The Indian Police Journal

Chain of Custody for the Integrity of Evidence:

A Critical Examination

Pranav Kumar, IPS*

Abstract
Maintenance of the chain of custody in criminal proceedings is required to establish
that the physical evidence being produced before the Court is the same as the one
that was taken possession of by the investigating officers during investigation. Chain
of custody is essential for the admissibility of any physical evidence in a court of law.
Despite its enormous significance, there is limited discourse in India over the chain
of custody in criminal jurisprudence and forensic practice. Chain of custody is of
particular relevance when a seized object or sample is sent to a forensic science
laboratory for expert opinion as all stages of transfer of possession and examination
are required to be documented. Constitutional Courts in India have dealt with the
question of chain of custody, mainly in the context of NDPS cases and cases involving
biological evidence. In light of the increasing utilization of forensic methodologies
in criminal investigations, the imperative to uphold a stringent chain of custody has
acquired heightened significance, necessitating a more meticulous scrutiny of the
issue. This article critically examines various aspects of the chain of custody and its
need for evidence integrity. The article provides a critical analysis of different facets
of the chain of custody and underscores its necessity for maintaining the integrity of
evidence.
Keywords: Chain of custody, physical evidence, forensic science.

Introduction possession of an object or a property seized during

an investigation (hereinafter "seized object")
The integrity of physical evidence is an essential including its movement from the point of recovery
prerequisite for its admissibility in a court of law. to its transport to the forensic science laboratory
Physical or real evidence is considered to be the (F.S.L.) for examination and eventual production in
most objective and reliable evidence in a criminal the court for admission and evaluation as evidence.
investigation or trial. Physical evidence is presented It primarily aims to protect the evidence by
in a court of law to prove the occurrence of an preventing contamination or tampering with the
offence or to link the victim, accused or witness to evidence. Thus, various aspects of the chain of
the scene of crime. However, before a court can custody are of considerable relevance for police
consider a piece of physical evidence for evaluation officers conducting investigation and forensic
during a trial, the integrity of the evidence must be examiners handling physical evidence in a
proven. Chain of custody reflects the continuity of laboratory for examination.
Author's Introduction:
*IGP, Swami Vivekananda State Police Academy, Barrackpore, West Bengal.

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Elements of chain of custody (i) Chronological i.e., documentation regarding

Chain of custody begins as soon as the the sequence of movement of seized object
investigating officer (I.O.) takes control of the in the period between seizure and production
seized object in his possession during the before the Court during the trial. It is
investigation. Following are the key ingredients of mandatory to note the date and time along
the chain of custody of a seized object which with the signatures of persons involved
should be properly documented during during each movement/transfer of the seized
investigation and forensic examination: object.
(i) Description of the evidence (ii) Logical, i.e., justification and reasonableness
(ii) Identification details/ unique case identifier of handling of the seized object by various
(e.g., case number/property number) persons, including custody, control,
transport or analysis. Each movement/
(iii) Place of seizure/collection transfer of seized object shall be done only
(iv) Place of storage in the interest of investigation, prosecution
(v) Identity of persons having possession of the and production before the court.
evidence and purpose thereof The chain of custody documentation shall satisfy
(vi) Details of handling of the evidence e.g., both the above requirements for admissibility of
analysis, sampling, re-packaging. evidence. During the trial, the prosecution has to
establish that during the entire period of transit
(vii) Time and date-related information from the point of seizure to the production before
(viii) Particulars of sealing including the court, duly identified and authorised persons
documentation regarding any removal of only had custody of the seized object and all steps
seal/re-sealing of transfer of evidence from one person to another
were for taken for justified purposes.
From the requirements described above, it can be
understood that there are two fundamental elements Typical movement of a seized object in the course
in the chain of custody: of investigation and trial in India can be represented
by following diagram:

The movement pattern varies depending on the expert examination. In case of movement of an object
practices followed in a police organisation, the type from point A (place of seizure) to point F (trial court),
and quantity of objects and the need for forensic/ possession of objects at all intermediary points as

