Legality of Medical Evidence in India

The article 'Legality of Medical Evidence in India' emphasizes the admissibility of medical evidence in our Indian Criminal Justice System. The article aims to make the readers understand the above-mentioned topic with the help of various legislative provisions along with remarkable judgments.

Introduction

In our Indian criminal justice system, whenever a case is filed before the court of law, both parties come up with their respective contentions and present their case before the court, be it to get someone punished or acquitted. To support the contentions, evidence is produced before the court. Evidence plays a vital role in a case’s determination, and there exists a person who prepares a report related to such evidence. Such a person is known as an expert, and he or she does so by gathering different required information about the case.

There are different kinds of evidence, and one of those is medical evidence. It is upon the discretion of the court to decide the evidentiary value of such evidence produced before it. Whenever a crime is committed and reported, medical experts play a crucial role from its initial phase till the post-mortem report. They make reports from the initial stage, i.e., the crime spot’s investigation and do so till the end, and such report is submitted to the court.

In our criminal justice system, expert opinion plays a significant role in deciding a case; hence, medical experts play a good role.

Meaning of Medical Evidence

The evidence law of India classifies evidence to be oral, documentary and circumstantial. Medical evidence is the opinions of medical experts which is presented by the parties of the case, in order to support the relevant facts. Medical evidence can be understood as testimony by witnesses who are experts in medicine as well as medical records & standard medical texts presented as proof at trial. If we focus on its definition, medical evidence can be defined as materials that bring before the court, proper and relevant facts, with the help of which the court considers the facts to be true or false.

For more clear understanding, we can take the example of a murder case. In such cases, medical pieces of evidence have a role to provide post-mortem reports, the consequence of the wound, cause of death, time of death, age determination and in many more things pertinent to support the case. These things can be proved in the court conclusively, with the aid of medical evidence.

Nonetheless, medical evidence is corroborative in nature and also, doesn’t always have an overriding effect on the testimony of eyewitnesses, till the testimony is proved to be of false nature. It’s upon the court to accept or reject it there is a conflict between both. In cases related to offences against the human body, medical evidence plays a decisive role. The testimony of eyewitnesses cannot be rejected on the basis of medical evidence, until and unless the medical evidence rules out any possibility of injury in the way claimed by the eyewitness completely.

Who can be a Medical Expert?

Medical evidence is presented by the medical experts, and these are the persons who are specialised in such field of knowledge and have the expertise to present opinions before the court, related to that case, as well as draw conclusions about such case. They are deemed to be impartial and work unbiasedly. They are the persons who work in the field related to medicine, lawfully. They present the medical data before the court of law with strong justification, which is done with the standard of the case, professionally. They are expected to work with the proper standard of the case, as the court would rely on such findings as presented by them, to draw conclusions from relevant facts. If such experts present incorrect findings or work without due care, then the court won’t be able to draw correct conclusions, leading the case the wrong way.

Provisions related to Medical Evidence

Section 45 – Indian Evidence Act

The general rule of evidence law is that no third person can present evidence before a court of law. Such evidence would be considered inadmissible. But Section 45 of Indian Evidence Act provides an exception to the above rule. According to it, the court has got the power to take the opinion of experts of particular fields in cases where it is unable to form an opinion in a particular matter.

Five fields have been mentioned under this provision, from which the court can put the demand of expert opinion i.e., Science, arts, handwriting, fingerprint, and foreign law.

This provision has got its basis in a Latin maxim i.e., “cullibet in sua arte est credendum”, which means that the court must rely on a person with special knowledge in his or her field, at a particular point relevant to that respective field.

The court may take an expert opinion when it comes to a point where it is unable to reach a conclusion related to a particular matter, without the opinion of an expert related to that respective field. If a situation arises where the witness is himself or herself an expert, then a third party may be called upon to have an unbiased conclusion. Without the expert opinion of a medical expert, the court won’t be able to determine many things like the reason for death, time of death, cause of injury, the weapon used, etc. Section 45 states that medical evidence can be used in order to corroborate other types of evidence presented in the case or facts of such a case.

Article 20(3) – Indian Constitution

Article 20(3) of our Indian Constitution relates to self-incrimination and says that “no person accused of any offence shall be compelled to be a witness against himself”. It has its basis in the maxim “Nemo Tenetur Accusare Se Ipsum Nisi Coram Deo”. It means that no person is bound to accuse oneself. So the relevancy of this Article here is that it acts as a shield for the accused with respect to giving evidence against himself or herself.

