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Ram Deo Prasad v. State of Bihar — Absence of forensic evidence and investigative lapses affecting sentence

Part of the Forensic Docket on Legal Desire Forensics — how a forensic technique fared under appellate scrutiny.

The facts

The case involved the rape and murder of a four-year-old child, for which the trial court and High Court convicted the accused and sentenced him to death under Sections 376 and 302 of the Penal Code.

The Supreme Court held that the presumption arising from the injuries found on the victim’s body, which led to her death, was not rebutted by the accused, and that his conviction was therefore justified.

However, the Court went on to note deficiencies in the investigation, an absence of forensic evidence, and lapses in the trial proceedings, coupled with the accused’s lack of resources to properly contest the case.

In light of these factors, the Court modified the sentence, converting the death penalty into a term of imprisonment, even though the underlying conviction itself was affirmed.

Why this belongs in the Forensic Docket: An absence of forensic evidence and investigative lapses can spare a convicted person from the death penalty even where the conviction itself stands — thin forensic work has consequences at sentencing even when it doesn’t defeat guilt.

Case details

Citation[2013] 6 S.C.R. 108
Case numberCriminal Appeal No. 1354/2012
CourtIndian Supreme Court
Decided2013-04-11
ModuleCase Method Library

Read the full judgment (PDF), sourced from the Indian Supreme Court Judgments open dataset (AWS Open Data Registry, CC-BY-4.0).

Explore more in the Forensic Docket or browse the full Forensics hub.

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