Open Access Research Article
White Black Legal – International Law Journal · ISSN 2581-8503
FROM CRIME SCENE TO COURTROOM: THE ROLE OF FORENSIC EVIDENCE UNDER THE BNSS, 2023
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Abstract
FROM
CRIME SCENE TO COURTROOM: THE ROLE OF FORENSIC EVIDENCE UNDER THE BNSS, 2023
AUTHORED
BY – VEDSHREE DILIP SHEVANTE
Institution
– Shree L.R. Tiwari College of Law
Academic
Year – 5th year BA.LL.B. (2026–2027)
ABSTRACT
Forensic
science offers scientific techniques for locating, gathering, analyzing, and
assessing evidence, it has grown to be a crucial component of criminal
investigations. The Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS) gives this
role greater statutory recognition, particularly through Section 176(3), which
provides for forensic examination and videography of crime scenes in specified
serious offenses. This research examines the role of forensic evidence under
the BNSS 2023 and traces its journey from the crime scene to the courtroom.
With special attention to contamination and chain of custody, it emphasizes the
importance of correctly identifying, gathering, preserving, transporting, and
examining forensic material. The study also examines the relationship between
forensic investigation under the BNSS and the evidentiary framework under the
Bharatiya Sakshya Adhiniyam, 2023, including expert opinion, Evidence of the
DNA and also the electronic evidence. Through judicial decisions, this research
study highlights that scientific evidence cannot be treated as automatically
conclusive and that its reliability depends upon the method of examination,
integrity of samples, proper documentation and judicial scrutiny. The study
further deals with practical challenges such as shortages of trained forensic
personnel, laboratory capacity, delays, rural- urban disparities and quality
control requirements. It concludes that the effectiveness of forensic reform
under the BNSS depends not specifically on statutory requirements but on
adequate infrastructure, trained manpower, reliable procedures, proper chain of
custody and fair judicial evaluation of scientific evidence.
Keywords:
Forensic Science, Bharatiya Nagarik Suraksha Sanhita, 2023, Section 176(3),
Investigation, Scientific Evidence.
INTRODUCTION
The
use of forensic science in contemporary criminal investigations and the
administration of justice has grown in significance. It enables investigators
and courts to examine physical and scientific evidence through systematic
methods of collection, preservation, examination and analysis. Unlike
Traditional evidence systems that depended entirely upon human recollection or
observation. Properly collected forensic evidence can provide objective
information capable of establishing connections between a crime scene, the
circumstances of an offence and the individuals involved. Its significance
becomes particularly evident in serious offences where identification of the
offender, reconstruction of events and preservation of reliable evidence are
essential to a fair criminal process.
Forensic Investigation is the basic investigation and is commonly
associated with Edmond Locard’s Exchange Principle: “Every contact leaves a
trace”[1].
The principle reflects the idea that interaction between a person, object and
environment may result in the transfer or creation of material traces capable
of assisting an investigation. Such traces may include fingerprints, biological
material, DNA, fibres, impressions and other physical or digital evidence.
However, the evidentiary value of such material depends not merely upon its
discovery, but upon its proper identification, collection, preservation,
documentation, examination and presentation. Any contamination, alteration or
improper handling at an early stage may affect the reliability and subsequent
use of the evidence.
As
forensic science has evolved over time, it has helped make criminal
investigations more scientifically grounded. Traditional investigations have
often relied on subjective evidence, such as eyewitness accounts, statements,
confessions and investigative observation. Scientific methods provide an
additional means of testing and corroborating facts through objective evidence
that can be examined using established techniques. This does not mean that
forensic evidence is infallible or that scientific investigation can replace
all other forms of evidence. Rather, its importance lies in providing
investigators and courts with an additional, systematic and verifiable basis
for understanding the circumstances surrounding an offence. Traditional methods may be vulnerable
to error or manipulation, particularly where investigations depend heavily on
eyewitness testimony and human recollection. Scientific investigation, on the
other hand, involves evidence that is systematically collected, documented,
preserved, and analysed before being presented. This provides a more objective
and verifiable basis for understanding the facts of a case. The evolution from
traditional to scientific investigation signifies a change in the direction of
making sure that evidence is thoroughly investigated, confirmed, recorded, and
backed by scientific techniques so that it can be evaluated objectively. It
represents a shift towards ensuring that evidence is properly examined,
verified, documented, and supported by scientific methods so that it can be
objectively assessed.
This
changing approach has received significant statutory recognition under the
Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS)[2]
which replaced the Code of Criminal Procedure, 1973[3],
subject to the statutory exception indicated in the commencement notification.
The growing importance of technologically and scientifically supported evidence
in the criminal justice system is reflected in the BNSS's numerous provisions
pertaining to the use of technology and scientific procedures in criminal
investigations. Among these provisions, Section 176(3) of the BNSS[4]
acquires particular weight. In cases involving offences carrying a sentence of
seven years or more in prison, the provision establishes a statutory duty for
forensic inspection and videography of the crime scene. The provision is
significant because it seeks to move forensic investigation beyond merely discretionary
or occasional reliance and towards a more structured role within the
investigation of serious offences. The emphasis on crime-scene examination and
documentation also recognises that evidence may be lost, contaminated or
altered if it is not identified and preserved at the earliest stage of an
investigation.
The
introduction of a statutory forensic mandate, however, raises several practical
and legal questions. The effectiveness of Section 176(3) cannot be determined
solely by the existence of the statutory requirement. The availability of
qualified forensic specialists, well-equipped forensic labs, suitable
crime-scene infrastructure, prompt sample collection and transportation, upkeep
of the chain of custody, technological capability for videography, and
efficient coordination between investigating officers and forensic institutions
are all necessary for its implementation. Differences in infrastructure and
institutional capacity may also affect the uniform implementation of the
provision across jurisdictions. Consequently, there exists a need to examine
whether the statutory recognition of forensic investigation under the BNSS can
effectively translate into reliable, timely and scientifically sound criminal
investigation in practice. The issue is also closely connected with the broader
objective of a fair criminal justice system. Forensic evidence can assist not
only in establishing the involvement of an accused but also in excluding
individuals who are not connected with the offence. Its proper use may
therefore contribute to both effective investigation and protection against
erroneous implication. At the same time, over-reliance upon scientific evidence
without adequate standards of collection, preservation, interpretation and
judicial scrutiny may create its own evidentiary concerns. The legal framework must
therefore balance the advantages of scientific investigation with procedural
safeguards and reliability standards.