Article 27 – Indian Evidence Act

This provision says that If an accused person provided information that led to the discovery of a fact, that information, to the degree it relates to the fact can be established; whether or not such information amounts to a confession is irrelevant. Hence, there’s a collusion between this provision and Article 20(3) as described above.

After many contradicting decisions of High Courts, it was finally held by the Supreme Court that both provisions have to be reconciled. Whether or not the accused was forced to make the statements is the question that needs to be answered. If the information was provided freely by the accused, Article 20(3) will not apply and section 27 will consider it significant. But, if such information was obtained under duress, that information should be disregarded because it violates Article 20. (3).

Article 21 – The Indian Constitution

Article 21 of the Constitution states that:

“No person shall be deprived of his life or personal liberty except according to a procedure established by law."

Thus, making it the most significant fundamental right in the entire document.

Indian judiciary has significantly widened the application of Article 21 as a result of the Maneka Gandhi v. Union of India, AIR 1978 SC 597, ruling. According to the court, the right to life includes the right to live in dignity and would cover all of the elements that contribute to a man's existence being important and worthwhile. It was recently held by the SC that the Right to Privacy is a fundamental right under the scope of the Right to life.

In Selvi v. State of Karnataka, AIR 2010 SC 1974, Indian Supreme Court decided that the absence of the accused's agreement, narco-analysis, brain mapping, and lie detector tests are violations of his right to life and personal liberty based on the broad interpretation of article 21 of the Indian Constitution. Following this ruling, the breadth of medical evidence has been more strictly regulated, and the ruling has also drawn criticism for making the criminal justice system much more victim- and law-obeying-friendly and accuser-friendly.

Evidentiary Value of Medical Evidence

Although it is not direct evidence, a medical expert's opinion can be corroborated. It can only substantiate an eyewitness' claims and demonstrate actual evidence. The worth of medical evidence has significantly increased over time. Yet, there is nothing mentioned about the importance or weight of expert judgments in the clause. This section only specifies the admissibility of expert testimony. Expert testimony is frequently used to either support or refute oral testimony, but it does not qualify as significant evidence. The only purpose of an expert's evidence is to provide the court with advice. The expert must be evaluated impartially by the court because he is not a witness to the facts. The expert is never given the power to decide; instead, the Court makes decisions with the expert's input.

Formerly, the view of an expert was considered only an opinion, which is irrelevant generally and dependent on the circumstances to be considered important and have only persuasive value. In the event of a dispute between oral and expert evidence, oral evidence is given more weight. The court decided in the matter of State of Haryana v. Bhagirath, Criminal Appeal No. 258 of 1984. A medical expert's testimony does not have to be the last word in a case. The court will look at this perspective. If an opinion is illogical or biased, the court is not compelled to follow it. After all, a person's opinion is what they create in relation to a real-world situation. When two doctors disagree, it is up to the judge to take the position that is more unbiased or likely. The court is not compelled to accept a doctor's conclusion simply because they said it if it is not supported by probability.

However, this position has begun to evolve. Evidence evaluation is both an art and a science. To determine a contested question of fact, the Court must take into account all pertinent information. It is necessary to weigh all factors, including any expert opinion offered. The crucible must be filled with all necessary inputs. But the Court’s wisdom, common sense, and intellect must be the source of such appreciation. The ability to understand persons and court proceedings is essential. The court’s understanding of the course of events and typical and likely human behaviour will be crucial. Accepting the guidelines of reasonably prudent thinking is necessary. The decision-making process must consider all pertinent circumstances. After being tested, analysed, and reviewed, no piece of evidence can be considered to have prevailed over the others unless it is decisive, persuasive, and beyond a reasonable doubt.

So, the significance of the medical data or expert opinions generally depends on the nature of the issue. In actual fact, we see that reliable and credible oral evidence takes precedence over scientific evidence, and its value depends on how much it supports or refutes the direct testimony of an eyewitness, eliminating the possibility of the harm that the party is alleging. Hence, medical evidence is highly persuasive, yet it can be discounted for good reasons.

Absence of Expert: Not Indispensable to the case of Prosecution

Regardless of the calibre of the direct evidence presented in the case, the Supreme Court concluded in Vineet Kumar Chauhan v. State of Uttar Pradesh, Appeal (Crl.) 35 of 2006, that it cannot be established as a general rule that an expert opinion is essential for the prosecution case. Expert opinion may not be necessary if the direct evidence is unquestionable and the other evidence is consistent with the direct evidence.

