Supreme Court Restores Acquittal In POCSO Case, Holds DNA Evidence Not Infallible If Blood Sample Collection Is Disputed

"Since the concerned DNA report which forms the core basis to derive nexus of appellant to conviction, itself is doubtful, no reasonable view could have been formed which is only consistent with the guilt of the accused." Supreme Court of India, in a significant ruling, held that a conviction under the Protection of Children from Sexual Offences (POCSO) Act cannot be sustained solely on a DNA report if there are glaring evidentiary inconsistencies regarding the collection of the accused's blood sample.

A bench comprising Justice Aravind Kumar and Justice Prasanna B. Varale observed that the probative value of DNA evidence relies heavily on corroborative material and an uncompromised chain of custody, without which guilt cannot be established beyond reasonable doubt.

Background of the Case

The case stems from the tragic death of a minor girl who succumbed to burn injuries after self-immolating in July 2017. Following her death, an aborted foetus was preserved for DNA analysis, which the prosecution used to accuse the appellant of impregnating the minor. The Sessions Court acquitted the appellant after noting severe contradictions among prosecution witnesses regarding when the appellant's blood sample was drawn for the DNA test. However, the Madurai Bench of the Madras High Court reversed this acquittal and sentenced the appellant to ten years of rigorous imprisonment, prompting the present appeal.

Legal Issues

The primary question before the court was whether a DNA report could be relied upon to secure a conviction when prosecution witnesses provided fundamentally contradictory dates for the collection of the accused's blood sample. The court was also called upon to determine whether the High Court was legally justified in reversing a well-reasoned trial court acquittal by characterizing critical evidentiary discrepancies as a mere slip of the tongue.

Court's Observations

The court heavily scrutinized the timeline of the DNA extraction and testing, noting fundamental impossibilities in the prosecution's narrative. The bench pointed out that the final DNA report was issued on October 9, 2017, yet the medical officer categorically deposed that he collected the appellant's blood sample on January 31, 2018—months after the report was finalized. Furthermore, the Assistant Director of the Forensic Lab admitted she did not know when the sample was collected and lacked a specialized degree in DNA testing. The court concluded that it was biologically and chronologically impossible to rely on the forensic report when the foundational timeline was shattered.

"If so, the DNA report dated 09.10.2017 could not have been relied upon to convict the appellant in the absence of any other corroborative material which established the fact that blood sample of appellant had been obtained prior to 09.10.2017."

Delving into the doctrinal value of forensic science, the court relied on its previous judgments in Prakash Nishad v. State of Maharashtra, Pattu Rajan v. State of T.N., and Manoj v. State of M.P. to explain the probative limits of DNA evidence. The bench emphasized that while technological advancements have increased the reliability of DNA profiling, such evidence is still not infallible. Its weight depends heavily on the surrounding facts, corroborative materials, and the strict maintenance of an uncompromised chain of custody. Since the foundational integrity of the blood collection process was compromised in this case, the forensic report lost its evidentiary anchor.

"In the present case, even though, the DNA evidence by way of a report was present, its reliability is not infallible, especially not so in light of the fact that the uncompromised nature of such evidence cannot be established."

"Only when the judgement of acquittal suffers from patent perversity or is based on misreading/omission to consider material evidence on record and/or where no two reasonable views are possible... the interference by the appellate court is warranted."

Addressing the appellate court's jurisdiction to reverse an acquittal, the bench invoked the parameters laid down in Bhupatbhai Bachubhai Chavda v. State of Gujarat. The Supreme Court highlighted that a High Court should only interfere with an acquittal if the trial court's judgment suffers from patent perversity or misreading of evidence. The bench sharply criticized the High Court for brushing aside the glaring date discrepancy regarding the blood sample as a minor contradiction or a mere slip of the tongue, observing that the trial court had rightly evaluated the evidence and extended the benefit of doubt to the accused.

"Since the concerned DNA report which forms the core basis to derive nexus of appellant to conviction, itself is doubtful, no reasonable view could have been formed which is only consistent with the guilt of the accused."

Ultimately, the Supreme Court allowed the appeals and set aside the High Court's judgment of conviction, ruling that the prosecution had failed to establish the appellant's guilt beyond a reasonable doubt. The 2019 judgment of acquittal passed by the Sessions Court was fully restored, and the appellant was directed to be released forthwith, with his bail bonds discharged.

Date of Decision: 12 March 2026