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Forensic toxicology has become the scientific fulcrum of prosecutions under the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act), because the prosecution must prove not only the recovery of a substance but also that it is a notified narcotic drug or psychotropic substance in a particular quantity and purity. The Forensic Science Laboratory (FSL) report and related toxicological evidence therefore often make the difference between conviction and acquittal, while at the same time functioning within a legal regime that is both draconian in its sentencing structure and highly technical in its procedural safeguards. Indian courts, especially the Supreme Court and various High Courts, have repeatedly underscored that strict compliance with statutory provisions, standing orders on seizure and sampling, and chain‑of‑custody norms is indispensable in NDPS trials, and that lapses in these respects can seriously erode or even destroy the evidentiary value of forensic toxicology reports.
This paper critically examines the dual role of forensic toxicology in NDPS cases, as a powerful incriminating tool and as a vulnerable point of challenge, by analysing the statutory framework, the NDPS (Seizure, Storage, Sampling and Disposal) Rules, 2022, the erstwhile standing orders on sampling, and key judicial decisions including Noor Aga v. State of Punjab, Thana Singh v. Central Bureau of Narcotics, and Hira Singh v. Union of India. It argues that courts have moved toward a calibrated approach: while recognising the indispensability of expert opinion in establishing the nature of the contraband, they also insist on rigorous procedural compliance as a constitutional counter‑weight to the NDPS Act’s reverse onus and stringent penalties.
The study adopts a doctrinal and analytical methodology based on close reading of statutes, rules, standing orders and case law, supplemented by contemporary academic and practitioner commentary on forensic evidence in NDPS trials. It concludes that although forensic toxicology has high evidentiary value, inconsistent investigative practices, under‑resourced laboratories and divergent judicial approaches to procedural lapses generate legal uncertainty, and it proposes reforms relating to accreditation of laboratories, standardisation of toxicological protocols, digitised chain‑of‑custody systems and clearer judicial standards for the consequences of non‑compliance, all framed in the context of the accused’s Article 21 rights.
Keywords:
NDPS, Article 21, Forensic Science Laboratory, Forensic Toxicology, Evidentiary Value
Cite Article:
"Role and Evidentiary Value of Forensic Toxicology in NDPS Cases: A Critical Study of Procedural Compliance and Judicial Interpretation", International Journal for Research Trends and Innovation (www.ijrti.org), ISSN:2456-3315, Vol.11, Issue 5, page no.b341-b353, May-2026, Available :http://www.ijrti.org/papers/IJRTI2605142.pdf
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2456-3315 | IMPACT FACTOR: 8.14 Calculated By Google Scholar| ESTD YEAR: 2016
An International Scholarly Open Access Journal, Peer-Reviewed, Refereed Journal Impact Factor 8.14 Calculate by Google Scholar and Semantic Scholar | AI-Powered Research Tool, Multidisciplinary, Monthly, Multilanguage Journal Indexing in All Major Database & Metadata, Citation Generator