THE INTERSECTION OF MEDICINE AND LAW: EVALUATING THE SIGNIFICANCE OF MEDICAL TESTIMONY

Author: Aish Sajjan, Regional Institute of Management and Technology, Punjab.

Alongside other substantial factors that determine the conviction or acquittal of the accused in a case, medical opinions or the autopsy reports also play a significant role as they bridge the gap between law and science furnishing equitable insights that aid the judicial decision-making. It is of utmost importance in the civil, criminal or family disputes to establish the direct facts, interpret evidence and ensure justice. Medical opinions drawn from anti-mortem or post-mortem reports, forensic examinations and injury analyses help determine the causes of death, the nature of injuries, the time and circumstances of incidents. In trials for offences of kidnapping and rape, the question most in dispute at times is the age of the person kidnapped or of the girl raped. In all such cases the medical opinion is adduced to establish insanity and minority. In rape cases apart from showing the minority of the girl, the medical opinion is tendered to establish the offence of rape. Although the medical opinions alone are not substantial evidence, they hold a positive corroborative value in establishing facts, manner in which the death could have occurred etc. On the other hand the ways in which the medical opinions are presented are not to be considered a deciding factor to either verify or discredit the statement of an eye-witness. These opinions are instrumental in corroborative evidence. Acknowledged as authoritative but not legally binding, the courts mostly rely on their impartiality and reliability. Since their evidence has the power to support or refute a case, accuracy and moral rectitude are crucial. However, issues including conflicting medical advice, improper use of expert testimony, and outside pressures can make the legal system more difficult to navigate. Essentially, medical opinion is essential to the legal system because it provides the scientific basis for interpreting evidence, ensuring justice, and upholding fairness in court. This article aims to highlight the significance of the medical opinions and challenges posed to the same through various celebrated cases.

As per the popular norm, the materials that help adduce the relevant facts to establish a case in the court to persuade the same is called “Evidence”. Talking about medical evidence these are generally the opinions given by the experts of the concerned field as per their experience, knowledge and expertise. Medical opinions, although only corroborative, can form the basis for conviction or acquittal or the accused. The opinions help figure out the time of death or murder, the way in which it may have been committed, the circumstances, weapons, injuries and other factors that may have affected the death. Thus medical opinions often play a decisive role in the trials as they help corroborate the essentials required to prove the innocence or the guilt of the accused. However, the eyewitnesses' testimony cannot be disregarded on the grounds of a purported discrepancy between it and the medical data unless the latter goes so far as to totally rule out any possibility of injuries occurring in the manner that the eyewitnesses described.

As far as expert opinions are concerned the Bhartiya Sakshya Adhiniyam, 2023, (BSA), lays down various provisions highlighting the importance of the same. For example, Section 39 of BSA states, “that in the matters relating to science, art, law, identity verification etc. the opinions of the experts of the concerned fields are deemed relevant,” the same was upheld in the landmark case of Ramesh Chandra Agarwal Vs. Regency Hospital Ltd. & Ors. Similarly, bringing into light the facts that either support or are in contradiction with the expert opinion are covered under Section 40 of BSA. It states that, “facts gain relevance if they either support or are in contravention of the expert opinion, if not otherwise relevant.” On the same lines, Section 45 states that, “Relevant are also the grounds that an expert may use to support their conclusion.” verification of Hand-writing, electronic evidence, signatures etc. are also covered in the Bhartiya Sakshya Adhiniyam.

When judges are making decisions about criminal cases, medical evidence serves as a guide to help them make logical choices. Medical evidence or the opinion of a medical expert is used in the trial of a murder, manslaughter, or any other bodily harm case to establish the cause of injuries, their effect (i.e., whether the injuries could cause death), the plausible weapon that may have been used to cause the injury, etc . Medical knowledge is a whole distinct field, and in order to express an opinion on it, one must possess specialized information that is impossible for a common person to possess. As a result, medical officers who are employed as experts give medical evidence and express their opinions to the court. It is unavoidable that this expert opinion will be considered when criminal cases are being decided. According to medical evidence and the related scientific procedures, insanity is proven in cases where the accused may be requesting relief on the grounds of insanity or unsoundness of mind. The age of the girl, or whether or not she is a minor, is the first question that comes up in situations of rape or kidnapping. Once more, the minority is established with the assistance of medical opinion. Additionally, the scientific tests that are carried out to provide an expert's report are crucial in proving that rape is an offense in and of itself. However, the expert's assessment's evidential importance is unenforceable because the Court of law retains the discretion to accept or reject it. Section 45 of the Indian Evidence Act, 1872, which, in theory, devalues expert testimony by categorizing it as essentially corroborative, gives the Court this discretionary power in its decision-making.

