1

NAME OF THE COLLEGE: GLS LAW COLLEGE

BATCH: 2015-2020

NAME OF THE SUBJECT: POLYGRAPH AND NARCO TEST IN

INEVIDENCE LAW IN INDIA

TITLE OF THE PROJECT: Modern Scientific Techniques in

Forensic Science: It’s Significance
On Criminal Justice System

SUBMITTED TO : Ms. Foram Pandya

(Assistant
Professor, GLS Law
College)

SUBMITTED BY : YASH THAKKAR ,

ROLL NO. : 73

ACADEMIC YEAR : 2019-2020

TABLE OF CONTENTS:

Sr. no. Titles Page no.

1. Abstract 4

2. Hypothesis 5

3. Literature Review & Research Methodology 6

4. Introduction 7-15

4. Conclusion & References 16

MODERN SCIENTIFIC TECHNIQUES IN FORENSIC SCIENCE:
IT’S SIGNIFICANCE IN CRIMINAL JUSTICE SYSTEM

1. Abstract:

Forensics is the scientific discipline concerned with proving criminal offenses. It proves
in a way that an investigator collects, documents and analyses all facts related to the
crime. The most important task of the investigator is to collect the largest possible number
of pieces of evidences that connect to a criminal offense. They are mostly found at the site
of criminal events, and in technical terms, is called physical evidence. Based on these sets
hypotheses that connect one fact with another, and then we come to the theory that
explains the nature of the criminal acts. Forensic proof of crimes are very complex
transaction with the ultimate goal to prove or disprove the offense and find the
perpetrators. On the other hand, every individual is granted with some basic fundamental
rights enshrined in the constitution, and where the court stands and balances the same
with reference to regarding the admissibility of same.

Key Words: Forensic Science-Criminal Profiling-Physical Evidence-Criminal Justice

System-Medicine-Examination of Witnesses-Accused
2. Hypothesis:
Are these Modern Scientific Techniques in Forensic Science are reliable to achieve the
goal and objective of the Criminal Justice System, which is to provide speedy justice to
the victim and maintaining a balance between the fundamental rights enshrined in the
constitution. And whether these techniques violate such rights and are they acting as a
hindrance in providing justice.
3. Literature Review:

The society owes a commitment to the people that the potential and strength of the states
is not abused in the dispensation of justice and that the concept of human right is upheld
and nurtured all the time. To preserve the common rights, the basic tool human being has
devised is the police set-up. Death, rape and torture in police custody are common,
Factual reports have embarrassed several State Government and their police personal
which employed third degree methods in the interrogation of the suspected people
detained to disclose the truth or their plans. The third degree method will never put an end
to the crime as the criminal get hardened and wish to take revenge and cause
embarrassment to the establishment. Interrogation of the suspected criminals using third
degree methods often results into loss of fear and respect for the authority of the State.
The law enforcement agency in the country will have to react effectively by scientific
interrogation of the victim and the accused and try to get as much evidence as possible to
establish the charge. This is to be done by resorting to forensic polygraph technique.
Forensic Polygraphy is the technique to check deception of truth by a subject juxtaposed
with the veracity of his statement.

4. Research Methodology:

It is “Doctrinal Research”, focusing on the data’s already collected, the study will be a
“Developmental Study”, regarding the growth of the Modern Scientific Techniques in
Forensic Science and its Admissibility in Court. And it will be “Secondary Data
Collection”, from the judgements of the Hon’ble Court of India.
5. Introduction:

The nature of law is dynamic and not static, so the law also changes when society change.
The law is the cement of the society and the judiciary has the responsibility of interpreting
the law for the greater good. The application of science and technology to the detection
and investigation of crime and investigation of crime and administration of justice is not
new to India. In spite of this many people are not aware from the fact that science plays
an important role in the identification of crime and criminals. The area of its operation is
quite wide and comprehensive .In its application to the administration of law, it is known
as “Forensic Science”. Earlier it was forensic medicine, which first came to the field of
the science in as such as medical man’s opinion has been sought throughout the ages to
find out the cause of death of a person both in case of natural or of unnatural death.