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well as at points A and F is required to be covered person showing the articles taken in possession
by chain of custody. The length of chain is by the police officer at the time of arrest. Section
significant since possession of the object outside 451 of the CrPC, which comes into operation after
point A and F are not relevant for evidentiary the production of property during enquiry or trial,
purposes. does refer to "proper custody" of the property.
However, the object of this section is to allow interim
Legal requirements regarding the chain of custody
custody of the property during the pendency of
in India
such enquiry or trial. Further, the term "proper
The chain of custody aims to establish the integrity custody" is not defined as such in the section.
of physical evidence produced during a criminal Clause 105 of the proposed Bharatiya Nagrik
trial. Thus, maintenance of the chain of custody Suraksha (Second) Sanhita Bill, 2023 (BNSS)
itself must be proven beyond reasonable doubt introduces mandatory recording of search
(standard of proof in criminal law) before the court (including search under clause 185 of BNSS) and
evaluates the evidence. The salient provisions seizure by audio-video electronic means. Further,
concerned with the question of chain of custody in Clause 193 of the BNSS mandates the filing of
criminal laws in India are briefly discussed below: "sequence of custody" of electronic evidence at
the time of filing of report in final form (charge-
Provisions in Code of Criminal Procedure, 1973 sheet/closure) after the conclusion of the
(CrPC) investigation, which once enacted, would be the
CrPC does not explicitly stipulate the requirements first direct reference to the concept of chain of
for chain of custody during investigation or trial. custody in Indian law. However, no such provision
During the investigation, police are authorised to has been proposed in the case of ordinary physical
seize any material object (e.g., biological evidence, evidence.
offending weapon, fingerprints) under section 102 Section 292 of CrPC deals with the admissibility of
of CrPC which deals with the general procedure of reports officers of mint or security/note printing
seizure of property. The section prescribes that press, officers of Forensic Science Laboratories and
every seizure should be forthwith reported to the examiners of questioned documents even if such
concerned Magistrate along with the seized officer is not called as a witness. Section 293 of
property. If the seized property cannot be CrPC deals with the manner of reports of certain
conveniently transported to the court or securely government scientific experts whose reports may
accommodated, it can be left in the custody of any be used as evidence during any inquiry or trial.
person under a bond (commonly referred to as However, there is no mention of requirement of
Zimmanama) which can be called for production chain of custody in either of the sections.
before the Court, whenever required. Section 102
CrPC does not mention anything in particular about Provisions in Indian Evidence Act, 1872 (Evidence
the chain of custody. Similarly, Section 100 CrPC Act)
regarding the procedure of search only mandates Evidence Act does not explicitly stipulate anything
signatures of at least two independent witnesses regarding proof of chain of custody of physical
on the seizure list. Sub-section 100 (6) prescribes evidence. In the Evidence Act, physical evidence
for providing a copy of the seizure list to the itself is not enumerated as a type of evidence in
occupant of the closed place from where the seizure Section 3, which includes only oral and
is made while sub-section 100 (7) contains the same documentary evidence. However, in several cases,
provisions in case of seizure made from the person this gap has been addressed by statutory
concealing any article about his person. Section 51 interpretations by Constitutional Courts. The
also provides for giving a receipt to the arrested provisions regarding the admissibility of evidence

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apply to questions of chain of custody whenever certificate/challan and acknowledgement receipt of

