Allahabad High Court Grants Bail in Rape-Murder Case, Raises Alarm Over Uttar Pradesh Forensic Lab Shortcomings

By Rajesh Pandey

In a significant observation while granting bail to an accused in a rape and murder case, the Allahabad High Court said it was doing so with “deep anguish and considerable concern” because crucial scientific evidence could not be properly established.

The court used the occasion to highlight serious deficiencies in the forensic infrastructure of Uttar Pradesh.

Justice Arun Kumar Singh Deshwal, while allowing bail to the accused, Manoj, remarked that outdated equipment and inadequate facilities in the state’s Forensic Science Laboratories (FSLs) were largely responsible for the failure to generate a complete DNA profile.

He observed that the responsibility for addressing these shortcomings ultimately lies with the state government.

“The inability to obtain a complete DNA profile stems from obsolete machinery and insufficient forensic infrastructure.

No one can truly be blamed except the government, which must prioritise strengthening these essential scientific facilities,” the court noted.

Expressing hope for urgent reforms, the bench said it expects the state administration to equip forensic laboratories with modern technology and adequate manpower.

The court also directed that a copy of its order be forwarded to Uttar Pradesh Chief Minister Yogi Adityanath for consideration.

According to the prosecution, the victim was allegedly sexually assaulted and later murdered.

The initial First Information Report (FIR) was filed against unidentified persons, but Manoj was subsequently named as an accused based on the statement of an alleged eyewitness recorded at a later stage of the investigation.

The defence challenged the prosecution’s claims, arguing that the alleged recovery of the victim’s wristwatch from an open area at the accused’s instance could not be treated as definitive proof of involvement in the crime.

The defence further pointed out that the eyewitness statement was recorded after a considerable delay, raising doubts about its reliability and weakening the prosecution’s case.

Counsel for the accused also highlighted that the forensic report did not establish any DNA match between the accused and biological samples collected from the deceased.

According to the defence, this significantly undermined the allegations and supported the contention that the accused had been wrongly implicated.

Based on these arguments, the defence urged the court to grant bail, maintaining that there was insufficient evidence to justify continued incarceration.

Although the complainant’s counsel and the state’s legal representatives opposed the bail plea, they were unable to effectively contest the factual issues raised regarding the forensic findings and the investigation.

While ultimately granting relief to the accused, the court observed that it had little choice because the forensic report failed to conclusively establish whether the DNA found in the victim’s samples belonged to the applicant. The court noted that this was due to the inability of the laboratory to generate a complete DNA profile.

Justice Deshwal described the situation as one of the most serious flaws in both the investigation process and the forensic system. He observed that similar problems are increasingly appearing in criminal cases across the state.

Referring to several cases previously heard by the court, the judge said that in many rape-and-murder investigations, vaginal swabs and DNA samples of accused persons had been sent for examination.

However, forensic reports frequently concluded that the source of DNA could not be determined because the genetic profiles generated were incomplete.

The court also cited its recent observations in the case of Mevalal Prajapati vs State of Uttar Pradesh (2026), where the Director of the Uttar Pradesh FSL reportedly informed the court that many forensic laboratories were struggling with staff shortages and a lack of advanced DNA-analysis equipment.

Justice Deshwal noted that the present matter involved a particularly grave allegation, where a woman was allegedly raped and subsequently killed.

Yet, despite the seriousness of the accusations, the absence of reliable scientific evidence left the court with no option but to grant bail.

“Although the allegations relate to a heinous offence, the lack of proper forensic evidence compels this court to release the applicant on bail, albeit with a heavy heart and considerable pain,” the court observed.

In its order dated May 21, the High Court concluded by expressing the expectation that the Uttar Pradesh government would take immediate steps to modernise forensic laboratories, provide cutting-edge equipment and fill vacant positions to strengthen criminal investigations in the future.