5.1 Forensic Science: Meaning:

Forensic science is simply defined as the application of science to the law or legal
matters. In today’s CSI and Forensic Files world, this area of science is much more
widely known to the general public. However, it is also misunderstood due to pseudo-
real-life crime drama. When the actual real-life judicial system needs science to
resolve a question, the person who is called upon to bring science into the courtroom
is often a forensic scientist. The law and science are strange bedfellows. Science is an
empirical method of learning, anchored to the principles of observation and discovery
as to how the natural world works. Scientific knowledge increases human
understanding by developing experiments that provide the scientist with an objective
answer to the question presented. Through the scientific method of study, a scientist
systematically observes physical evidence and methodically records the data that
support or not support the scientific process. The law, on the other hand, starts out
with at least two competing parties with markedly different views who use the
courthouse as a battleground to argue factual issues within the context of
constitutional, statutory, and decisional law.
Forensics involves the application of knowledge and technology from different
scientific disciplines in jurisprudence. These are, for example, biology, pharmacy,
chemistry, medicine, etc., and each of them applies in the present, increasingly
complex legal proceedings in which the required knowledge and skills of experts
from these areas to prove offenses. For the purposes of this article, we will hold on the
biology or forensic biology, which is the most important branch of the DNA analysis.
Forensic biology deals with serological and DNA analysis of physiological fluids in
the human body in order to identify and individuate people, animals and
microorganisms. It should be added that the application of certain procedures dates
back to the earliest history of medicine, but it is still used today. These are, for
example, methods in which the examination of the body (depending on its conditions)
can determine gender, race, age of the person, analysis of the tooth, or the
determination of blood group testing, and the presence of specific antibodies in the
body.
The area of forensic science is changing very fast by the new technologies and
methods. Nowadays use of DNA tests, high-performance liquid chromatography,
mass spectrometry, 3-D computer imaging, and other sophisticated technologies are
used by
scientists to reconstruct the offence and the mishap. The modern forensic science can
differentiate trace element and organic materials down to the level of merely a few
hundred molecules. Given the sensitivity of the instruments, forensic scientists require
adhering to rigorous procedures and standards to make certain that their outcome are
valid and dependable and can withstand inspection in the courts of law and the
community. The recent forensics can facilitate to expose concealed offense, convict
the guilty and vindicate the innocent if it exercises with care. At present, multifaceted
science plays an important role in recognizing sufferers of offence, mishap, tragedy,
and combat which provides assurance, conclusion, and poignant support for
bereaved’s survivors.
The characteristic of our criminal justice system is the attentive look for reality. Our
technique of inquiry, rules of criminal procedure and appellate procedure are
fundamentally designed to make certain that the responsible are punished whereas the
innocent are protected. However, while ours is a system to be appreciated, it is not an
ideal system, and those charged with the administration of justice have a responsibility
to seek its continued improvement. Science and law, two distinctive professions have
more and more become comingled, for making sure a fair procedure and to observe
that justice is done.
Nowadays the legal system has to pact with new scientific proof on many instances,
which has posed profound challenges for the law. At basic level, many of these
challenges occur from fundamental differences between the scientific and legal
procedure. The quandaries are self-evident. On one hand, scientific proof holds out the
alluring chance of tremendously precise fact-finding and a decrease in the ambiguity
that frequently accompanies legal decision-making. Simultaneously, scientific
methodologies often contain risks of ambiguity which the legal system is unwilling to
bear. Additionally, at every instance, scientific proof examination of the capability of
judges and lawyers, all of whom may lack the scientific proficiency to understand the
proof and evaluate it in an informal manner. Lawyers must make efforts to understand
the difficulty of scientific investigation and expressions if they are to fully
comprehend testing procedures and consequences, and their impact in the legal field.
One modern development in the scientific community that has had a substantial and
almost mesmerizing impact on the legal profession is the development of lie detection
and Narco-Analysis in criminal cases. Usually, forensic science is the application of
science to find out the answer which required by the legal system. These answers may
relate to civil or criminal actions. At present it is also very much related with scientific
field. Forensic science which is used to answer criminal question provides answer
though the comparison with, controlled substance, biological proof a firearms that
may be found at the site of the offence.
In Addition to this, with the help of trace proof and impression proof like fingerprints,
tire tracks and footwear impressions and all other proof that may be found in a scene
of offence, the required answers for criminal examination can be found with the help
forensic science. The proof found on the site of the offence is generally produced in
the crime laboratory and it is this branch of forensic science that is used in the media
and shown in fiction stories and programs.
5.2 Modern Techniques in Forensic Science:

The Forensic Science is one of advanced techniques used in recognizing crimes and
criminal’s .It is very challenging, charming, dynamic, and exiting science. The
application of advance science which embraces all institution like Chemistry,
Ballistic, photography, Physics, Brain Fingerprinting, Toxicology, Narcotics, DNA
Profiling, Narco-Analysis, Biology, etc. in criminal law is commonly understood as
the forensic science in the field of law. The main functions of forensic science are the
detection, collection, packing, transportation and analysis of physical evidence and
biological material etc. The below para’s discuss the different types of the techniques
and its admissibility in the court.