Corroboration: Required in Expert Opinion

The Supreme Court stated in Muralilal v. State of Madhya Pradesh, AIR 1980 SC 531, that there is no rule stating that a handwriting expert's conclusion must be supported by other evidence, but caution should be exercised due to the imprecise nature of the science involved in handwriting identification. It is necessary to study the justifications for the opinion and to take into account all available data. As the court has ruled, it would be extremely risky to convict someone based only on an expert's testimony.

This is true since the expert's viewpoint depends on his qualifications, which in turn depends on the degree of growth of the industry he works. For instance, fingerprint analysis is a highly established subject, thus the likelihood of error is minimal there. However because handwriting recognition is a relatively new science, there is a strong likelihood that the court's ruling may contain errors.

An expert's opinion must be viewed in the context of the other evidence presented in the case, though, even in circumstances involving highly established subjects. For instance, the court ruled in Prakash v. State of Karnataka, Criminal Appeal No., 1682 of 2005, that even though the fingerprints matched, the report was not credible if the method of capturing the fingerprint was unclear, i.e., it was not proven how the accused's fingerprints entered the object from which the fingerprints were collected.

Role of Medical Evidence in Criminal Cases

When it comes to rendering verdicts in criminal cases, the purpose of medical evidence is to direct judges towards making logical choices. Medical evidence or a medical expert's opinion is used in court to establish the cause of injuries, and their effect, such as whether they are likely to result in death, the most likely weapon that may have caused the damage, etc. in cases of murder, manslaughter, or any other type of bodily harm. Medical knowledge is a completely distinct field, and in order to express an opinion on it—which is impossible for a general person to do—one must possess specialist knowledge in that field. As a result, medical experts who have been recruited as witnesses offer the court their assessments of the medical evidence. This professional judgement is necessary and frequently considered when criminal cases are decided.

In a situation where the accused might seek relief based on mental incapacity or insanity, it is medical evidence and the scientific procedures linked with it that proves the insanity. The first issue that comes up in every case involving a girl, including rape or kidnapping, is whether or not the girl in question is a minor. Once more, the minority is established with the use of medical advice. The scientific studies that are carried out to provide an expert's report also significantly contribute to proving the crime of rape in and of itself. The expert's opinion is not enforced as evidence, nevertheless, because the court of law has the power to accept or reject it. Section 45 of the Indian Evidence Act, 1872, which in theory devalues expert testimony by categorising it as simply corroborative in nature, is the source of the Court's discretionary power.

In Chimanbhai Ukabhai v. State of Gujarat, AIR 1983 SC 484, the Supreme Court ruled in 1983 that the medical evidence presented and analysed by the prosecution had corroborative value, making it admissible. In addition, the court noted that the medical testimony suggested that the complainant's injuries may have contributed to the person's death naturally as claimed. Also, the medical evidence establishes the veracity of the alleged causes of harm independently, and this can subsequently be confirmed with eyewitness testimony. As a result, the testimony of such witnesses can be recorded and approved as acceptable. Yet, it is not viable to discount an eyewitness narrative based on an apparent discrepancy with medical data unless the medical evidence goes above and beyond to completely rule out all possibilities of injuries occurring in the manner described by the eyewitnesses.

Even while the issue at hand related to the death penalty in trials, it was also considered in the case of Rajendra Pralhadrao Wasnik v. State of Maharashtra, Review Petition (Criminal) Nos. 306-307 of 2013, whether a criminal may be changed and rehabilitated in society. The court ruled that the prosecution must present evidence in court to demonstrate that the prisoner cannot be changed or saved. On this front, a number of data can be revealed, including details regarding the defendant's actions while incarcerated and while out on bail, medical information regarding his mental health, and communication with his family, among other things. The convicted may also present such records or medical evidence.

We can look at this most recent decision of the Supreme Court from the year 2020 to comprehend the situation of medical evidence in Indian criminal jurisdiction and its admission. In the case of Santosh Prasad & Santosh Kumar v. State of Bihar, Criminal Appeal No. 264 of 2020, the supreme court ruled that the accused cannot be found guilty of rape based entirely on the prosecutrix's statement unless her testimony is impeccable. The prosecutrix's statement or evidence was scrutinised by the top court in the landmark decision, but it turned out that it did not agree with the doctor's medical testimony. As a result, the Court thought about the bigger picture and addressed the question of whether the accused can be found guilty based solely on the prosecutrix's deposition even though the medical evidence and the testimony of the other witnesses do not support it.