In
light of this, this study investigates the function and application of forensic
investigation in accordance with Section 176(3) of the Bharatiya Nagarik
Suraksha Sanhita, 2023. It seeks to analyse the extent to which the provision
strengthens science-based criminal investigation, the procedural and
infrastructural challenges associated with its implementation, and the
safeguards necessary to ensure the reliability and evidentiary value of
forensic material. The study further considers whether the statutory mandate
represents a meaningful transformation in criminal investigation or whether its
effectiveness ultimately depends upon the institutional capacity available to
implement it.
RESEARCH
GAP
Forensic
science and scientific investigation have been given more weight in the
Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), especially in light of Section
176(3), which permits forensic examination and videography of the crime-scene
investigation in some significant offenses. However, existing discussions
largely focus on the importance of this provision and the shift from
traditional investigation towards scientific investigation. The entire path of
forensic evidence from the crime scene to the courtroom has received relatively
little attention. The value of forensic evidence depends on both the accuracy
of scientific testing and the proper handling of the evidence throughout the
investigation. Therefore, issues relating to chain of custody, crime-scene
videography and the consequences of improper handling of evidence require
further examination. The entire process of forensic evidence from the crime
scene to the courtroom has received relatively little attention. The
evidentiary value of forensic evidence may be impacted by gaps or abnormalities
in the chain of custody, which must also be understood by courts.
Another
area requiring attention is the increasing use of digital and cloud-based
evidence. Modern investigations may involve evidence stored on mobile phones,
computers, servers and cloud platforms. Questions may arise regarding its
collection, preservation, authentication, encryption and protection from
alteration or deletion. The link between the investigation requirements under
the BNSS and the evidentiary framework for electronic and digital documents
under the Bharatiya Sakshya Adhiniyam, 2023 (BSA) hence warrants more analysis.
The
practical implementation of forensic investigation also depends upon the
availability of trained forensic experts, properly equipped laboratories and
reliable quality-control procedures. The accused must, however, be given a fair
chance to contest forensic evidence and, if needed, request independent
testing. The manner in which Courts deal with conflicting, incomplete or
unreliable forensic opinions is another important area that requires
consideration.
Therefore,
the research gap lies in examining whether the BNSS has created an effective
and reliable forensic-investigation framework, rather than merely imposing a
procedural requirement. This study seeks to examine the entire evidentiary
pathway from crime-scene collection and preservation to forensic analysis and
courtroom evaluation, with particular focus on chain of custody, videography,
digital evidence, laboratory standards, defence access and judicial evaluation
of forensic evidence.
RESEARCH
QUESTIONS
The
following queries serve as the foundation for the study:
1. In
what ways has the BNSS, 2023 altered the function of forensic science in
criminal investigations?
2. What
does the BNSS's Section 176(3) mean?
3. What
precautions must be taken to guarantee that evidence gathered from a crime
scene is trustworthy until it is presented in court?
4. What are the principal infrastructural and
institutional difficulties faced by forensic laboratories in India?
5. How
should Courts evaluate forensic and expert evidence?
6. What
is the legal situation if Section 176(3)'s required forensic procedure is not
carried out?
7. What
reforms are necessary to ensure effective implementation of scientific
investigation under the BNSS?
RESEARCH
METHODOLOGY
The
current study takes an analytical and doctrinal stance. It is based on a
systematic study of statutory provisions, judicial decisions, Government
reports, parliamentary materials, official forensic policy documents, and
relevant secondary sources such as books, research articles, legal journals,
and academic literature. These sources are used to understand the existing
legal framework, identify practical challenges, and analyse the role of
forensic investigation under the BNSS, 2023.
The
Bharatiya Sakshya Adhiniyam, 2023 (BSA) and the Bharatiya Nagarik Suraksha
Sanhita, 2023 (BNSS) are the main legal sources taken into consideration in
this study. To comprehend the changing legal situation regarding forensic
evidence, pertinent court rulings pertaining to expert opinion, DNA evidence,
scientific investigation, electronic evidence, and the maintenance of the chain
of custody have also been reviewed.
Government
and institutional sources have been consulted to assess the practical framework
for forensic investigation, particularly with regard to forensic laboratories,
trained personnel, technological infrastructure, mobile forensic facilities,
and ongoing reforms. These materials also show ongoing efforts to improve
forensic infrastructure in response to the heightened demands brought about by
the new criminal statutes.
The
study is not based on a primary field survey. Its findings and observations are
drawn from the available statutory, judicial, governmental, institutional, and
academic sources and are analysed in the context of the objectives of the
research.
OBJECTIVES
OF THE STUDY
The
objectives of this research paper are –
1. To
analyse the role forensic science plays in the administration of justice.
2. To
examine the BNSS, 2023 legal framework pertaining to forensic evidence.
3. To
examine the challenges in the case of crime scene contamination and improper collection
and handling of evidence.
4. To
study the validity and admissibility of forensic evidence used in court.
5. To
investigate how forensic science aids in the administration of justice by
connecting evidence to the commission of a crime.
6. To
examine the shortage of forensic experts, laboratory infrastructure and
forensic capacity in India.
7. To
identify practical problems relating to crime-scene management, preservation
and chain of custody.
HYPOTHESIS
The
research proceeds on the hypothesis that:
"By
institutionalising scientific evidence collection, Section 176(3) of the BNSS,
2023 has the potential to transform criminal investigation; however, its
effectiveness depends upon adequate forensic infrastructure, trained manpower,
strict chain-of-custody procedures, scientific quality control, and clear
judicial standards for evaluating forensic evidence."
LEGAL
FRAMEWORK UNDER BNSS, 2023
Section
176[5]
deals generally with the procedure that police must follow while investigating
an offence. Section 176(3)[6] is
a new sub-section and is particularly important for scientific investigation,
as it adds a specific forensic requirement for serious offences. The provision
says that a police officer must arrange for a forensic expert to attend the
crime scene and gather forensic evidence when they get information about an
offense carrying a sentence of seven years or more in prison. Additionally, the
process must be recorded through electronic means.
“The
officer in charge shall cause the forensic expert to visit the crime scene”
This
puts the onus of scheduling the forensic expert's visit to the crime site on
the officer in charge of the police station. The police officer is not expected
to personally perform every scientific examination. The forensic specialist
helps by carefully and scientifically analysing and gathering evidence from the
crime site while the police handle the overall investigation.
