Ram Chandra Ram v. State of U.P. & ors., 2025
The Court rightly held that the focus of a rape trial is on consent and commission of the offence, not on paternity, unless directly relevant.
Judgement Details
Court
Allahabad High Court
Date of Decision
12 September 2025
Judges
Justice Rajeev Misra
Citation
Acts / Provisions
Facts of the Case
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A case was registered against the applicant under multiple IPC and POCSO provisions for rape and other offences.
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Chargesheet was filed, and trial began.
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After five prosecution witnesses were examined, the accused filed an application before the Trial Court for DNA testing of the prosecutrix and her child.
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He argued that the child, though allegedly premature, was "fully grown," and thus could not be his, suggesting a DNA test would prove his innocence.
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The Trial Court rejected the application. The accused approached the Allahabad High Court under Section 482 CrPC, challenging the rejection.
Issues
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Can DNA testing of the prosecutrix and her child be directed routinely in rape cases?
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Are there compelling or exceptional circumstances in this case to warrant such a test?
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What is the role of DNA evidence in rape prosecutions, especially when paternity is not the core issue?
Judgement
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The Allahabad High Court upheld the Trial Court's rejection of the DNA test application.
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It emphasized that in a prosecution under Section 376 IPC, the paternity of the child is not directly relevant to determining the offence.
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It held that DNA tests in such cases must not be ordered routinely, due to the serious social consequences for the survivor and child.
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The Court noted that no compelling or unavoidable circumstances had been presented by the accused.
Held
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The application for DNA test of the prosecutrix and her child was rightly rejected by the Trial Court.
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There were no clinching facts or circumstances justifying such a direction.
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The Courts must exercise “care, caution, and circumspection” before allowing such intrusive tests, considering the social sensitivity and privacy involved.
Analysis
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The judgment aligns with the principle that rape trials should not become trials of the survivor or subject her to unnecessary and invasive procedures.
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It reaffirms that DNA evidence, while powerful, should not be misused to harass or delay the trial process.
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The Court rightly held that the focus of a rape trial is on consent and commission of the offence, not on paternity, unless directly relevant.
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The verdict provides procedural safeguards for rape survivors and preserves their dignity during trial.