From the analysis above, it is clear that the prosecutor's case must be supported by medical evidence in order to establish the crime of rape. Additionally, as stated by a number of other important cases, including Piara Singh v. Territory of Punjab, 1977 AIR 2274, the court must take into account the evidence that is consistent with the direct evidence or whose testimony is consistent with the facts of the prosecutrix's deposition when two medical pieces of evidence contradict one another and are on an equal footing to form an expert opinion.

Scientific Methods as relevant to Medical Evidence

When it comes to deciding criminal cases, scientific techniques like blood tests, DNA tests, autopsy reports, blood stains, etc., carry a significant amount of admissible evidence. Additionally, many of these scientific methods utilised by experts when assembling medical evidence are practically required in rape cases and other crimes involving women. Medical evidence in rape cases may originate from the following sources: characteristics of the complainant's attack or characteristics of harm close to the vaginal regions or other private parts. There are many indicators of the crime of rape, including blood or basic stains on the prosecutor of the accused, spermatozoa close to the vaginal emission, denunciation examination, and loss of virginity indicators.

Due to the fact that rapes against women are frequently performed inside walls, there is frequently no further direct proof beyond the prosecutor's own testimony in these cases. Medical evidence frequently plays a significant role in these situations. A medical student who was brutally abused and gang raped in the case of Mukesh & Anr v. State for NCT of Delhi and Others, (2017) 6 SCC 1, often known as the Delhi gang rape case, subsequently passed away from her internal wounds. In this case, there was no ocular or direct evidence. So, the importance and corroboration of medical evidence were essential. In the Kathua rape and murder case, clonazepam was discovered on the murdered girl's body, per the post-mortem, later in 2018. The physicians claim that the infant was drugged with a narcotic before being raped and later murdered. She had been kept by Sanji Ram, one of the people accused of the crime, for a number of days, according to forensic evidence. Hair fragments from the girl were found that matched those discovered at the temple. The autopsy revealed that she had been brutally killed, repeatedly raped by several males, and hit in the head with a large stone.

Delhi Forensic Science Laboratory evaluated 14 boxes of materials as part of the investigation, including vaginal swabs, hair strands, blood samples from four suspects, the dead girl's viscera, her garment and salwar, plain clay, and clay that had been stained with blood. Along with the vaginal swabs, additional samples were discovered to match the accused's DNA. In the temple where she was sexually abused, Asifa's hair was found, and it matched both hers and the accused. The medical evidence that had been gathered led to the conviction and incarceration of eight people. Because of this, medical evidence is significant and useful in corroborating other types of evidence when it comes to specific crimes against women, including rape.

The other important rulings, such as Ranjit Hazarika v. State of Assam, (1998) 8 SCC 635 and State of Punjab v. Gurmeet Singh, 1996 AIR 1393, where the prosecutor's testimony was given the utmost weight. The medical evidence in the Ranjit Hazarika case was against the prosecutrix's testimony as well as that of the other witnesses, who also happened to be her parents. The medical report and opinion came to the conclusion that the girl had not been the victim of rape because there were no injuries to her private areas and her hymen had not ruptured.

Nonetheless, the court exercised its discretionary authority under Section 45 of the Indian Evidence Act to include medical evidence and relied on the direct and coordinated evidence offered by the prosecutrix and her parents as witnesses to find the defendant guilty. In the instance of Gurmeet Singh, however, the medical evidence supported the prosecutrix's statement, but the Trial Court had found the accused innocent on false grounds, such as the fact that the woman routinely engaged in sexual activity and had questionable morals.

The Supreme Court of India considered the medical evidence and relied on the girl's testimony when the prosecutrix appealed, which led to the respondents' conviction. The intriguing thing about this case is that, despite the fact that the medical evidence supported the prosecutrix's statement, the Apex Court specifically said in its ruling that the testimony of the prosecutrix did not need to be supported by any other evidence. Consequently, it is clear from both of these precedent-setting decisions that the nature of medical evidence is one of total corroboration and that the law never relies entirely on it to resolve a case. Along with the medical data, other variables and pieces of evidence are taken into account.

