Introduction:
In Chappidi Ravindranatha Reddy & Others v. Challa Narasamma & Others (Civil Revision Petition Nos. 3196 & 3197 of 2025), the Andhra Pradesh High Court reaffirmed the significant evidentiary value of fingerprint examination in disputes concerning the execution of documents. Justice Subba Reddy Satti held that expert opinion relating to thumb impressions carries greater relevance than handwriting opinion because the science of fingerprint identification is regarded as an exact science that does not ordinarily admit of mistake or doubt.
The dispute arose from a suit for specific performance based on an alleged agreement of sale. The plaintiffs asserted that the defendants had executed the agreement and were bound to perform their obligations under it. The defendants, however, denied execution of the document and contended that their signatures had been forged and the agreement itself was fabricated. Since the authenticity of the document became the central issue in the litigation, the plaintiffs sought the assistance of the court to obtain the thumb impression of the first defendant and have it compared with the thumb impression appearing on the disputed agreement through a fingerprint expert.
The trial court rejected the applications, holding that the issue of limitation had to be decided first and that obtaining expert opinion before framing substantial issues was premature. Aggrieved by this refusal, the plaintiffs invoked the supervisory jurisdiction of the High Court under Article 227 of the Constitution, contending that the trial court had failed to exercise the jurisdiction vested in it and had prevented the parties from producing crucial scientific evidence.
Arguments of the Parties:
The petitioners contended that the entire suit revolved around the question whether the agreement of sale had in fact been executed by the defendants. Since the defendants had specifically denied execution and alleged forgery, the comparison of thumb impressions by a qualified fingerprint expert was essential for the effective adjudication of the dispute.
According to the petitioners, scientific examination of thumb impressions would assist the trial court in arriving at the truth and would avoid unnecessary speculation. They argued that obtaining expert opinion at an early stage would not prejudice either side; rather, it would enable the court to evaluate the genuineness of the disputed agreement while deciding all issues arising in the suit. The petitioners further submitted that the trial court had adopted an unduly technical approach by refusing the request on the ground that limitation was yet to be decided.
The respondents supported the trial court’s order and argued that the applications were premature. They contended that the court had not yet framed all substantial issues and that evidence regarding the disputed document was yet to be recorded. According to them, the question whether expert comparison was required could be considered after the parties adduced evidence.
The respondents also relied upon precedents dealing with comparison of handwriting and argued that courts should exercise caution before referring disputed documents for expert examination. They maintained that the trial court had correctly postponed consideration of the request until a later stage of the proceedings.
Court’s Judgment:
Allowing the revision petitions, the Andhra Pradesh High Court held that the trial court’s reasoning did not withstand legal scrutiny and that its refusal to obtain expert opinion had resulted in failure to exercise the jurisdiction vested in it.
The High Court observed that when the execution of a document is specifically disputed and allegations of forgery are raised, scientific comparison of thumb impressions can significantly assist the court in determining the truth. The Court noted that the very purpose of expert evidence is to aid judicial decision-making in matters requiring specialised knowledge.
Justice Subba Reddy Satti emphasised the distinction between handwriting comparison and fingerprint identification. While handwriting analysis involves opinion evidence that may admit varying degrees of uncertainty, fingerprint examination stands on a much stronger scientific footing. Referring to the legal position recognised by the Supreme Court, the Court observed that identification of thumb impressions is treated as an exact science that ordinarily does not admit of mistake or doubt.
The Court held that because fingerprint patterns remain unique to every individual, expert comparison of thumb impressions provides a highly reliable method of establishing or disproving execution of a document. Although ageing may reduce the sharpness or clarity of fingerprint ridges, the underlying ridge patterns themselves do not change. Consequently, the passage of time cannot by itself become a reason to deny comparison.
Rejecting the trial court’s view that limitation had to be decided first, the High Court observed that obtaining expert opinion would still assist the adjudication of the suit irrespective of the outcome on preliminary issues. The Court noted that expert evidence relating to execution of the document was directly connected with the merits of the dispute and could facilitate an effective and comprehensive determination of the rights of the parties.
The Bench further held that the stage at which the applications were filed could not be a valid ground to reject them. Once the authenticity of the agreement itself was under challenge, the trial court ought to have taken steps to preserve and secure the best available evidence. Waiting until a later stage could unnecessarily delay the proceedings and adversely affect the quality of evidence.
The High Court also found that the authorities relied upon by the respondents concerning handwriting comparison were distinguishable and had no application to the facts of the present case. The dispute before the Court related specifically to thumb impressions, and the legal principles governing fingerprint evidence were materially different from those applicable to handwriting analysis.
Accordingly, the Court held that the trial court had failed to exercise the jurisdiction vested in it by law. Such failure had the potential to cause a miscarriage of justice because it deprived the parties and the court of important scientific evidence directly relevant to the core issue in the suit.
Invoking its supervisory jurisdiction under Article 227 of the Constitution, the High Court set aside the orders passed by the trial court. It directed the trial court to obtain the thumb impression of the first defendant and send it, along with the disputed agreement of sale, to a fingerprint expert for comparison and opinion.
The decision reinforces the principle that courts must actively utilise reliable scientific methods where the authenticity of documents is in serious dispute. It also highlights that procedural considerations should not prevent courts from securing evidence that can materially assist in arriving at the truth. By recognising the superior reliability of fingerprint examination in appropriate cases, the judgment strengthens the role of scientific evidence in civil adjudication and promotes a more accurate and effective administration of justice.