Introduction:

In the case of Muna @ Jagabandhu Bhoi v. State of Odisha, the Orissa High Court issued crucial directives regarding the functioning of Forensic Science Laboratories (FSLs) in criminal cases. Justice Sangam Kumar Sahoo emphasized the significance of timely receipt of chemical examination reports and highlighted the duty of the state to provide adequate infrastructure and manpower to ensure effective functioning of FSLs.

Arguments:

The appellant, represented by Mr. S.K. Baral as Amicus Curiae, challenged the conviction under Sections 454/376(2)(j)(l)/323 of the IPC, citing procedural lapses and the absence of crucial chemical examination reports. On the other hand, Mr. Rajesh Tripathy, Additional Standing Counsel for the State, defended the conviction, arguing the sufficiency of evidence despite the absence of the chemical examination report.

Court’s Judgement:

Justice Sahoo underscored the importance of chemical examination reports in criminal trials and reiterated the duty of the state to provide necessary infrastructure and manpower to FSLs. While upholding the appellant’s conviction under Section 376(2)(j)(l), the Court reduced the sentence to 10 years rigorous imprisonment. Additionally, the Court directed the Director of Public Prosecution to ensure prompt acquisition of chemical examination reports and instructed trial courts to take action against delays in their submission.