A) Narco-Analysis Test:

Narcosis is a state of stupor induced by drugs. The use of narcotics as a therapeutic

aid in psychiatric is believed to have a history dating back to the use of opium for
mental disorder by the early Egyptians.15Earlier in the 20th Century the medical
doctors started to use scopolamine together with morphine and chloroform to induce a
state called ‘twilight sleep’ during childbirth as these have the effect of sedative.
However, scopolamine was also known to create a state of disorientation, confusion
and amnesia during the period of intoxication.

Narco-Analysis is a process whereby a subject is put to sleep or put into semi

somnolent state by means of chemical injection and was then interrogated while in
this dream like state, or the process of injecting a ‘truth serum ‘drug into a patient
/suspect to induce semi consciousness, and then interrogating the patient /suspect
.This process has been utilized to enhance the memory of a witness.

Narco-analysis has witnessed a mixed response from the judiciary, ranging from
outright disapproval to reluctant and latent encouragement.

For instance, in M.C Sekharan v. State of Kerala, the Kerala High Court took an
acerbic approach towards the process, declaring unequivocally that it is against the
fundamental right of an accused. However, during 2004-2009, various High Courts
have been relaxed in commenting on the civil liberties aspect of Narco-Analysis while
some have decreed it a permissible practice, in conformity with Part III of the
Constitution. Thus the judicial tryst with Narco-Analysis in the previous decade had
been one of the ambivalence or approval. The judiciary possibly viewed this practice
to be a solution to compare the threat to internal security faced by India during the
aforementioned period.

A Narco-analysis test report has some validity but is not totally admissible in court,
which considers the circumstances under which it was obtained and assessed its
admissibility. Results of such tests can be used to get admissible evidence, can be
collaborated with other evidence or to support other evidence. But if the result of this
test is not admitted in a court, it cannot be used to support any other evidence
obtained the course of routine investigation.
In India, Narco-analysis was first used in 2002 in the Godhra carnage case. It was
also in the news after the famous Arun Bhatt kidnapping case in Gujarat wherein the
accused had appeared before NHRC and the Supreme Court of India against
undergoing the Narco-analysis. It was again in the news in the Telgi stamp paper
scam when Abdul Karim Telgi was taken to the test in December 2003. Though in the
case of Telgi, immense amount of information was yielded, but doubts were raised
about its value as evidence. Narco-analysis was in the limelight in the context of
infamous Nithari village (Noida) serial killings. The two main accused in the Nithari
serial killings Mohinder Singh Pandher and Surendra Kohli have undergone Narco-
analysis tests in Gandhinagar in Gujarat.

In the case of Rojo George vs. Deputy Superintendent of Police, while allowing the
Narco analysis test Court is of the opinion that in present day the criminals started to
use very sophisticated and modern techniques for committing the crime. So the
conventional method of investigation and questioning to the criminals will not be
successful for solution and there is need to utilize some new techniques such as
polygraph, brain mapping and Narco analysis

B) Polygraph or Lie Detector Test:

The term ‘Polygraph literally means ‘many writings’ therefore the name refers to a
process in which selected psychological activities are recorded. The first attempt in
this direction was made to expand a scientific instrument to identify reality or fraud as
early as 1895 by Lombroso. It was basically designed to record blood pressure and
changes in pulse rate. Later Larsen and Keeler designed an instrument which was
further developed by John Reid in 1947.The very fundamental principle underlying
Polygraph is that when a person lie he becomes nervous, which in turn causes mental
excitation. To conceal the excitement which the person attempts, adrenal glands are
stimulated to secrete Adrenalin, which on entering the blood stream, sets up the blood
pressure and rate of pulse and respiration. All these psychological changes when
recorded are collectively called Polygram, which is analysed and evaluate to find out
whether during the lie detection test, the subject experienced emotional stress with
any of the questions asked.

The main legal provisions which governs the expert evidence (Lie Detector test), are
in Indian Constitution, Code of Criminal Procedure, Indian Evidence Act. In Indian
Constitution there are various provisions which are related with the protection of the
accused person .In the Constitution of India, the provision of life, liberty and freedom
has been given under Article 20 and 21.

