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PROJECT REPORT

FORENSIC SCIENCE

INTERNAL
EXAMINATION
(POST MORTEM)

SUBMITTED TO: SUBMITTED BY:


Dr. Ajay Ranga Shubham Bhatia

Associate Professor B.A.LL.B. (Hons.)

University Institute of Legal Studies, Semester-9th

Panjab University, Chandigarh Roll No: 95/16

Section-B
ACKNOWLEDGEMENT
I have taken efforts in this project. However, it would not have been possible without the kind
support and help of many individuals and organizations. I would like to extend my sincere
thanks to all of them.
I am highly indebted to Dr. Ajay Ranga for his guidance and constant supervision as well as
providing information regarding the project and also for her support in completing this project.
I would like to express my gratitude towards my parents and friends for their kind co-operation
and encouragement which helped me in completion of this project.

Page | 1
INDEX

S.NO TOPIC PAGE NO.

1. INTRODUCTION 5

2. OBJECTIVES OF FORENSIC AUTOPSY 6

3. RULES REGARDING POST MORTEM 7-8


EXAMINATION

4. EXAMINATION OF BODY 9

5. INTERNAL EXAMINATION 10-11

6. PROCESS OF INTERNAL EXAMINATION 12-15

7. LEGAL ASPECTS 16-17

8. CONCLUSION 17

9. REFERENCES 18

Page | 2
TABLE OF ABBREVIATIONS

ABBREVIATION DEFINITION

AIR All India Reporter

& And

IE Internal Examination

ISC I- Shaped Incission

i.e. That is

SC Supreme Court

SCC Supreme Court Cases

vs Versus

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TABLE OF CASES

CASE NAME CITATION

Hari Krishna Maheswari v. Union of UP 1997(1) Crimes 432 (All)

Kuldeep Singh v. State of Punjab AIR 1992 SC 1944

Pedda Satya Narayana v. State of A.P AIR 1975 SC 1252

Razik Ram Chaudhary v. Chaudary AIR 1975 SC 667


Jaswant Singh

Sushil Sharma v The State of NCT Delhi, (2014) 4 SCC 317

Page | 4
INTRODUCTION

Execution Autopsy/necropsy implies examination of the dead body (post-mortem examination)


with a view to searching primarily for the cause of death. The necessity for this procedure was
evident to our ancestors. Records from Roman times narrate the examination of the wounds of
Gaius Julius Caesar by the physician Antistius in 44 BC. In 1302, a court in Bologna ordered
the examination of one Azzolino, who had died under suspicious circumstances of alleged
poisoning. This procedure was carried out by two physicians and three surgeons, including
Bartolomeo da Varignana.

Though conventions and legal provisions vary from country to country, there are generally two
types of autopsies:

The Clinical or Academic Autopsy, which is performed with the consent of the relatives of
the deceased to arrive at the diagnosis of cause of death where diagnosis could not be reached
during the treatment or to confirm diagnosis where it was doubtful.

The Medicolegal or Forensic Autopsy, which is performed on the instructions of the legal
authority in circumstances relating to suspicious, sudden, obscure, unnatural, litigious or
criminal deaths, and the information so derived is applied for legal purposes to assist the course
of justice. In the medicolegal autopsy, the body belongs to the State for the protection of public
interest until such time as a complete and thorough investigation into the circumstances
attending the death has been completed. Any or all portions of the body may be taken and kept
for detailed examination as well as preserved for later trial purposes.1

The object of the post-mortem examination of a body is to establish its identity when not
known, and to ascertain the time since death and the cause of death; but in addition, the question
of live birth and viability has to be determined in case of the body of a newly-born infant. 2

1
Krishan Vij, Textbook of Forensic Medicine and Toxicology. 17 (Elsevier, Gurugram, 5th Edition, 2011).
2
Jaising P. Modi, A Textbook of Medical Jurisprudence and Toxicology. 293 (Lexis Nexis, Gurugram, 26th
Edition, 2019).

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OBJECTIVES OF FORENSIC AUTOPSY

The objective of medico legal post-mortem examination is to establish the identity of a body,
when not known; to ascertain the time since death and the cause of death; and whether the
death was natural or unnatural and if unnatural, whether it was homicidal, suicidal or
accidental.3

 To determine the identity of the deceased. Accurate identification is mandatory because


unclaimed bodies, portions of the dead body or bones, etc., may sometimes be brought
for the examination to support false charge. In a charge of homicide, the two essential
requirements are positive identification of the victim and the proof of death by the
criminal act of the accused. This is collectively termed as corpus delicti.
 To determine the cause of death.
 To determine mode of dying and time since death wherever possible.
 To demonstrate the details of all the external and internal abnormalities, malformations,
disease, etc.
 To describe in detail all the external as well as internal injuries.
 To obtain samples of tissues/body fluids for examination/ analysis wherever necessary.
In case of newborn infants, to determine the issue of live birth and viability.
 To obtain photographs and video films wherever necessary. It is, of course, preferable
to obtain photographs in every case, if practicable.
 Need not to mention that the information so obtained is invaluable in the disbursement
of justice, i.e. in booking the criminals vis-á-vis protecting the innocent suspects. 4

3
Medico-Legal Autopsy, available at: https://www. https://legaldesire.com/medico-legal-postmortemautopsy-
in-india-purpose-benefits/ (last visited on December 15, 2020)
4
Krishan Vij, Textbook of Forensic Medicine and Toxicology. 17 (Elsevier, Gurugram, 5th Edition, 2011).