Medical Evidence v. Ocular Evidence

According to the general rule of evidence, medical evidence should only be used to support other evidence and cannot be used to disprove an unbiased, well-respected witness. In other circumstances, the ocular and medical data may be in stark opposition to one another. In that situation, either of the two courses may be taken:

a- In circumstances where the visual evidence is impeccable and there is no good reason to suspect that the accused is being falsely implicated, the court may take this strategy and decide that the witnesses have simply embellished the incident.

b- When the ocular evidence is not of that truthfulness and the medical evidence is beyond any reasonable doubt or suspicion, the court may rely on the medical evidence and evaluate it in relation to the ocular evidence.

So, the ocular evidence is to be disregarded when it conflicts with the medical evidence. Even the court has stated that the prosecution case has a fundamental flaw if the prosecution witness' testimony completely contradicts the medical evidence. If this flaw cannot be adequately explained, it is enough to invalidate the prosecution's whole case. The optical evidence must, however, be in stark contrast to the medical evidence in order to be disregarded. In other words, if the oral evidence is ordinarily trustworthy, it cannot be disregarded unless the medical evidence entirely excludes the prosecution's story.

The medical evidence and the optical evidence have historically engaged in a battle. Over time, numerous judges have used various justifications and relied on either of the evidence to render their decisions. There must always be some sort of direct evidence to show that the accused is guilty because medical evidence is corroborative in nature and only serves as a basis for reasonable doubt. Medical evidence plays a key role in a case's development by entering the crime scene with the intention of forming an opinion or providing an expert report. Yet, the testimony of a lone witness cannot be overruled by the report of a medical expert who was not there at the crime site when the crime was actually committed. Yet, in cases of controversy, the court has eventually favoured medical evidence over ocular evidence.

The injuries that caused the death, the likely weapon, the time of death, and other similar medico elements have all influenced the decision in cases when there is a discrepancy between the medical evidence and the visual evidence. But, given that the medical evidence is probative and corroborative in character, the ocular evidence cannot simply be ignored in this case. For it to be established as true, it must be backed up by concrete proof. In the case of Brij Bhusan v. State of UP, 2001 CriLJ 1384, the court decided that if the medical evidence was insufficient due to a discrepancy between the nature of the injuries and other pertinent information, the court would draw its own conclusions. In subsequent years, the court has further stressed the idea that, in cases where there is a disagreement between two medical witnesses, the direct evidence-supporting witness should be taken into account. This ruling was reaffirmed in the Makhan v. State of Gujarat, AIR 1971 SC 1797, decision and the court additionally emphasised that if such contradiction were to be overt, the prosecution case would be declared to be flawed in and of itself.

The Supreme Court ruled in the most recent case of Pruthviraj Jayantibhai Vanol v. Dinesh Dayabhai Vala, Criminal Appeal No. 177 of 2014, that the ocular evidence may only be discounted if there is a glaring discrepancy between the medical evidence and the oral testimony, and the medical evidence renders the ocular testimony implausible and eliminates the possibility that the ocular testimony is accurate. The court stressed the value of ocular evidence while overturning the accused's acquittal.

Relevant Case Laws with respect to the admissibility and relevance of Medical Evidence

Magan Bihari Lal v. State of Punjab, 1977 AIR 1091

"It is now well established that expert opinion must always be regarded with considerable caution, and perhaps none so with more caution than the opinion of a handwriting expert," the Supreme Court of India ruled. There is a wealth of presidential authority that asserts it is dangerous to base a conviction solely on an expert's view without strong supporting evidence. This guideline is now almost a rule of law because it is followed by everyone.

Ram Narain Singh v. State of Punjab, 1975 AIR 1727

This Court determined that when prosecution witnesses' testimony conflicts with medical or ballistics expert testimony, it constitutes a fundamental flaw in the prosecution's case and, unless adequately explained, is sufficient to undermine the prosecution's whole case.

Solanki Chimanbhai Ukabhai v. State of Gujarat, AIR 1983 SC 484

According to the Court, medical evidence usually only serves as corroboration. Nothing more than the possibility that the injuries might have been caused in the manner suggested is established. The defence may utilise the medical data to demonstrate that the injuries could not have been brought on in the manner suggested, casting doubt on the eyewitnesses. Therefore, unless the medical evidence goes so far as to completely rule out any possibility of injuries occurring in the manner reported by the eyewitnesses, the testimony of the eyewitnesses cannot be disregarded on the basis of an alleged difference between it and the medical data.

