Science For Everyone: DNA V / Review of Death Penalty XXVIII


Dharam Deo Yadav v. State of U.P., (2015) 5 SCC 509 discussed reliability of DNA evidence. Pantangi Balarama Venkata Ganesh, (2009) 14 SCC 607; Santosh Kumar Singh, (2010) 9 SCC 747; John David, (2011) 5 SCC 509; Krishan Kumar Malik, (2011) 7 SCC 130; Surendra Kohli, (2011) 4 SCC 80; Sandeep, (2012) 6 SCC 107; Rajkumar, (2014) 5 SCC 353; Mukesh, (2014) 4 SCC 69 have dealt with increasing importance of DNA evidence. Pattu Rajan v. State of Tamil Nadu, (2019) 4 SCC 771 considered value and weight to be attached to a DNA report.

DNA report in present case cannot have a clinching or high degree of probative value.


To justify imposition of Capital Punishment, High Court was of view, acts of murder committed were so gruesome, merciless and brutal, aggravating circumstances far outweighed mitigating circumstances.

There can be no doubt, crime committed was brutal and grotesque. State was directed to file: Psychological Evaluation Report, Probation Officer’s Report and Prison Report including material on conduct and work done.  

Swayed by brutality of crime, High Court affirmed imposition of Death Penalty. There is in fact, a probability of reform. Life Imprisonment: Minimum 25 Years.

Hon’ble Justice S. Ravindra Bhat, Manoj & Ors. v. State of Madhya Pradesh, [Criminal Appeal Nos. 248-250 of 2015].


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