The Constitutional embodiment invigorating the ban on self-incriminating has been

enshrined in Article 20(3) of the Constitution of India. Article 20(3) provides the
protection to the accused person in respect of the conviction.

In case of Sidhartha Vashist v. State, it was held by the court that the
interrelationship between the ‘right against self-incrimination and the ‘right to fair
trial‘ has been recognised in most jurisdictions as well as international human rights
instruments. The guarantee of ‘presumption of innocence’ bears a direct link to ‘right
against self- incrimination’ since compelling the accused person to give evidence
would place the burden of proving innocence on the accused instead of requiring
the prosecution to
prove guilt .Thus the right to refusal to answer such questions that may incriminate a
person is a procedural safeguard which has gradually evolved in common law and
bears a close relation to right to fair trial.

In the case of State of Bombay v. Kathi kalu Oghad, the Hon’ble Supreme Court
observed that conducting the Polygraph by the police without the consent of accused
person is clear violation of article 20(3) of the Indian Constitution. The right against
forced self-incrimination is enshrined in Article 20(3) of the Indian Constitution as
well as in the Criminal Procedure Code. In this case the Bombay High Court had to
decide whether compelling the accused person to undergo this test would violate his
right to silence and compel him to provide evidence against himself. In this case
Palshikar j. held that the right against self-incrimination applies only to court
proceeding and not to police interrogation.

In Ramchandra Reddy v. State of Maharashtra, it was held by the court that “The
Lie Detector test is an examination which is conducted by various probe attached to
the body of the person who is interrogated by the Expert. In this test the heart rate, the
skin conductance is measured. The underlying theory of this test is that when people
lie they become nervous. The heart beat increases, blood pressure goes up, breathing
rhythm changes, perspiration increases, etc. A baseline for this physiological
characteristic is established by asking the subject questions whose answers
investigators know. Deviation from the baseline for truthfulness is taken as a sign of
lie. Consequently, there is no direct incursion of the body. In this test the Polygraph is
taken which gives this reaction and an expert would then explain these reactions in the
Court which would be his reading of the Polygraph from which would flow this
conclusion which are to be admitted or not admitted by a judge on appreciation of the
statement and the objections raised thereto. In this case, the witness may answer or
may not answer the questions. The response of his answers to questions as recorded
on the Polygraph analysis of which is required to be tendered as evidence if and when
the occasion arises.”

C) Brain Mapping or P300 Test:

Dr. Lawrence A. Farwell, Director and Chief scientist of ‘Brain Wave Science’
IWOA developed this test and patented in the year 1995. He was a well-known
neurologist. This technique is also known as ‘Brain wave finger printing’. In this
technique, the suspect is first interviewed and interrogated to find out whether he is
concealing any important information. Then sensors are attached to the head and the
person is made to sit in front of a computer monitor. He is then shown and made to
hear certain images and voice. The sensor attached to head monitors and records
electrical activity and P300 waves in the brain, which is produced only if the subject
has link with stimulus. The subject is not asked any question. To put it simply, it
simply means that brain finger printing matches the information stored in the brain
with that of the related crime and crime scene. In case of an innocent person no such
P300 waves would get registered during the test.

In India, the first Forensic laboratory which used this technique is Forensic laboratory
of Bangalore. Proof produced by Expert in a criminal trial would be just a fraction of
the totality of the evidence on the appreciation of which the judge or jury takes
judgment. The Court takes into account all the other proofs at hand along with the
view of the scientific expert, which is just one piece of evidence needed to be taken
into
consideration and appreciated for its evidentiary value. Even after the validity of the
technique of brain fingerprinting satisfies Daubert's criteria, its application as a
forensic tool in individual cases will depend upon the genuineness of the investigation
and other factors.

The test would not be applicable in a case in which two suspects in an investigation
were both present at a crime, but one was a witness and the other a perpetrator. The
method can only detect information from their memory that would place both at the
scene of the crime and it cannot decide what their roles were, thereby creating a
distinct possibility of an innocent eye-witness becoming a suspect of the crime and
giving a dubious opportunity to the real culprit to create a situation of doubt.

