DNA Evidence Contradicting Prosecution Case Justifies Acquittal in Rape Trial: Punjab & Haryana High Court Dismisses State Appeal

Case Name: State of Haryana v. Yashpal

Date of Judgment: 06 March 2026

Citation: CRA-D-772-DB-2014

Bench: Justice Gurvinder Singh Gill and Justice Ramesh Kumari

Held: The Punjab & Haryana High Court held that where DNA profiling conclusively excludes the accused as the source of biological material found on the prosecutrix’s clothing, the prosecution case becomes doubtful. In such circumstances, the appellate court will not interfere with an order of acquittal, particularly in light of the “double presumption of innocence” applicable after acquittal by the trial court.

Summary: The appeal was filed by the State of Haryana challenging the judgment dated 09.05.2013 by which the trial court acquitted the accused of offences under Sections 376 and 452 IPC arising out of FIR No. 71 dated 16.04.2012 registered at Police Station Kosli, District Rewari.

According to the prosecution, the incident occurred on the evening of 15.04.2012 when the prosecutrix was alone at her house while her family members had gone to the fields. It was alleged that the accused forcibly entered the house, took the prosecutrix to the bathroom of a nearby house belonging to Rampat, gagged her and committed rape. Her mother allegedly arrived at the scene during the incident, upon which the accused pushed her and fled.

The matter was reported to the police the next day through a written complaint, following which an FIR was registered and the prosecutrix was medically examined. The medical officer noted certain injuries including a contusion on the back and observed that the possibility of sexual assault could not be ruled out. Samples including vaginal swabs and clothing were collected and sent for forensic examination.

During trial, the prosecution examined twelve witnesses including the prosecutrix, her mother and the investigating officers. The defence, however, raised a plea of false implication and produced witnesses to establish an alibi. Evidence was led to show that the accused, who was serving as a constable in Delhi Armed Police, was on duty in connection with municipal elections in Delhi on the date of the alleged incident.

The trial court ultimately acquitted the accused, finding that the prosecution failed to establish guilt beyond reasonable doubt.

Before the High Court, the State argued that the trial court had wrongly appreciated the evidence and had given undue weight to minor contradictions in the prosecution case. It was contended that the testimony of the prosecutrix and her mother clearly established the commission of rape and that the medical evidence corroborated the allegations.

The defence countered that the prosecution case was unreliable and that scientific evidence completely undermined the allegations. It was pointed out that the accused himself had sought DNA profiling to determine whether the semen detected on the prosecutrix’s clothing belonged to him.

The High Court noted that the forensic analysis detected human semen on the salwar of the prosecutrix and the underwear of the accused. However, when DNA profiling was conducted, the allelic pattern of the semen sample found on the prosecutrix’s clothing did not match the blood sample of the accused. This finding effectively ruled out the accused as the source of the biological material.

The Court observed that DNA evidence has significant probative value in criminal trials, particularly in cases involving allegations of sexual assault. When such scientific evidence contradicts the prosecution version, it creates serious doubt regarding the involvement of the accused.

The Court further reiterated the settled principles governing appellate interference with acquittal. Relying on the Supreme Court judgment in Chandrappa v. State of Karnataka, the Court held that an accused enjoys a double presumption of innocence after acquittal and that an appellate court should not interfere unless the findings of the trial court are manifestly perverse or unreasonable.

In the present case, the Court found that the trial court’s conclusions were based on a plausible appreciation of the evidence. The DNA report substantially weakened the prosecution case and supported the view that the guilt of the accused had not been established beyond reasonable doubt.

Decision: The High Court dismissed the appeal filed by the State and upheld the acquittal of the accused for offences under Sections 376 and 452 IPC.