This
is why Section 176(3) should not be understood as replacing ordinary police
investigation with forensic investigation. It is intended to integrate forensic
science into the investigation. The BNSS's Section 176(3) signifies a change
from a predominantly arbitrary approach to forensic investigation to a system
that is both legally recognised and organised. In accordance with Section 157[7] of
the CrPC, there was no such legal obligation to guarantee the presence of a
forensic expert at the crime scene for offences carrying a specific degree of
penalty. The BNSS therefore gives greater importance to the scientific
collection and preservation of evidence.
However,
additional clarification is needed about the application of Section 176(3). The
provision does not mean that forensic experts are required to visit crime
scenes across the entire country from 1 July 2024. Rather, it stipulates that
the requirement will take effect within five years on a date announced by the
relevant State Government. For example, Rajasthan issued a notification under
Section 176(3) on October 7, 2024, according to the Bureau of Police Research
and Development's State notification table.
Therefore,
Section 176(3) establishes a national statutory framework for forensic
investigation, while its actual implementation depends on State-level
notifications, availability of forensic resources, and the necessary
institutional arrangements.
Why
does Section 176(3) require videography?
This
is the second major requirement in forensic evidence. As previously mentioned,
the legislation mandates that a cell phone or other electronic device be used
to record the process of gathering forensic evidence. The integrity and
authenticity of the crime scene are significantly protected by videography. It
creates a contemporaneous visual record of the scene, preserving its original
condition and documenting the manner in which forensic evidence is identified,
collected, handled, sealed and preserved. To give a more accurate picture of
the conditions under which the evidence was obtained, it may additionally
record the surrounding area as well as the location and state of pertinent
objects and evidence. Such documentation reduces the scope for subsequent
manipulation, alteration or dispute regarding the handling of evidence. It also
makes it possible for the court and the investigative authorities to later
assess how the crime scene was investigated and if the forensic team followed
the guidelines. Therefore, videography strengthens transparency, accountability
and evidentiary integrity in the investigation process.
AUDIO-VIDEO
DOCUMENTATION
Section
176(3) is not restricted to physical collection of evidence. It also requires
videography of the collection process.
This
requirement is supported by the wider approach of the BNSS. Section 105 of the
BNSS[8] stipulates
that audio-video electronic recordings of the search and seizure procedures,
including the creation and signing of the seizure list, must be made. Section
185[9]
similarly provides for audio-video recording of searches conducted during
investigation.
These
provisions have significance beyond mere record keeping. Video documentation
can help establish:
A. The
state of the crime
B. The
location from which an article was recovered;
C. The
manner in which evidence was collected;
D. The
persons present during collection;
E. The
preparation and signing of seizure documentation; and
F. The
consistency between the findings at the site and the subsequent analysis.
BPR&D[10]
has developed a detailed Standard Operating Procedure dealing with crime-scene
audio-video recording, including photography, scene processing, storage and
transportation, documentation and chain of custody.
THE
LEGAL IMPLICATIONS OF NOT COMPLYING WITH BNSS SECTION 176(3)
Section
176(3)[11]
uses obligatory language: the police officer “shall” cause the forensic expert
to visit the crime scene
When
investigating major offences defined by Section 176(3) of the BNSS, the police
have a significant obligation to consult a forensic specialist. However, the
section does not specifically mention any separate punishment, fine, or
imprisonment for an officer who fails to comply with this requirement.
Even
though there is no specific punishment under Section 176(3), failure to follow
the provision can still affect the investigation. If a forensic expert does not
examine the crime scene or important evidence is not properly collected,
documented, or preserved, valuable evidence may be lost or become difficult to
rely upon later. This may also allow the defence to question the reliability
and proper handling of the evidence. The Court may therefore examine the
reasons for such non-compliance and consider whether it has affected the
investigation or the evidence presented before it. Nonetheless, the trial would
not automatically be declared invalid due to failure to comply with the
inquiry. The Court would take into account each case's specific facts as well
as how the non-compliance affected the available evidence. In addition, where
the failure is due to negligence or deliberate disregard of duty, the concerned
police officer may also face departmental or administrative action under the
applicable service rules.
As
a result, Section 176(3) is crucial for ensuring that scientific evidence is
correctly gathered and kept from the start, in addition to requiring the
involvement of forensic experts. The inquiry may be weakened and the forensic
evidence presented to the court may lose some of its evidentiary value if the
rule is not followed.
BHARATIYA
SAKSHYA ADHINIYAM, 2023 AND FORENSIC EVIDENCE
While
the Bharatiya Sakshya Adhiniyam, 2023, offers the legal foundation for deciding
how courts may utilise scientific and digital evidence (BSA)[12]
the BNSS primarily addresses the inquiry process.
1.
Expert Opinion is covered by Section 39 of the BSA
Section
39 of the BSA[13] It stipulates that the
opinion of an individual with specialized knowledge or expertise in a certain
subject becomes significant information when a court must make a decision on
issues pertaining to science, art, specialized fields, handwriting, or finger
impressions.
This
provision recognises that certain matters require specialised scientific or
technical knowledge which the Court may not possess. As a result, the Court can
better comprehend and assess such evidence with the help of the conclusions and
opinions of certified experts. The provision refers to the opinion of persons
who are “specially skilled” in the relevant field (Bharatiya Sakshya Adhiniyam,
2023, s. 39).
However,
expert evidence is not automatically accepted as conclusive proof. The Court is
still required to examine the expert’s opinion along with the other evidence
presented in the case.
In
State of Himachal Pradesh v. Jai Lal, (1999) 7 SCC 280[14],
the Supreme Court described expert evidence as being “of an advisory
character.” The Court explained that an expert’s opinion should assist the
Court in reaching its own conclusion rather than replace the Court’s
independent assessment. The reliability of such evidence depends on the reasons
given by the expert and the scientific data and material supporting the
opinion. This principle continues to be significant under the BSA. Forensic
evidence can provide valuable scientific assistance to the Court, but the final
assessment of the evidence remains with the Court. As a result, the Court must
take into account both the expert opinion and the case's overall facts and
circumstances.
2.
DNA Evidence: Powerful but Not Infallible
One
of the most important instruments in contemporary forensic investigation is DNA
analysis. It can assist in establishing a person's identity and identifying a
biological connection. However, how the sample is gathered, stored, analysed,
and interpreted has a significant impact on the validity and reliability of DNA
evidence.
