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Evidentiary Limitations Of Post-Mortem Reports In Indian Criminal Trials




Sagara Sachin, Christ (Deemed to be University), Pune, Lavasa


ABSTRACT


The use of post-mortem examination reports (“PMRs” or “post-mortem reports”) in Indian criminal trials presents complex evidentiary questions. Though an autopsy report is treated as expert evidence under Section 45 of the Indian Evidence Act, 1872 (IEA), Indian courts have long cautioned that a PMR “alone... is not a substantive piece of evidence”. In practice, PMRs generally serve to corroborate or supplement other evidence (such as dying declarations and witness testimony) rather than conclusively establish the facts. This paper examines the development of the law on PMRs, including statute and case-law, recent judicial trends (2022–2026), forensic reliability concerns, and comparative and constitutional perspectives. It concludes with critical observations and reform suggestions to clarify and improve the probative use of post-mortem evidence.



Indian Journal of Law and Legal Research

Abbreviation: IJLLR

ISSN: 2582-8878

Website: www.ijllr.com

Accessibility: Open Access

License: Creative Commons 4.0

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All research articles published in The Indian Journal of Law and Legal Research are fully open access. i.e. immediately freely available to read, download and share. Articles are published under the terms of a Creative Commons license which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

 

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The opinions expressed in this publication are those of the authors. They do not purport to reflect the opinions or views of the IJLLR or its members. The designations employed in this publication and the presentation of material therein do not imply the expression of any opinion whatsoever on the part of the IJLLR.

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