State of Orissa v. Kanduri Sahoo — NDPS custody chain (Excise Malkhana storage)

Part of the Forensic Docket on Legal Desire Forensics — a conviction confirmed through final appeal, kept here as a method-of-crime record.

The facts

The accused was found in possession of contraband articles under Section 20(b)(i) of the Narcotic Drugs and Psychotropic Substances Act, 1985.

The sample was sent for chemical examination four days after the alleged recovery; during that period, the articles were kept in the Excise Malkhana (storeroom).

The report of the chemical examiner covered the custody of the articles from the date of recovery to the date the sample was sent for examination.

The Supreme Court held that merely because the articles were kept in the Excise Malkhana for four days, that fact would not by itself render the prosecution’s version suspect, even though there was no specific order on record for that storage.

Status: conviction upheld through final appeal.

Why this belongs in the Forensic Docket: A documented custody trail through an Excise Malkhana, even without a formal storage order, was enough to preserve the integrity of a narcotics sample — a useful benchmark for what counts as an adequate, if imperfect, chain of custody.

Case details

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

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