raised during the inquiry or trial. As per section 136 the laboratory are produced by the prosecution in
of the Evidence Act, the judge decides on the the Court to prove chain of custody. Some FSLs
admissibility of evidence, and if one fact is now insist on the preparation of chain of custody
contingent upon a second fact, the judge may ask form by I.O. in case of biological evidence. If I.O.
for proof of the second fact first. Thus, if the chain had maintained the chain of custody form, the same
of custody of evidence is challenged, the judge is also sometimes produced in the Court. The chain
may ask for evidence to show maintenance of the of custody form prepared in FSLs for tracking of
chain of custody before the evidence is considered. exhibits is also produced in the Court. Witnesses
Evidence Act does mention the "proper custody" are examined to prove these documents as well as
requirements regarding the production of certain to adduce additional evidence to confirm the
documents as well as electronic documents. As per maintenance of the chain of custody. A sample seal
the explanation to section 90 of the Evidence Act is also sent to the Court for comparison, while the
"proper custody" means documents being in their actual brass seal is required to be produced at the
natural place and custody. Further, custody is not time of trial.
considered to be "improper" if it had a legitimate
Certain special statutes such as the Narcotic Drugs
origin or, based on the circumstances of a particular
and Psychotropic Substances Act, 1985 (NDPS
case, an origin which is probable. Analogous
Act), have stipulated specific search and seizure
provisions have been proposed in the Bharatiya
Sakshya (Second) Sanhita Bill, 2023. Additionally, requirements to ensure the authenticity of the
explanation 5 to clause 57 of the proposed bill seizure. Section 55 of the NDPS Act provides that
states, "where an electronic or digital record is all articles seized under NDPS shall be under the
produced from proper custody, such electronic and safe custody of the officer-in-charge of a police
digital record is primary evidence unless it is station in duly sealed condition till orders of the
disputed." Apparently the concept of "proper Magistrate are obtained. If any samples are taken,
custody" of documents cannot be equated with the same shall also be sealed. Further, section 57
"chain of custody" of physical evidence which prescribes mandatory intimation to departmental
requires stricter proof for evidence integrity. The superiors within 48 hours of the seizure.
reliability or credibility of physical evidence is Judiciary's view
decided after applying judicial mind based on the
overall facts and circumstances of the case. This Since the chain of custody is vital for the
may be contrasted with the position in the United admissibility of evidence, defence always
States, where Federal Evidence Rule 901 (and its endeavours to challenge the chain of custody
state adaptations) clearly stipulate the requirements during criminal trials and thereby create doubt over
of authentication or identification of an item of the integrity of evidence. A quick survey of
evidence as a condition precedent for admissibility, jurisprudence on this subject in India reveals that
which makes requirement of an unbroken chain of the Supreme Court and High Courts have delineated
custody implicit. the need to maintain the chain of custody in several
judgments, and questions on the chain of custody
In practice, courts in India usually do not insist on are now being increasingly raised in courts.
any formal chain of custody form, as is the case in
several Western jurisdictions. Instead, chain of A missing link in the chain of custody can result in
custody is examined both on the basis of documents the inadmissibility of crucial evidence and resultant
and statements of witnesses. During the trial station acquittal. Chain of custody may be treated as broken
diary/general diary, Malkhana (store room)/ in case of lack of proper documentation,
Property register, Receipt/dispatch register, road discrepancy in different documents, lack of proper