The
State of Gujarat v. Kishanbhai[15]
case concerned a six-year-old girl who was raped and killed. The prosecution
case was mainly based on circumstantial evidence. The accused was convicted by
the trial court, but the High Court later acquitted him because there were
several gaps and weaknesses in the investigation and evidence. The matter then
reached the Supreme Court. The fact that the victim and the accused had the
same blood type (B positive) was a significant problem. The Supreme Court noted
that it was impossible to determine whether the victim's blood was genuinely on
the accused's clothing just because they shared the same blood group. The
investigating agency should have gone further and conducted DNA profiling. DNA
testing could have provided stronger scientific evidence about whether the
accused was connected with the crime.
Therefore,
the Supreme Court emphasized that investigating authorities should make
appropriate use of available scientific procedures rather than relying solely
on conventional methods of investigation, given the growth of forensic science.
FORENSIC
INFRASTRUCTURE AND THE IMPLEMENTATION OF BNSS
The
success of scientific investigation under the BNSS, 2023 depends not only on
what the law provides, but also on whether the necessary forensic facilities
are available when they are needed.
Since
the journey of forensic evidence starts at the crime scene, investigators must
have access to forensic support as soon as possible.
District
Forensic Science Laboratories (DFSLs), State Forensic Science Laboratories
(SFSLs), and Central Forensic Science Laboratories (CFSLs) are among the
various layers of laboratories that make up India's forensic system. These
facilities play an important role in examining and analysing evidence collected
during criminal investigations. District-level facilities can provide forensic
assistance closer to the crime scene, while State and Central laboratories
provide broader and more specialised forensic examination.
This
becomes more crucial in light of Section 176(3) of the BNSS, which mandates
that forensic professionals visit the crime site and gather forensic evidence
in certain major offenses after the provision is put into effect in the
relevant State. The provision can achieve its intended purpose only when
trained forensic personnel, suitable equipment, laboratories, and proper
transportation and preservation facilities are available.
In
practical terms, the effectiveness of forensic investigation depends on the
entire system working together. If a forensic team is unable to reach the crime
site in time, if a district does not have suitable forensic facilities, or if a
sample has to travel long distances without proper preservation, the quality
and reliability of the evidence may be impaired. Therefore, improving forensic
infrastructure is a crucial component of making Section 176(3) successful and
is not distinct from its execution.
The
existence of CFSLs, SFSLs and district-level forensic facilities shows the
importance of building forensic capacity at different levels. However, the real
objective should be to ensure that a person investigating a crime is able to
obtain appropriate scientific assistance when and where it is required. Only
then will the evidence gathered at the crime site be able to pass through the
forensic procedure in a safe and dependable manner and eventually make it to
the trial.
“WHAT
HAPPENS IF MANDATORY FORENSIC EXAMINATION IS NOT CONDUCTED?”
In
Dashwanth v. State of Tamil Nadu[16],
decided on 8 October 2025, the Supreme Court assessed significant holes in the
prosecution's case based on circumstantial evidence. The Court found that
important circumstances, including the “last seen together” theory, missing
CCTV footage, alleged planted recoveries, and the proper custody of DNA
samples, had not been satisfactorily established.
With
regard to the DNA evidence, the prosecution was unable to adequately
demonstrate the chain of custody of the samples from their collection. The
Court therefore questioned whether the integrity of the samples had been
sufficiently maintained. This affected the reliability that could be placed on
the scientific evidence.
The
case demonstrates that forensic evidence cannot be considered reliable merely
because a scientific report has been produced before the Court. Additionally,
the prosecution must be saved, transferred, sealed, examined, examined,
examined, and the prosecuted, preserved. Therefore, the evidentiary value of
forensic evidence may be diminished by a breach or unexplained gap in the chain
of custody.
THE
JOURNEY FROM CRIME SCENE TO COURTROOM
Stage
One: Identification of Forensic Evidence
The
method of identifying forensic evidence is the primary stage during the crime
investigation. Evidence may be present in different forms, depending on the
nature and circumstances of the crime. It may include:
A. Fingerprints;
B. Blood
And Other Bodily Fluids;
C. Other
Biological Materials;
D. Hair
And Fibres;
E. Weapons
And Ammunition;
F. Footprints
And Tool Marks;
G. Questioned
Or Disputed Documents;
H. Drugs,
Poisons and Other Substances;
I.
CCTV Footage;
J. Mobile
Phones and Computers;
K. Photographs
and Videos; And
L. Other
Forms of Trace Evidence.
When
forensic evidence is discovered, its relevance may not always be immediately
obvious. Material that may appear insignificant to an ordinary observer can
yield important information when examined using scientific and forensic
methods. t could establish a person's identification, connect them to a crime
scene, or offer further information pertinent to the inquiry.
Therefore,
the role of the first responder and crime-scene investigation team is extremely
important. The crime scene must be approached and handled carefully to prevent
potential evidence from being contaminated, altered, misplaced, or destroyed. A
careless or improper response at this initial stage may result in the permanent
loss of valuable evidence and may affect the subsequent investigation and
judicial proceedings.
Stage
Two: Documentation of the Crime Scene
Once
possible evidence has been identified, the crime scene must be properly
documented before the evidence is disturbed or removed. Documentation keeps a
physical record of the condition of the crime scene as it was found by the
investigating team.
The
scene may be documented through photographs, videos, notes, sketches,
measurements, and other appropriate records. The location and condition of the
evidence should be recorded carefully so that its original position and
surroundings can later be understood. Proper documentation also helps show how
the evidence was found and how the crime scene appeared before the
investigation altered it.
This
stage is important because the crime scene cannot remain unchanged forever. It
may be challenging to restore the scene to its former state once evidence has
been gathered or items have been relocated. A proper record therefore helps
preserve the scene for further investigation and for presentation before the
Court.
Stage
Three: Collection and Recovery of Evidence
After
the crime scene has been properly documented, the identified evidence is
carefully collected and recovered. The manner in which evidence is collected
depends upon its nature. Different sorts of evidence may require different
sorts of methods of handling, packaging, and preservation.
Biological
material, fingerprints, weapons, documents, digital devices, and other forms of
evidence must be handled with appropriate care. The objective is to collect the
evidence without damaging it or introducing anything that may affect its later
examination.
At
this stage, even a small mistake can affect the usefulness of the evidence.
Therefore, the investigating and forensic teams must follow the appropriate
procedures while collecting and packaging each item.