In the year 1983, the Supreme Court in the case of Chimanbhai Ukabhai v. State of Gujarat found that the medical evidence that was put up and investigated by the prosecution had a corroborative value thereby ruling it admissible. Further, the court stated that the medical evidence demonstrated that the injuries might have led to the death of the individual in a normal course as is alleged by the complaint. Additionally, the medical evidence establishes the veracity of the claimed causes of harm on its own. This can then be confirmed by eyewitness accounts, and as a result, the testimonies of these witnesses may be recorded and deemed admissible. However, eyewitness accounts cannot be disregarded because they seem to contradict medical data unless the medical evidence goes so far as to completely rule out any possibility of injuries occurring in the manner that the eyewitnesses state. Additionally, the case of Rajendra Pralhadrao Wasnik v. State of Maharashtra, examined whether a convicted person may be changed and rehabilitated in society, despite the fact that the issue at hand was the death penalty in court. The prosecution must provide evidence in court to demonstrate that the prisoner cannot be changed or redeemed, the judge ruled. Numerous facts can be revealed on this front, such as details regarding the defendant's conduct both while incarcerated and while out on bail, medical records pertaining to his mental health, and correspondence with his family members, among other things. Convicts may also provide such reports or medical proof. We can examine this most recent Supreme Court ruling from 2020 to gain an understanding of the status of medical evidence in Indian criminal jurisdiction and its admissibility. In, Santosh Prasad @ Santosh Kumar v. State of Bihar, the supreme court ruled that the prosecutrix's statement alone could not convict the accused of rape unless her testimony was exceptional. In the historic ruling, the highest court proceeded to review the prosecutor's statement or supporting documentation, which ultimately did not align with the physician's medical testimony. Therefore, the Court took into account the whole situation and addressed the question of whether the accused could be found guilty based solely on the prosecutor's deposition, even if the other witnesses and medical evidence did not corroborate it. The aforementioned approach makes it clear that the prosecutrix's evidence must support the medical evidence in order to establish the offence of rape. Additionally, it has been established by a number of other seminal cases, such as Piara Singh v. Territory of Punjab, that when two medical pieces of evidence contradict one another and are equally credible for the purpose of forming an expert opinion, the court will consider the evidence that is consistent with the direct evidence or whose testimony is consistent with the prosecutor's deposition facts. In the very recent R.G Kar Medical College Rape Case, the autopsy reports were the sole basis for the conviction of the accused. Thus, medical evidence plays a significant role in criminal trials.

In the Indian legal system, medical evidence is essential since it offers a scientific and impartial basis for deciding criminal and civil matters. It helps uncover the truth about incidents like injuries, unnatural deaths, medical malpractice, and other disagreements that call for a professional interpretation of medical data. Under Sections 39-45 of the Bhartiya Sakshya Adhiniyam, 2023, which allow for the reliance on expert opinions, Indian courts acknowledge the significance of medical evidence. Its importance has been further emphasized by judicial precedents, which highlight its capacity to independently establish, dispute, or confirm important facts in a case. For example, it assists in determining the reason of death, the time of death, and the type of injuries in criminal trials, and it supports the assessment of claims pertaining to personal injuries or negligence in civil cases. Medical evidence is not definitive, nevertheless, and courts have the authority to judge its veracity and dependability, especially when there are differing views or when it deviates from other types of evidence. The significance of careful examination is underscored by issues including bias, manipulation, technical complexity, and the requirement for interpretation by non-medical specialists. To sum up, medical evidence is a vital instrument for the administration of justice in India. Its efficacy hinges on the medical practitioners' honesty, the judiciary's capacity to comprehend and incorporate it with other evidence, and adherence to scientific methods. In the Indian legal system, medical evidence upholds the values of justice and truth by guaranteeing impartiality and transparency.

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