The Supreme Court in the case of Selvi v. State of Karnataka, held the use of Narco-
analysis, brain-mapping and polygraph tests on accused, suspects and witnesses
without their consent as unconstitutional and violation of the ‘right to privacy’. A
three-Judge Bench of Chief Justice K.G. Balakrishnan and Justices R.V. Raveendran
and J.M. Panchal, in a 251-page judgment, said:

“We hold that no individual should be forcibly subjected to any of the

techniques in question, whether in the context of investigation in criminal
cases or otherwise. Doing so would amount to an unwarranted intrusion into
personal liberty.”

The judges said:

“The compulsory administration of the impugned techniques violates the right

against self-incrimination. The test results cannot be admitted in evidence if
they have been obtained through the use of compulsion. Article 20 (3) of the
Constitution [No person accused of any offence shall be compelled to be a
witness against himself] protects an individual's choice between speaking and
remaining silent, irrespective of whether the subsequent testimony proves to
be inculpatory or exculpatory.”

The Bench further said:

“Article 20 (3) aims to prevent the forcible conveyance of personal knowledge

that is relevant to the facts in issue. The results obtained from each of the
impugned tests bear a testimonial character and they cannot be categorised as
material evidence.”

The CJI said:

“It is our considered opinion that subjecting a person to the impugned

techniques in an involuntary manner violates the prescribed boundaries of
privacy.”

The Bench held that if these techniques were used compulsorily if would violate
Article 20 (3). The Bench made it clear that even when the subject had given consent
to undergo any of these tests, the test results by themselves could not be admitted as
evidence because “the subject does not exercise conscious control over the responses
during the administration of the test. However, any information or material that is
subsequently discovered with the help of voluntary administered test results can be
admitted, in accordance with Section 27 of the Evidence Act.”

D) DNA Profiling:

One of the latest growing and most reliable modes of investigation in forensic science
is DNA profiling. DNA is the abbreviation of the term, “Deoxyribose Nucleic Acid”.
It is an organic substance which is found in every living cell and which gives an
individual genetic blue print. DNA can be obtained from a wide variety of sources
like, blood, semen, bone, saliva etc.

DNA tests are highly effective because each individual’s DNA is unique except the
twins. The probability of DNA being same is one in three billion. And it is credible
because it cannot be tampered with DNA test can be used in various cases in order to
such as to establish the parentage of a child, identify mutilated dead bodies etc.

Under the Indian Evidence Act, 1872, is against the legitimization of a child and the
public policy is that no child should suffer due to lapses on the part of their parents. It
is well established that when certain fact is considered as conclusive proof of another
fact, the judiciary generally disables the party in disrupting such proof. The only
exception occurs when the party is able to show that there was no access to the other
party when the conception could have taken place. Whenever paternity is contested,
the burden of proof is on the party pleading negative.

In the famous case of Gautam Kundu v West Bengal, the apex court has laid down
certain note-worthy guidelines regarding DNA test and their admissibility in the
parentage case:

1. The courts in India cannot order blood test as a matter of course.

2. Whenever application is made for such prayer in order to have roving
enquiry, the prayer of blood test cannot be entertained.
3. There must be strong prima facie case in which the husband must have
established non-access in order to dispel the presumption arising under
section 112 of Indian Evidence Act, 1872.
4. The court should carefully examine as to what would be the
consequence of ordering the blood test.
5. No one can be compelled to give blood sample for analysis.

In case of Kanti Devi v Poshi Ram, the Supreme Court held that even a DNA test
that indicated that the person is not the father of the child would not be enough to
rebut the conclusiveness of marriage as proof of legitimacy of child.

Section 125 of the Code of Criminal Procedure code, 1973 lamented that the
natural and fundamental duty of a man is to maintain his legally wedded wife,
children and parents so long as they are unable to maintain themselves.

The famous 9/11 in U.S.A attack left none in any doubt about the great capacity and
capability of the criminals of that era found their modus operandi used in the
commission of such crime. Hence there is an urgent need for modification of the
crime investigation process and tools were felt.

The development of DNA is a welcome step and it has become more and more
reliable instrument. Unlike civil paternity case, Indian courts have accepted the role of
DNA in criminal paternity case. Likewise in Rajiv Gandhi Murder Case, the DNA
samples of alleged assassin Dhanu were compared with her relatives, which gave
conclusive proof about her being involved in the gruesome attack.

Similarly in the famous Tandoor murder case, the DNA samples of the victim Naina
Sahni were compared with that of her parents to establish her identity.