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seal, inconsistency between statements of (ii) Designating a nodal officer for each storage
witnesses or gaps in the statements over movement facility
of seized object etc. Ordinarily, the chain of custody
(iii) Taking other steps for compliance to
is presumed to have been maintained if the details
of an exhibit on the seizure list are correctly Standing order no. 1/89 issued by Govt. of
mentioned, the seal is intact, and any opening/ India under section 52A of the NDPS Act
handling of the exhibit in a laboratory has been In Okafor Chukwuka Ugochukwu and anr. vs.
documented. This view is aided by the Explanation Narcotics Control Bureau (2020), Delhi High Court
"f" to Section 114 of the Evidence Act according to while hearing an appeal in an NDPS case pertaining
which the Court may presume that common course to the seizure of 1.78 kilograms of cocaine, acquitted
of business has been followed in a case. Even two foreign nationals due to doubts on the chain
though it can be argued that the Higher Judiciary of custody. The Court observed that: "…It is well
in India has generally not insisted on rigorous settled that the prosecution is required to establish
formal/documentary proof of chain of custody (see the complete chain as to the movement of the sample
Supreme Court rulings in Mustak @ Kanio Ahmed in order to establish that the same had remained
Shaikh vs. State of Gujarat and Shatrughna Baban intact..."
Meshram vs. State of Maharashtra), failure to In Ashit Biswas vs. State of West Bengal, Calcutta
maintain proper chain of custody is emerging as High Court, while setting aside the conviction of
one of the reasons behind acquittal in several cases. an accused under the NDPS Act, held that the
In Malaichamy and anr. vs. State of Tamil Nadu, discrepancies in the statement of witnesses
the Supreme Court declined to consider the seizure regarding the chain of seized articles "clearly snap
of offending articles which were not kept under the link before the articles seized at the spot and
seal by the I.O. those produced in Court during trial, rendering
In particular, the chain of custody-related issues the prosecution case wholly unreliable."
have been critically examined in connection with Delhi High Court in Vinay Kumar vs. State (N.C.T.
NDPS Act cases and cases involving biological of Delhi) held that the concept of chain of custody
evidence in India. Higher scrutiny in NDPS Act needs to be established in case of biological
cases is imperative since exclusive and conscious evidence. The Court defined "chain of custody" as
possession of contraband is a primary requirement "the complete record of biological evidence from
for holding the accused guilty of an offence of the place of its extraction and up to its
possession under the NDPS Act which prescribes presentation in the Court and its complete
stringent penalties. On the other hand, biological documentation at every stage."
evidence (particularly trace evidence like D.N.A.)
In Prakash Nishad vs. State of Maharashtra,
is highly susceptible to contamination and
Supreme Court, while acquitting an accused of rape
manipulation. In Union of India vs. Mohanlal and probably for the first time has elaborately dealt with
Ors., Supreme Court, inter-alia, issued directions the concept of chain of custody. The Court, while
to both Central Government and State Governments referring to Guidelines for collection, storage and
for dealing with seizure in NDPS Act cases: transportation of Crime Scene DNA samples for
(i) Setting up of storage facilities with vaults Investigating Officers developed by Central
having double locking system for the Forensic Science Laboratory, Chandigarh, remarked
exclusive storage of drugs and conveyances that "a chain of custody document in other words
seized under the NDPS Act to prevent theft, is a document which should include name or
pilferage or replacement initials of the individual collecting the evidence,

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each person or entity subsequently having custody (ii) Chain of custody record (e.g., signature, date,
of it, dated the items were collected or transferred, time, description of evidence) must be
agency and case number, victim's or suspect's name maintained to record a comprehensive history
and the brief description of the item." The of each evidence transfer.
judgement indicates growing appreciation of the
importance of an unbroken chain of custody by (iii) Unique case identifier shall be given to each
the Courts. individual item of evidence.

Chain of custody in forensic science laboratories Similarly, International Standard Organization (ISO)
standard ISO/IEC 17025 - General Requirements for
Maintenance of the chain of custody of seized the Competence of Testing and Calibration
objects received in an F.S.L. is equally imperative laboratories prescribes, inter-alia, following two
as the object or sample is handled for forensic critical guidelines for laboratories under the
examination by forensic examiners. FSLs commonly heading of "Handling of test or calibration items":
use Laboratory Information Management System
to manage the chain of custody. Chain of custody (i) Specifying procedure for the transportation,
documentation in a laboratory is required to contain receipt, handling, protection, storage,
the following details: retention, disposal or return of test items
(i) Location of the sample in the laboratory including provisions for protecting the
integrity of items. Adequate precautions
(ii) The current custodian of the sample should be taken to prevent deterioration,
(iii) Time and date of movements contamination, loss or damage to the item at
(iv) Previous location of sample any stage of examination or storage.

