Gauhati High Court holds negative DNA findings not conclusive; conviction can rest on reliable testimony and medical evidence
The Gauhati High Court has held that a negative DNA finding does not by itself negate allegations of sexual assault, observing that the prosecution can establish the offence through credible victim testimony supported by medical evidence.
Justice Pranjal Das, while agreeing with the findings of the trial court, observed that when the testimony of the prosecutrix is reliable and corroborated by her statement and medical evidence, the absence of DNA confirmation does not affect the prosecution’s case.
The case arose from a criminal prosecution involving allegations of sexual assault, where the trial court had returned a finding of guilt based on oral and medical evidence.
During the proceedings, a DNA report was produced which did not conclusively support the prosecution’s case, leading the accused to argue that the lack of scientific corroboration undermined the conviction.
The accused contended that:
- The negative DNA findings created reasonable doubt
- The prosecution failed to conclusively establish the offence
- Scientific evidence should prevail over oral testimony
The defence argued that in the absence of DNA linkage, the prosecution case could not be sustained.
Rejecting the contention, the High Court reiterated settled principles of criminal law:
- DNA evidence is not conclusive in sexual offence cases
- Conviction can be based on credible and trustworthy testimony of the victim
- Medical evidence and surrounding circumstances can sufficiently corroborate the prosecution case
The Court emphasised that a negative DNA finding is only one piece of evidence and cannot override otherwise reliable material on record.
The Court reaffirmed that:
- The testimony of the prosecutrix, if found reliable, can form the sole basis of conviction
- Scientific evidence is corroborative in nature, not determinative
- Courts must assess the totality of evidence, rather than rely on isolated factors
This approach aligns with established jurisprudence that minor inconsistencies or absence of scientific proof do not automatically discredit a prosecution case.
The High Court upheld the prosecution case, affirming that the offence of sexual assault stood proved on the basis of testimony and medical evidence, notwithstanding the negative DNA report.