Stage
Four: Preservation and Chain of Custody
After
collection, the evidence must be properly preserved, and its movement must be
recorded. This is where the chain of custody becomes important. It means
keeping an accurate log of who gathered the evidence, how it was handled, where
it was kept, when it was moved, and when it arrived at the forensic lab.
From
the moment the evidence is gathered until it is analysed and presented in
court, the goal is to preserve its identity and integrity. Evidence can be
prevented from being lost, replaced, tainted, or tampered with by properly
sealing, labelling, storing, transporting, and documenting it.
Stage
Five: Transportation to the Forensic Laboratory
Once
the evidence has been collected, packaged, and preserved, it is transported to
the appropriate forensic laboratory for examination. The type of evidence may
determine the mode and circumstances of transportation.
During
transportation, the evidence must remain properly sealed and protected. As part
of the chain of custody, its movement should also be accurately recorded. Any
unexplained gap or irregularity in the movement of evidence may raise questions
about its identity or integrity.
Stage
Six: Scientific Examination and Analysis
Forensic
experts examine the material using appropriate scientific methods and
techniques depending upon the nature of the evidence. Different types of
evidence may require different forms of examination. For example, biological
material may be examined through DNA analysis, fingerprints may be compared for
identification, and questioned documents may be examined to determine their
authenticity or connection with a person. Other evidence may require techniques
such as microscopy, chromatography, ballistic examination, or digital forensic
analysis.
Stage
Seven: Preparation of the Forensic Report
After
completing the scientific examination, the forensic expert prepares a report
containing the findings of the examination. The report records the evidence
examined, the methods used, and the results obtained from the analysis. The
forensic report becomes an important link between the scientific examination
and the legal investigation. It communicates the scientific findings to the
investigating authorities and, where relevant, to the Court.
However,
a forensic report does not determine an accused person's guilt or innocence on
its own. Its findings form part of the evidence that must be considered along
with the other material available in the case.
Stage
Eight: Use of Forensic Evidence During Investigation
The
forensic examination's conclusions can then help the investigating authorities
comprehend the facts surrounding the crime. The results may help establish
connections between the crime scene, the victim, the accused, and other
relevant material.
Forensic
findings may also support or contradict other evidence collected during the
investigation. In this way, scientific evidence can help investigators form a
clearer understanding of what may have happened and how the different pieces of
evidence are connected.
Stage
Nine: Presentation Before the Court
The
final stage of the journey is the presentation and evaluation of forensic
evidence before the Court. Subject to the relevant legal requirements, the
forensic report and any pertinent data may be included in the evidence
presented to the court. Where necessary, the forensic expert may also be
required to explain the examination, methodology, and findings. The Court then
evaluates the forensic evidence along with the other evidence available in the
case.
The
Court does not simply accept scientific evidence because it comes from a
forensic laboratory. The relevance of the matter must be taken into
consideration. The parties may also raise questions regarding the collection,
preservation, chain of custody, examination, or interpretation of the evidence.
Stage
Ten: Judicial Evaluation of Forensic Evidence
The
journey of forensic evidence finally reaches its purpose when the Court
evaluates its evidentiary value while deciding the case. At this step, the
entire route of the evidence becomes relevant—from how it was recognized and
gathered at the crime scene, to how it was stored, transported, analyzed, and
presented before the Court.
Any
weakness at an earlier stage may affect the value attached to the evidence at
the final stage.
Only
when every step of this process is carefully managed and the evidence's
integrity is preserved from the crime scene to the courtroom, then it can contribute
to justice.
THE
COURTROOM: HOW SHOULD FORENSIC EVIDENCE BE EVALUATED?
A
forensic report does not bring the judicial process to an end. Instead, it
gives the Court scientific material that must be carefully examined before it
is relied upon.
The
Court may consider questions such as:
1. Who
conducted the forensic examination?
2. Was
the person properly qualified?
3. What
exactly was examined?
4. How
was the sample collected?
5. Was
it properly sealed and preserved?
6. Was
the chain of custody properly maintained?
7. What
method was used for the examination?
8. Was
the method scientifically accepted and properly applied?
9. Was
the possibility of contamination adequately addressed?
10. Does
the expert's conclusion agree with the other evidence available in the case?
The
Supreme Court's decision in State of Himachal Pradesh v. Jai Lal[17]
is important in this regard. The Court explained that expert evidence is mainly
advisory in nature. An expert assists the Court by providing specialised
scientific knowledge, but the final decision remains with the judge. The Court
must independently examine the reliability of the expert's opinion along with
the other evidence on record. Therefore, forensic evidence should not be viewed
in either of two extreme ways. It should not be rejected simply because it
involves technical or scientific concepts. At the same time, a forensic or
laboratory report should not be treated as automatically conclusive.
THE
RIGHT TO FAIR TRIAL AND FORENSIC EVIDENCE
The
accused must have a meaningful opportunity to understand and challenge the
scientific evidence used against them. This becomes particularly important in
cases involving complex forensic evidence because a scientific conclusion may
appear highly authoritative, while its reliability depends on how the evidence
was collected, examined, and interpreted.
For
example, when a DNA report is relied upon, the defence may need information
about:
1. The
Original Sample;
2. The
Method of Collection;
3. Laboratory
Records;
4. The
Testing Method Used;
5. Quality-Control
Procedures;
6. Possible
Contamination;
7. Interpretation
of the Results;
8. Statistical
Basis of The Conclusion;
9. Chain
Of Custody; And
10. Qualifications
of the Forensic Analyst.
The
Supreme Court's decisions relating to DNA evidence show that scientific
evidence is not beyond judicial scrutiny. In Pattu Rajan v. State of Tamil Nadu[18],
the Court recognised DNA evidence as opinion evidence and explained that its
evidentiary value depends upon the circumstances and other evidence in the
case.
Similarly,
in Manoj & Ors. v. State of Madhya Pradesh[19],
the When evaluating DNA evidence, the Supreme Court emphasized the significance
of appropriate testing protocols and contamination prevention.
Therefore,
as the use of forensic evidence increases under the modern criminal justice
system, the safeguards available to the accused must also remain strong.
Scientific investigation should help the Court discover the truth while
ensuring that the accused receives a fair opportunity to examine and challenge
the evidence relied upon against them.
DISTINCTION
BETWEEN CRPC AND BNSS
The
primary difference between the CrPC and the BNSS, with relation to forensic
science, is not that forensic evidence was wholly missing under the CrPC.