(v) Previous custodian of the sample (ii) Ensuring unambiguous identification of items
both physically as well as in records.
Laboratories are required to track the location of
the object within the laboratory. Apart from manual Few forensic science/testing laboratories in India
records, laboratories having automation can also have NABL accreditation or ISO certification.
track the movement through different systems However, there is a need to specify minimum
which can be - (i) sample-based (logging each standards for F.S.L.s to ensure the integrity of
movement of the sample in the system), (ii) location- evidence. Notably, the scheme for notifying the
based (e.g., by using RFID scanners at each step Examiner of Electronic Evidence under 79A of
of the transfer of object) or (iii) container-based Information Technology Act, 2000 (I.T. Act)
(sample is moved in a container with a unique mandates compliance with ISO/IEC standards for
identifier). Several proprietary products are also certification.
available for this purpose. Malkhana management system suggested by
National Accreditation Board for Testing and BPR&D and chain of custody
Calibration Laboratories's (NABL) document 113
The Malkhana Management System project report
on "Specific Criteria for Accreditation of Forensic
prepared by the Bureau of Police Research &
Science Laboratories" stipulates the following
Development (BPR&D), Govt. of India covers
requirements for chain of custody under the
aspects of chain of custody, safe and secure storage
heading of "Evidence Management":
of seized/ gathered evidence and timely disposal
(i) F.S.L. must have a documented system for as per law. The report broadly suggested the
evidence control to ensure and document the following measures to ensure the integrity of
integrity of physical evidence evidence:

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(i) Recording of proper identification details of custody is compromised, no credence can be

seized property attached to the evidence arising out of an
examination of seizure or sample in any legal
(ii) Use of compactors for storage keeping proceedings.
records, documents and small articles,
ISO 22095: 2020 Chain of custody: General
(iii) Creation of a database for indexing of terminology and models—prescribes standards on
Malkhana articles/ documents, implementing chain of custody in a supply chain,
which can be used "by any organisation operating
(iv) Computer-coded identification of seizure,
at any step in a supply chain, as well as by standard
Automated identification and Data Capture setting organisations as a reference point for
Technologies through the use of (i) bar codes specific chain of custody standards."
(linear or 2D), (ii) Quick response (QR) code
(similar to 2D bar code) or (iii) RFID (Radio- Chain of custody of electronic evidence
frequency Identification) The acquisition and processing of electronic
evidence are also obligated to adhere to the rigorous
(v) Heightened security for sensitive and
chain of custody requirements. Section 65B of the
valuable items such as double key vaults and Evidence Act contains provisions regarding the
use of motion-activated video cameras within admissibility of electronic evidence In Arjun
the Malkhana as well as within the firearms, Panditrao Khotkar vs. Kailash Kushanrao
narcotics, cash/jewellery vaults, etc. Gorantyal, where the validity and scope of the
(vi) Security of electronic gadgets from magnetic section were in question, a three-judge bench of
Supreme Court, inter-alia, suggested for "framing
tampering.
suitable rules for the retention of data involved in
Several police organisations have implemented trial of offences, their segregation, rules of chain
Malkhana Management Systems in different forms. of custody, stamping and record maintenance, for
Software programmes such as e-Malkhana are also the entire duration of trials and appeals, and also
in use for tracking and recording maintenance of in regard to preservation of the meta data to avoid
seized properties. The BPR&D project specifically corruption." As mentioned earlier, the proposed
discussed the practices followed in Central Bureau BNSS 2023 bill provides for submitting details of
of Investigation (CBI) and Andhra Pradesh Police. the sequence of custody of electronic custody at
It could act as a good model for management of the time of filing of report in final form by police to
properties seized by police. the Court. Technical details of the handling of
electronic evidence are beyond the scope of this
Chain of custody in non-criminal matters
article. It would suffice to state here that the
Maintenance of chain of custody of a seizure or vulnerability of digital data at all stages of collection
sample is also a legal requirement for integrity of and analysis is increasing with advancements in
evidence in non-criminal litigations. Some examples computational technology, hence, a clearly defined
of such proceedings are - (i) Dope testing of chain of custody is required to avoid allegations of
athletes, (ii) Quality control testing of food items, mishandling or tampering with digital evidence. A
and (iii) Environmental sampling for pollution distributed ledger system of Blockchain technology
monitoring. The basic principles of chain of custody is one such advanced method suggested to create
in these situations remain the same - to ensure that a fool proof chain of custody for electronic
the seized object is handled only by the authorised evidence. Under the Scheme for Notifying Examiner
persons for specified purposes and that each of Electronic Evidence under section 79A of the
handling is adequately documented. If the chain of I.T. Act, detailed guidelines, including compliance