E) Fingerprints:

Though fingerprints have been used by the crime investigators for more than a
century, they persist one of the most requisite after pieces of evidence. All human
beings are born with a characteristic set of ridges on the fingertips. The ridges, which
are rich in sweat pores, form a pattern that remains fixed for life. Even if the skin is
removed, the same pattern will be evident when the skin regenerates. Some of the
typical patterns found in fingerprints are arches, loops, and whorls. Oils from sweat
glands collect on these ridges.

When we touch something, a small amount of the oils and other materials on the
fingers are left on the surface of the object we touched. The pattern left by these
substances, which collect along the ridges on our fingers, make up the fingerprints that
police look for at the scene of a crime. It is the unique pattern made by these ridges
that motivate the police to record people's fingerprints. To take someone's
fingerprints, the ends of the person's fingers are first covered with ink.

The fingers are then rolled; one at a time, on a smooth surface to make an imprint that
can be preserved. Fingerprints collected as evidence can be compared with
fingerprints on file or taken from a suspect. In Voelker v. Tyndall, the court held that
statutes establishing state and police identification services and permitting the
fingerprinting and photographing of persons arrested on a criminal charge are a
proper exercise of the police power and do not abridge the privileges or immunities of
citizens or deprive them of due process of law.

F) Brain Fingerprinting:

Brain Fingerprinting is yet another latest innovative computer technology to recognize

the criminal accurately and scientifically by measuring brain-wave responses to
crime- relevant words or pictures presented on a computer screen. Brain
Fingerprinting has proven 100% accurate in over 120 tests, including tests on FBI
agents, tests for a US intelligence agency and for the US Navy, and tests on real-life
situations including misdemeanour crimes. The same system is also adopted\ in most
European as well as developed countries.

Brain fingerprinting is based on the finding that the brain generates a unique brain
wave pattern when a person encounters a well-known use of functional magnetic
resonance
imaging in lie detection derives from the studies suggesting that persons asked to lie
show different patterns of brain activity than they do when being truthful. Issues
related to the use of such evidence in the courts would be discussed later.

When a crime is committed, a record is stored in the brain of the doer. Brain
Fingerprinting provides a means to objectively and scientifically connect evidence
from the crime scene with evidence stored in the brain of the perpetrator. Brain
Fingerprinting measures electrical brain activity in response to crime-relevant words
or pictures presented on a computer screen, and reveals a brain MERMER (memory
and encoding related multifaceted electroencephalographic response) when, and only
when, the evidence stored in the brain matches the evidence from the crime scene.

Thus, the guilty can be identified and the innocent can be cleared in an accurate,
scientific, objective, non-invasive, non-stressful, and non-testimonial manner. But this
technique, is not used in India.
6. Conclusion:

Presently forensic science plays vital role in crime and criminal detection. There are
various techniques relating with the important role in detection of crime. DNA Profiling,
Brain fingerprinting, Brain Mapping, Narco-Analysis, Polygraph test, Forensic
photography etc. are the important techniques in the field of forensic science which play
pivotal role in criminal investigation to find out the crime and criminals:

1. The present criminal justice system is possessed with individual liberty and freedom
and in this context a safe passage is unavoidable to criminals due to weakness in the
criminal justice system leading to dilution of evidence.
2. Since the validity of the test and admissibility of Narco-analysis has been quashed by
the Apex court taking into consideration the circumstances under which it is obtained,
the possibility of justice has weakened.
3. It is submitted that if the provision of administering Narco-analysis test is made
compulsory for the accused /witness in grave offences, it may pave the way for
improving the quality of criminal justice through strengthening of evidence system.
This move will bring about a qualitative change in the criminal justice.
4. But a big question mark on the validity of the Narco-analysis test when the demanding
for justice by accused person. The Narco test can be said to be unethical, when
everything in investigating fails. Every person is innocent until proven guilty, and the
same aspect should be maintained while carrying out any criminal investigation.
5. Due to the sophisticated modes and changing conditions of committing crimes by the
shrewd criminals there is a dire need to apply the new scientific technique like
Polygraph test, Brain Fingerprinting etc.

7. References:

- https://www.ncbi.nlm.nih.gov/pmc/articles/PMC3171915/
- file:///C:/20Singh/AppData/Local/Packages/Microsoft.MicrosoftEdge_8wekyb3d8bb
we/TempState/Downloads/231977%20(1).pdf
- https://shodhganga.inflibnet.ac.in/bitstream/10603/70232/10/chapter6.pdf