Forensic science was already used for purposes such as DNA examination, medical
examination, scientific analysis, and expert reports. However, the BNSS gives
forensic investigation a more structured role in the investigation process.
Because Section 176(3) of the BNSS mandates that a forensic expert visits the
crime scene and permits videography of the evidence-collection procedure in
applicable major offences, it is especially significant. This places greater
emphasis on scientific examination from the earliest stage of investigation.
The
BNSS also gives specific recognition to the custody of electronic devices
through Section 193(3)(i)[20],
which requires the police report to mention the sequence of custody of an
electronic device. This is particularly relevant in the present digital age,
where electronic evidence can easily be transferred, copied, altered, or
deleted. Therefore, the shift from the CrPC to the BNSS can be understood as a
move towards a more organised and technology-oriented approach to criminal
investigation. The BNSS gives forensic examination a more prominent and
organized role, especially at the crime scene and in the management of
electronic evidence. This reflects the increasing importance of scientific
methods in establishing facts and strengthening the reliability of criminal
investigations.
However,
the effectiveness of these provisions will depend not only on the statutory
framework but also on their proper implementation. Trained
forensic experts, adequate laboratories, proper chain-of-custody procedures,
quality control, timely forensic reports, and sufficient State-level
infrastructure are essential for achieving the purpose of these provisions.
Therefore,
the real significance of the BNSS lies not merely in giving forensic science
greater statutory recognition, but in creating a stronger connection between
the crime scene, scientific examination, and the courtroom. The effectiveness
of this approach will ultimately depend on whether forensic evidence is
properly collected, scientifically examined, carefully documented, and fairly
evaluated by the Court.
CHALLENGES
DURING FORENSIC SCIENCE INVESTIGATIONS
CHALLENGE
I: CRIME-SCENE CONTAMINATION AND IMPROPER COLLECTION
Maintaining
the crime scene in its original state is the first significant issue in
forensic inquiry. Numerous causes, such as the following, may cause the crime
scene's condition to be disrupted or changed:
A. Unnecessary
Movement of Objects;
B. Excessive
Handling of Evidence;
C. Entry
Of Unauthorised Persons;
D. Movement
or Disturbance of the Body and Surrounding Material;
E. Improper
Packaging of Exhibits;
F. Contact
Between Different Items of Evidence; And
G. Environmental
Factors Such as Heat, Moisture, Dust, or Rain.
Biological
evidence is particularly sensitive to contamination. In cases involving DNA
evidence, even minor contamination can affect the reliability and
interpretation of the scientific results. It may also create difficulties in
determining whose biological material was actually detected at the crime scene.
The
importance of preventing contamination is recognised not only in forensic
practice but also in judicial proceedings. The Supreme Court has emphasised the
need to maintain the quality and reliability of DNA testing and to take
appropriate measures to minimise the possibility of contamination.
The
BNSS, 2023 adopts a partly preventive approach to this issue. Section 176(3),
seeks to improve the professional examination and documentation of the crime
scene and the evidence found there.
However,
legislation alone cannot completely prevent contamination. Effective
crime-scene management also requires properly trained personnel, appropriate
protective equipment, standard operating procedures, and careful handling and
preservation of exhibits.
CHALLENGE
II: CHAIN OF CUSTODY
The
process may be broadly understood as:
A. Crime
Scene
B. Investigating
Officer
C. Evidence
Storage
D. Transport
E. FSL
F. Forensic
Analyst
G. Court
At
every stage, it should be possible to establish:
A. What
was collected?
B. Who
collected it?
C. When
was it collected?
D. How
was it sealed?
E. Where
was it stored?
F. Who
handled it?
G. When
was it sent to the laboratory?
H. Was
the seal intact when received?
I.
What examination was conducted?
The
defense may contest the identification, validity, and integrity of the evidence
if these queries are not adequately addressed.
This
is not merely a procedural concern. The Supreme Court has recently considered
whether the prosecution was able to prove an uninterrupted chain of custody and
if the integrity of forensic materials had been appropriately preserved. In
Pooranmal v. State of Rajasthan[21]The
Supreme Court emphasised how crucial it is to keep forensic samples in an
appropriate chain of custody. The Court observed that before relying on an FSL
or DNA report, the prosecution must show that the samples were properly
collected, sealed, preserved, and safely transferred to the laboratory. It must
also be established that the samples were not tampered with during this
process. The case demonstrates that forensic evidence's dependability is not
just dependent on laboratory-based scientific analysis. If the prosecution
cannot satisfactorily establish this chain, the reliability of the forensic
report may be questioned.
CHAIN
OF CUSTODY UNDER THE BNSS
The
BNSS has specifically recognised the importance of documenting the custody of
electronic devices. Section 193(3)(i) requires the police report to include:
“The
sequence of custody in case of electronic device.”
Bharatiya
Nagarik Suraksha Sanhita, 2023, Section 193(3)(i). This provision is
particularly significant because digital evidence can be copied, altered,
transferred, or deleted without leaving obvious physical signs. However, an
important legal issue remains. Section 193(3)(i) expressly refers to electronic
devices and does not provide a similarly detailed, single statutory framework
for every category of physical forensic evidence, such as blood samples, DNA
swabs, weapons, and trace evidence.
Therefore,
the integrity of physical evidence continues to depend significantly on
departmental procedures, laboratory protocols, proper documentation, and
general principles of evidence law. Further standardisation of procedures for
the collection, storage, transportation, and examination of physical forensic
evidence could therefore strengthen the forensic framework under the BNSS.
CHALLENGE
III: FORENSIC INFRASTRUCTURE AND SHORTAGE OF EXPERTS
A
major concern is whether India has sufficient forensic infrastructure and
trained personnel to meet the increased demands created by the new criminal
laws.
The
government stated in December 2024 that India had thirty-two State Forensic
Science Laboratories, ninety-seven Regional Forensic Science Laboratories, and
seven Central Forensic Science Laboratories, located at Chandigarh, Delhi,
Bhopal, Pune, Guwahati, Hyderabad, and Kolkata (oldest). The same Government
response acknowledged the need for additional infrastructure to address
shortages of trained personnel and the workload faced by forensic laboratories.
The
Government has introduced several measures to expand forensic infrastructure.