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to ISO/IEC standards, have been provided for conclusion of the trial. If video recording
laboratory certification. cannot be done, cogent reasons thereof shall
be recorded in the case diary. Supreme Court
Ethical aspects
has already issued extensive directions with
Conscientious handling of evidence is required to regard to videography of crime scene and
prevent tampering. Apart from the legal and capacity building in that regard in Shafi
professional responsibilities, the issue of Mohammad vs. State of Himachal Pradesh.
maintenance of chain of custody is also an Calcutta High Court has recently ordered
important ethical issue. No amount of mandatory videography of all seizures of
documentation per se can prevent tampering or "commercial quantity" under the NDPS Act.
planting of evidence unless sound ethical practices Clause 105 of the proposed BNSS also
are promoted within investigative agencies and prescribes audio-visual recording of search
forensic institutions. Procedures dealing with chain and seizure proceedings.
of custody should not only ensure the legal  Seizure should be done in the presence of
necessity of chronological and logical independent witnesses. Police witnesses
documentation but should also adhere to principles can only be mentioned in the seizure list as a
of transparency and fairness. Instances of wilful last resort. In case of large objects/quantity,
tampering of evidence, planting of evidence, change due intimation should be given.
of sample etc. are reported from time to time. These
instances warrant exemplary legal and departmental  Tamper-evident/tamper-resistant packaging
action against the erring officials to act as a should be done as far as possible. Proper
deterrent. Apart from bolstering the prosecution's labelling and sealing of seized objects shall
case, maintenance of the chain of custody also plays be done at the place of seizure itself.
a pivotal role in protecting the rights of the accused.  Use of computer-assisted systems such as
The criminal justice system, which presumes the bar code/QR code or RFID for tracking the
accused to be innocent till proven guilty, is designed movement of exhibits in police stations
to ensure a fair and impartial trial, and a transparent Malkhanas/store rooms and FSLs is highly
chain of custody contributes to this objective. recommended.
Accurate documentation and handling of evidence  Seized articles should be produced before
prevent the possibility of planting, tampering or the concerned Magistrate as soon as
contamination of the evidence. possible, preferably within the next 24 hours.
Suggested guidelines  Entries in chain of custody forms should
Considering the paramount importance of chain of correspond to entries in the Malkhana
custody for evidence integrity, the following register, station diary, correspondence
suggestions can be considered by police and registers and other relevant documents.
forensic examiners for improving the maintenance  If the seized article has been weighed,
of chain of custody- measured or valued before the seizure, the
statement of the concerned person doing
For police officers
weight measurement or valuation should
 Scene of crime should be secured with always be recorded.
rigorous access control and strict need-  In the case of biological evidence, item (e.g.,
based entry and exit. blood, semen, tissue) type-based specific
 Seizure proceedings shall be video recorded guidelines should be strictly followed for
and recordings shall be preserved till the collecting and preserving evidence.

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 Seized objects should be preserved in such facilities. In Shafi Muhammad (supra), the
a manner so as to allow the provision of re- Supreme Court has already issued guidelines
testing/re-examination. In case of samples for installing CCTVs in police stations.
drawn for examination, both test and control
 During inspection of Malkhanas by superior
samples shall be drawn in at least duplicate.
police officers, an audit of chain of custody
 An exhibit should be opened minimum of exhibits should also be conducted to
number of times and once sealed, the seal check the integrity of evidence.
should be removed only with the permission
 Training of police officers on the importance
of the Court under proper documentation.
and methods of chain of custody should be
 Care should be taken in recording the regularly imparted and given due weightage
statements of formal witnesses who are likely in training courses on investigation.
to be examined over the chain of custody
 Chain of custody forms of police must be
during trial. Statements should correspond
mandatorily produced along with any exhibit
to entries in relevant records and be
produced in Court at the time of filing of
chronologically and logically consistent.
report in final form (charge-sheet/closure).
 CCTVs shall be installed in Malkhanas with A simplified model form of chain of custody
at least 18 months of storage backup for police officers is presented in figure 1.

