case diary and final report submitted under Section 173 CrPC; 2) Whether the accused deserves to be ... It is submitted that the appellant is not found with the possession of the contraband. ... Court at Ariritsar by NIA on 29.09.2021....
I now see the original final report submitted to police Inspector, Jnanabharathi Police station, which bears my signature. The signature of the witness is marked as Ex.P.14(a). I have formed of the opinion that victim girl used an act like that of sexual intercourse. This report with final opinion is marked as Ex.p.14.
The Forensic Science Laboratory report was not submitted to the court or not, it is not forthcoming. The Ganja which was seized by the police is whether it is a Ganja, leaves or seed, it is not specified in any documents. The Investigating Officer has already completed investigation and filed charge sheet. In the memorandum they have shown one car and in the charge sheet they have shown three cars.
The learned Public Prosecutor admitted that a part of investigation was conducted as per the direction of Circle Inspector. This legal infirmity in connection with the investigation by a non-empowered officer was not considered by the trial Court, therefore the final report is not admissible. Now the question is whether the Circle Inspector of Police, Sulthanbathery has been given any power under Section 4 of the Abkari Act to give direction to conduct such investigation? The....
But the Forensic Science Laboratory report was not submitted before the Trial Court. This lends support to the case of the defence that it is a case of accidental burns and it is not a case of homicidal death. The said can was sent for Forensic Science Laboratory examination. In the absence of Forensic Science Laboratory report, it cannot be said that the kerosene contained in M.O. 9 - can was made use of by the accused for commission of the crime.
Filing of subsequent supplementary challan to form part of the original challan too would not affect the status of earlier filed Final Police Report. Mere recital in the report that statements of some more witnesses, who were posted at far off places, were yet to be recorded and the Report of the Forensic Science Laboratory had to be obtained, would not, in my opinion, make the Police Challan filed in the present case, an incomplete Final Police Report. The documents relied u....
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