Irfan @ Bhayu Mevati v. The State of Madhya Pradesh

Criminal Appeal · 2025 INSC 150Decided 16 Jan 2025
Crl.A. Nos.-001667-001668 of 2021 (heard with Crl.A. No. 220 of 2022, filed by co-accused Asif Mevati)
Justice Vikram Nath · Justice Sanjay Karol · Justice Sandeep Mehta

Background

In 2018, a third-grade schoolgirl went missing after school in Madhya Pradesh and was later found badly injured, having been sexually assaulted and subjected to severe physical violence requiring surgery. The appellants were identified through CCTV footage and an identification parade, charged, and convicted by the trial court, which sentenced them to death; the Madhya Pradesh High Court confirmed the death sentence. The defence argued the crucial DNA evidence used to convict them was flawed and was never actually proved in court by the scientists who prepared it.

Decision Breakdown

The Supreme Court agreed that the DNA report, the central pillar of the prosecution's case, had only been formally exhibited through a police officer's testimony, while none of the three scientific experts who conducted the DNA profiling were ever examined or made available for cross-examination. Relying on its own precedents (including Anokhilal and Rahul v. State), the Court held that merely tendering a scientific report through a non-expert witness does not prove its contents, and that in a capital case especially, the accused must get a genuine, meaningful opportunity to test forensic evidence. Because the entire trial had also been completed with unusual haste (in under two months), the Court found the accused had been denied a fair trial.

Lesson Learnt

In serious criminal cases, and especially where the death penalty is on the line, forensic evidence like a DNA report cannot simply be stamped as proved through a police witness; the scientists who actually did the testing must be produced and made available for cross-examination, or the conviction can be undone even years later.

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