The National Forensic Infrastructure Enhancement Scheme (NFIES) has a total
outlay of ₹2,254.43 crore[22]
for 2024–25 to 2028–29. The scheme provides for nine additional National
Forensic Sciences University off-campuses and seven additional Central Forensic
Science Laboratories, along with the enhancement of the existing NFSU Delhi
campus. Its objective is to address the shortage of trained forensic
professionals and reduce laboratory pendency.
As
per the Government's Rajya Sabha response dated 11 February 2026, five of the
approved NFSU off-campuses were operating from transit campuses. The Government
also stated that one hundred fifty-four forensic experts were engaged
contractually in the seven CFSLs during 2025–26 to ensure zero pendency.
However, corresponding State FSL data was not maintained centrally. These
developments show both progress and continuing challenges. At the same time,
there remains a need for more trained personnel, laboratories, specialised
facilities, and stronger State-level capacity. The absence of centrally
maintained data on State FSL manpower and pendency also makes it difficult to
obtain a complete national picture of the existing forensic workload.
CHALLENGE
IV: FORENSIC LABORATORY BACKLOG AND DELAY
The
expansion of mandatory forensic investigation may also create delays if the
number of laboratories and trained experts is not sufficient to process the
increased volume of forensic exhibits.
The
government has acknowledged that there is a severe lack of qualified forensic
personnel and that mandated forensic investigation under the new criminal laws
is expected to increase the burden of forensic laboratories.
The
relationship can be understood as follows:
A. More
mandatory crime-scene examinations
B. More
forensic exhibits
C. Greater
laboratory workload
D. Potential
increase in pending cases
E. Delay
in forensic reports
F. Delay
in investigation and trial
Therefore,
the issue cannot be addressed merely by requiring investigating officers to
send a larger number of exhibits to forensic laboratories. The Government's
ongoing measures, including the establishment of additional CFSLs, NFSU
campuses, laboratory modernisation, and mobile forensic facilities, reflect the
need to increase this processing capacity.
CHALLENGE
V: RURAL–URBAN DISPARITY
Access
to forensic facilities is not necessarily uniform across India.
A
metropolitan city may have access to a State FSL, regional laboratories,
trained forensic experts, and specialised facilities for areas such as DNA
analysis and digital forensics. In contrast, a rural district may have to
depend on mobile forensic units or transport evidence over considerable
distances to reach an appropriate laboratory.
Section
176(3) of the BNSS, which mandates that a forensic expert visit the crime scene
in relevant circumstances instead of just receiving the gathered material at
the laboratory, makes this issue more crucial.
Government
schemes have therefore placed increasing emphasis on mobile forensic
facilities. In a February 2026 Rajya Sabha response, the Government stated that
projects covering thirty States/Union Territories had been approved for Mobile
Forensic Vans[23]. Separate projects
covering twenty-five States/Union Territories had also been approved for
laboratory modernisation. Reducing the distance between distant crime sites and
specialized forensic facilities can be greatly aided by mobile forensic units.
They are closer to the spot where the evidence. However, the effectiveness of
such units depends on the availability of trained personnel, appropriate
equipment, regular maintenance, adequate training, and timely deployment. A
mobile forensic van, by itself, cannot replace a properly functioning forensic
system.
CHALLENGE
VI: QUALITY CONTROL AND ACCREDITATION
The
effectiveness of forensic investigation cannot be measured by the quantity of
laboratories or equipment alone.
A
laboratory may have modern equipment but may still face challenges relating to:
Validated Scientific Methods; Standard Operating Procedures; Internal Quality
Control; Proficiency Testing; Proper Documentation; Contamination Prevention;
Calibration and Maintenance of Equipment; Trained Forensic Analysts; And
Technical Review of Forensic Reports.
In
its 2024 report on forensic science and human rights, the National Human Rights
Commission listed a number of institutional issues that forensic labs must deal
with, such as a lack of qualified staff, poor infrastructure, storage
constraints, and flaws in quality control systems.
The
Delhi Forensic Science Laboratory provides an example of a more developed
quality-control framework. Its Quality Management Division states that the
laboratory follows a quality management system based on ISO/IEC 17025:2017.
This includes internal audits, technical procedures, method validation,
corrective measures, and continuous improvement.
The
broader lesson is that forensic evidence cannot be considered reliable merely
because it is described as “forensic.” Its reliability depends on the entire
process through which the evidence is collected, preserved, examined,
interpreted, documented, and reported.
FINDINGS
The
study looked at the function of forensic science under the BNSS, 2023 and
discovered that, in addition to legal provisions, its efficacy depends on
appropriate evidence management, sufficient infrastructure, scientific
validity, and court inspection.
1. Section
176(3) of the BNSS is an important step towards making criminal investigations
more scientific and evidence-based. It encourages the use of forensic science
while investigating serious offences.
2. Forensic
science should not completely replace the traditional methods of investigation.
Instead, it should work alongside ordinary investigation methods. Section
176(3) aims to supplement the investigation of major offenses with scientific
evidence.
3. The
forensic process actually begins at the crime scene. The way evidence is
identified, collected, sealed, maintained and transported is very important.
Even if the laboratory conducts the test correctly, the result may become
unreliable if the evidence was not properly handled before reaching the
laboratory.
4. The
chain of custody is an extremely important part of inquiry. Chain of custody
means keeping a proper record of who collected, handled, transferred and
examined the evidence. Even a precise laboratory test might not be enough if
there is uncertainty about whether the sample was appropriately stored or if it
is the same sample taken from the crime scene.
5. Lack
of proper infrastructure and trained manpower continues to be a major
challenge. Government policy documents have also recognised problems such as
shortage of trained forensic professionals and delays in forensic laboratories.
Therefore, more forensic laboratories, equipment and trained personnel are
required for effective implementation.
6. Forensic
evidence is very useful, but it is not always perfect or conclusive. Scientific
evidence can have limitations or errors. Therefore, courts must carefully
examine expert evidence and should not accept it as automatically conclusive
simply because it uses scientific terms.
7. Digital
evidence, audiovisual recordings, electronic devices, electronic records and
expert opinions are the pillars of the investigation as it shows transparency.
8. Section
176(3) BNSS still require greater clarity. Although the provision creates a
duty relating to forensic investigation, it does not clearly specify the same
legal consequence for every instance of non-compliance. This leaves an
important area for further judicial interpretation and legal development.
9. According
to the study, the Bharatiya Nagarik Suraksha Sanhita, 2023 signifies a
substantial change in the function of forensic science in criminal
investigations. The BNSS does not introduce forensic evidence, as scientific
and expert evidence was already recognised under the earlier legal framework.