As a result, the importance of medical evidence has grown over time. It is corroborative rather than conclusive, and in cases where there is a glaring discrepancy between the direct evidence and the medical evidence regarding the entirety of the prosecution case, it undermines the prosecution's case. If a prosecution witness' testimony conflicts with the medical evidence, this is a major flaw in the prosecution case and, unless it is adequately explained, is enough to undermine the entire prosecution case.

Analysis

Despite the fact that scientific techniques and procedures have substantially advanced and developed, there has not been a significant revision to the Indian Evidence Act of 1872 that could explain the weightage to be given to medical evidence. Our current methods are more accurate than what our eyes and ears can detect. Human senses, psychology, and the way in which an individual perceives the world around him or she can all be highly unreliable and erroneous, whereas medical evidence is a dependable source of information that is based on science. As science has advanced to a point where people cannot, the dependability of medical data is unquestionably greater than how a human interprets the facts. Since DNA testing is not included in this Act and was not developed at the time it was passed, nothing has changed. As a result, there is no legislation that regulates DNA tests or establishes the guidelines for their execution.

It is also crucial to note that Section 45 of the Indian Evidence Act presents some challenges to the use of expert testimony. First of all, the Section says nothing about how the court will decide whether the expert they choose is educated about the subject matter or who qualifies as an expert. Additionally, the Act does not specify how the court should ensure that the appointed expert is unbiased towards any one party. Several reasons contribute to India's lax standards for expert opinion evidence.

Courts must establish the requirements for gathering medical evidence to ensure that it is trustworthy and free from room for human mistakes. India's forensic science is completely behind other industrialised countries that have made significant advancements in the field of crime prevention. The sort of power science has allowed forensic professionals to solve any case they are faced with just a single DNA sample or saliva sample. By utilising this resource, the Indian judicial and executive authorities would undoubtedly be able to better control crime. In India, laboratories' potential has yet to be realised. Only the legislature and efficient application of the law can do this.

We need to update the law to reflect new scientific knowledge so that both can operate concurrently. Implementing criminal laws from a century ago won't help with today's issues because crime has changed and become sophisticated and quick. It is imperative that legislation and investigative methods advance. The only way to accomplish the main objectives of our judicial system is in this way.

Conclusion

Indian Evidence Act of 1872 states that medical evidence may be used in India to support other categories of evidence. Medical evidence, which is regarded as expert proof, is a significant and crucial part of the evidence, especially in cases involving crimes against women. Since expert testimony is necessary for criminal trials, the government has built laboratories and other organisations all around the nation that offer scientific services to the criminal court system. Because of this, the ability of the law to deliver justice depends on witnesses and evidence.

The most significant aspect in determining whether the court will rule in favour of the prosecution or the defence is the evidence that it hears. As witnesses are the justice's eyes and ears, it is possible to consider that oral testimony is more important than medical evidence. If the oral testimony is found to be credible, factually sound, and indicates probability, it must be accepted; it cannot be rejected in light of false medical data. Because the medical officer is an expert witness, his testimony should not be given extraordinary weight, but rather just restricted weight.

A medical officer's testimony must be assessed and taken into account in the same manner as any other ordinary witness' testimony, however, there is no unassailable presumption that he is a reliable observer of reality. Because the value of medical evidence's admissibility depends on a number of factors, including the credibility of the medical expert, whether the medical opinion supports the contention made by the parties, and whether the opinion is weakening the contentions, then the oral evidence scrutinised more closely, it is correct to maintain the corroborative position of medical evidence rather than giving it definitive status.

References

Bibliography

• Khaled Fahmy, The Anatomy of Justice: Forensic Medicine and Criminal Law in Nineteenth-Century India (1999)
  
• Subhash Chandra Singh, DNA Profiling and the Forensic Use of DNA Evidence in Criminal Proceedings (2011)
• Edmond, Gary, and Kent Roach, A Contextual Approach to the Admissibility of the State's Forensic Science and Medical Evidence (2011)
• Grover, N., & Tyagi, Development of Forensic Science and Criminal Prosecution-India, (1910)
• R. V. Kelkar, Lectures on Indian Evidence (4th Ed., 2006)

Webliography

• Shanuja Thakur, All about the legal aspects of medical evidence, Available Here
• Sonali Priyadarsani, Medical Evidence: Pivotal Role in Criminal Jurisdiction, Available Here
• Anubhav Bijalwan, Importance of Medical Evidence, Available Here

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