Figure1: Model form of chain of custody for police

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For FSLs scene without proper documentation. This lacuna

formed one of the grounds for the acquittal of O.J.
 FSLs should develop ISO-compliant
Simpson as the jury discarded the blood evidence
protocols for handling and examining
linking Simpson to the crime scene. In a robust
exhibits. The protocol should include
criminal justice system, the unbroken chain of
guidelines for evidence collection,
custody is a cornerstone in building a credible case.
packaging, labelling, storage, transportation
With the increasing application of forensic
and transfer of custody of items
examination in the investigation of crimes, Indian
 Rigorous documentation of the custody at courtrooms are likely to witness more nuanced
each stage should be part of the protocol. arguments over the chain of custody in the coming
This documentation should include precise days. Therefore, the police and the forensic
details of the date and time of each transfer, community in India must prepare themselves for
the names and signatures of individuals higher standards of scrutiny in handling and
involved in handling and any other relevant producing physical evidence. In fact, as a note of
observations. caution, compliance with improved chain of custody
standards is a must before promoting techniques
 Provisions should be kept for repeat
like trace forensics to avoid a travesty of justice. A
examination by preserving a part of the
proper chain of custody safeguards the scientific
sample without destroying the entire sample,
and forensic validity of the evidence, providing a
as far as technically feasible.
solid foundation for the conclusions drawn from
 FSLs should conduct regular internal audits its analysis.
and quality assurance checks to review the
adherence to the chain of custody protocols. References
This helps identify any deviations or 1. Al-Khateeb H., Epiphaniou G. and Daly H.
vulnerabilities in the system so that (2019). Blockchain for modern digital
appropriate corrective measures can be forensics: The chain-of-custody as a
taken. distributed ledger. In Blockchain and
 FSLs should critically review all instances Clinical Trial (pp. 149-168). Springer Cham.
of a break in the chain of custody to identify 2. Arjun Panditrao Khotkar vs. Kailash
defaulters. Kushanrao Gorantyal, 2020 SCC OnLine SC
571
 Chain of custody forms of FSLs must be
mandatorily produced along with any exhibit 3. Ashit Biswas vs. State of West Bengal AIR
produced in Court. Online 2019 Cal 753 ::2020 Cri LJ (NOC) 126
Conclusion 4. Badiye A., Kapoor N. and Menezes R. G.
(2021). Chain of custody. StatPearls
Ensuring the integrity of evidence is at the core of
Publishing.
the entire investigative process. Hence, the
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U.S. (1994-95), one of the critical arguments raised Ostrom B. (2013). The Biological Evidence
by the defence pertained to the chain of custody. preservation handbook: Best Practices for
The defence posited that several police officers had Evidence Handlers.
handled blood samples collected from the crime

July-December 2023 53
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6. Dershowitz A. M. (1997). Reasonable doubts: 16. National Accreditation Board for Testing and
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Simpson case. Simon and Schuster. for accreditation of forensic science
7. Evans M. M. and Stagner P. A. (2003). laboratories and checklist for assessors.
Maintaining the chain of custody evidence 17. Okafor Chukwuka Ugochukwu and Anr. vs.
handling in forensic cases. AORN journal, Narcotics Control Bureau (2020). Indlaw DEL
78(4), 563-569 1064
8. Giannelli P. C. (1982). Chain of custody and 18. Order dated 22.06.2022 passed by Calcutta
the handling of real evidence. Am. Crim. L. High Court in C.R.M. (NDPS) 492 of 2022
Rev., 20, 527. with C.R.M. (NDPS) 493 of 2011.
9. Giannelli P. (1996). Forensic Science: Chain 19. Prakash Nishad @ Kewat @ Kewat Zinak
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