This indicates a movement from merely permitting forensic evidence to
integrating scientific investigation more directly into the investigation
process.
10. The
examination of recent Supreme Court decisions, including Pooranmal v. State of
Rajasthan and Dashwanth v. State of Tamil Nadu, demonstrates the importance of
proper collection, sealing, preservation, transportation and chain of custody.
If the prosecution is unable to prove the integrity of the sample used to
create the report, a scientifically sound report may lose its evidential
significance.
11. The
research further finds that the BNSS creates a stronger statutory framework for
forensic investigation but does not by itself provide a complete and uniform
system for handling every category of forensic evidence.
12. Another
important finding is that the success of mandatory forensic investigation
depends upon institutional capacity. The effectiveness of Section 176(3) cannot
be assessed only by the existence of a statutory requirement. It also depends
upon the availability of trained forensic experts, adequately equipped
laboratories, mobile forensic facilities, proper storage systems,
quality-control mechanisms and timely forensic reports. Thus, the research
establishes that forensic reform under the BNSS is not merely a legislative
reform; it is also an infrastructural and administrative reform.
13. Finally,
the research finds that the increasing use of forensic evidence strengthens the
need for careful judicial scrutiny and fair-trial safeguards. Their reliability
must be assessed in light of the methodology used, qualifications of the
expert, integrity of the sample, chain of custody, possibility of contamination
and other evidence on record. Therefore, the true change that the BNSS is
considering is not just expanding the use of forensic science but also
establishing a trustworthy connection between the crime scene, scientific
analysis, and courtroom assessment.
CONCLUSION
The
journey “from crime scene to courtroom” reflects the complete process through
which forensic evidence becomes part of a criminal case. The role of forensic
science does not begin when a forensic expert prepares a report. It begins much
earlier, from the moment the police reach the crime scene and determine what
needs to be protected, documented, and collected.
The
BNSS, 2023 recognises the growing importance of scientific investigation.
Because it aims to enhance the involvement of forensic experts in the
investigation of specific serious offences, Section 176(3) is important.
Instead of relying solely on the investigating officer's personal preference,
forensic involvement in such circumstances is meant to play a significant role
in the inquiry once the provision becomes operative in the relevant State.
Other technological measures that assist this strategy are also included by the
BNSS, such as requirements pertaining to scientific expert reports, audio-video
recording of searches and seizures, recognition of electronic evidence, and
documentation of the chain of possession of electronic equipment. Together, these
provisions reflect a broader movement towards a more systematic and
scientifically supported criminal investigation process.
However,
the effectiveness of these legal provisions ultimately depends on their proper
implementation. The presence of a legal requirement alone cannot ensure
reliable forensic evidence. If forensic teams are not available, a crime-scene
examination may not be carried out effectively. Similarly, if the chain of
custody of a sample is not properly maintained, its reliability may be
questioned. Errors caused during the gathering or storage of evidence at the
crime scene cannot be fixed, not even by a well-equipped forensic lab. A
scientifically prepared report is also meaningful only when its basis can be
understood, and its findings can be properly examined before the Court. The
real shift, therefore, is not simply from traditional investigation to forensic
investigation. It is in the direction of a criminal justice system where
scientific evidence is meticulously gathered, appropriately stored, impartially
analysed, and assessed by the court based on its dependability and evidentiary
value. India has already taken steps towards strengthening forensic
infrastructure, trained manpower, mobile forensic units, and specialised
institutions. Initiatives such as the National Forensic Infrastructure
Enhancement Scheme show that the need for stronger forensic capacity has been
recognised. The next challenge is to ensure that infrastructure, trained
personnel, proper procedures, and judicial standards develop alongside the
statutory requirements.
Ultimately,
the success of Section 176(3) should not be measured merely by whether forensic
experts visit crime scenes. Whether or not the evidence gathered at the crime
scene is brought to court with its identity, integrity, and scientific
dependability intact will determine its true worth.
[1] Edmond Locard, The Analysis of
Dust Traces, American Journal of Police Science, Vol. 1, No. 3, pp. 276–291
(1930)
[2] Bharatiya Nagarik Suraksha Sanhita,
Act No. 46 of 2023.
[3] Code of Criminal Procedure, 1973
[4] Bharatiya Nagarik Suraksha
Sanhita, No. 46 of 2023, § 176(3).
[5] BNSS, § 176.
[6] BNSS, § 176(3).
[7] Code of Criminal Procedure (CrPC),
1973, § 157.
[8] BNSS, § 105.
[9] BNSS, § 185.
[10] The Bureau of Police Research and
Development (BPR&D).
[11] BNSS, § 176(3).
[12] Bharatiya Sakshya Adhiniyam, 2023
(BSA).
[13] BSA, § 39.
[14] State of Himachal Pradesh v. Jai
Lal, (1999) 7 SCC 280: AIR 1999 SC 3318.
[15] State of Gujarat v. Kishanbhai,
(2014) 5 SCC 108.
[16] Dashwanth v. State of Tamil Nadu,
2025 INSC 1203.
[17] State of Himachal Pradesh v. Jail
Lal, (1999) 7 SCC 280: AIR 1999 SC 3318.
[18] Pattu Rajan v. State of Tamil
Nadu, (2019) 4 SCC 771.
[20] BNSS, § 193(3)(i).
[21] Pooranmal v. State of Rajasthan
& Anr., INSC 217 (2026), 3 S.C.R. 314.
[22] Ministry of Home Affairs (Government
of India).
[23] Ministry of Home Affairs
(Government of India).
How to Cite This Article
VEDSHREE DILIP SHEVANTE, FROM CRIME SCENE TO COURTROOM: THE ROLE OF FORENSIC EVIDENCE UNDER THE BNSS, 2023., White Black Legal – International Law Journal, ISSN: 2581-8503, Vol. Volume 4, Issue VOLUME 4 ISSUE 2, October 2026, pp. 99-127. Available at: https://www.whiteblacklegal.co.in/details/from-crime-scene-to-courtroom-the-role-of-forensic-evidence-under-the-bnss-2023
Author & Publication Record
Authors: VEDSHREE DILIP SHEVANTE
Registration ID: 107129 | Published Paper ID: WBL7129
Year: Oct- 2026 | Volume: 4 | Issue: 2
Approved ISSN: 2581-8503 | Country: Delhi, India
Page No.: 99-127
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