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RULES REGARDING POST-MORTEM EXAMINATION

1. The medico-legal post-mortem examination should never be undertaken unless there is


a written order from the Superintendent of Police or the District Magistrate. Before
commencing the examination, the medical officer should carefully read the police
report on the appearance and situation of the body when it was first discovered, and the
cause of death as far as could have been ascertained. This precaution is necessary,
especially in the case of a decomposed body, so as to enable him to examine particularly
the organ or the part of the body most suspected for the evidence of death.
2. The examination should be conducted in daylight, and not in artificial light. It should
also be as thorough and complete as circumstances permit. The three great cavities and
the organs contained in them should all be carefully examined even though the apparent
cause of death has been found in one of them, just to avoid unnecessary and, sometimes,
unpleasant cross questions in Court, inasmuch as evidence of factors contributory to
the cause of death may be found in more than one organ.
3. Ordinarily a dead body is sent to the morgue but in exceptional cases the medical officer
may be taken to the place where the dead body is lying. In that case he should note the
place and nature of the soil where he found the dead body, and also its position
especially as regards the hands and feet and the state of the clothes, if any.
4. He should also note, in cases of death from violence, the position of the body in
reference to surrounding objects, such as sharp stones and the like, contact with which,
it might be alleged, had produced the injury, and also whether any blood-stains were
visible on such objects or anywhere near the corpse, and whether any weapons were
lying near it. The ground in the vicinity should be carefully searched for the presence
of footprints and evidence of any struggle. In the case of suspected death from
poisoning, he should note whether any appearance as of vomited matter, etc., was
present in the neighbourhood of the body.
5. All the details observed by the medical officer should be carefully entered on the spot
by himself in the post-mortem report or in a notebook, which can be used as evidence
in a legal inquiry.5

5
Jaising P. Modi, A Textbook of Medical Jurisprudence and Toxicology. 295 (Lexis Nexis, Gurugram, 26th
Edition, 2019).

Page | 7
6. He should not mind the report getting soiled; this will enhance its value, inasmuch as it
goes to prove that it was written at the time when “facts were still fresh in the mind." If
there is an assistant, the best plan is to dictate to him as the examination proceeds step
by step, and then read, verify and attest the report.
7. It is not safe to trust to memory and to write the report later on after completing the
examination. The notes and the report to be sent to Court must tally with each other.
There should be no discrepancy. Nothing should be erased, and all alterations should
be initialled.
8. The medical officer holding a post-mortem examination should be familiar with the
normal and pathological appearances of the viscera. He should note the time of the
arrival of the body at the morgue, the date and hour of the post-mortem examination
and the name of the place where it was held.
9. The necessary papers authorising the medical officer to hold an autopsy are frequently
brought by the police long after the body has arrived. This dilatory method on the part
of the police has occasionally led to the decomposition of the body in the post-mortem
room even when it has arrived in a good condition. It is, therefore, safer to note the
exact time of delivery of these papers.
10. There should be no unnecessary delay in holding the post-mortem examination.6 It
should be made as soon as the papers are brought, and the excuse of attending upon a
midwifery case or any other similar reason should not prevent him from performing
this most important, though too frequently unpleasant, duty.
11. No outsider should be allowed to be present at the autopsy.
12. Always hand over the report and other specimens/tissues/ articles, etc., immediately
after conducting the postmortem. Never indulge in delaying the things.
13. A doctor should better not take up the autopsy, which he does not feel competent to
carry out. He should not be too proud or too ashamed to suggest more skilled and
experienced doctor, since a poor opinion is often worse than no opinion. 7
14. All the details should be noted there and then in the postmortem register. If there is an
assistant, it may be better to dictate the notes to him as the autopsy proceeds step by
step and then to read, verify and attest the report. All corrections should be initialed.
Nothing should be erased or mutilated or left to memory

6
Sushil Sharma v The State of NCT Delhi, (2014) 4 SCC 317
7
Krishan Vij, Textbook of Forensic Medicine and Toxicology. 18 (Elsevier, Gurugram, 5th Edition, 2011).

Page | 8
EXAMINATION OF BODY

The examination of the body in the mortuary must be thorough and exhaustive. Deficiencies
may well be exposed later in the court to the discomfort of the doctor. Every case must receive
same degree of care and skill, as any case may turn out to be the basis of a civil suit or a case
for the insurance claim and so on. Relevant sketches, photographs and radiographs may be
preserved wherever desirable.8

The Examination of body is further divided into two categories:

1. External Examination: The external examination is a ritual full of meaning and


common sense. It needs to be performed in as orderly a fashion as a pilot’s pre-flight
instrument check-up. The importance of external examination in case of medico legal
autopsy is far greater, as it is often from the outer evidence that inferences may be
drawn about the nature of the weapon, direction of application of force and possible
determination of inlet/outlet wounds and distance of discharge in case of firearm
injuries.
Therefore, the doctor must spend sufficient time in careful evaluation of the body
surface and should not be too impatient in running towards dissection in an attempt to
arrive at the cause of death. The routine for the external examination may vary
depending upon the nature of the case, but it may be preferable to proceed from head
to foot so that nothing escapes notice.
2. Internal Examination: The internal examination is a detailed examination of the
internal parts of the body and each organ bit by bit. The organs have to be incised,
removed and inspected carefully.9

8
Medico-Legal Autopsy, available at: https://www. https://legaldesire.com/medico-legal-postmortemautopsy-
in-india-purpose-benefits/ (last visited on December 15, 2020)
9
Krishan Vij, Textbook of Forensic Medicine and Toxicology. 19,20 (Elsevier, Gurugram, 5th Edition, 2011).

Page | 9
INTERNAL EXAMINATION

It is neither possible nor advisable to lay down any hard-and-fast rule regarding the procedure
to be followed for the internal examination. In general, it is convenient to commence with the
cavity chiefly affected and the incisions adapted to suit the circumstances of the case. All the
three major cavities, i.e. skull, thorax and abdomen, should be opened and examined. The
spinal cord need not ordinarily be examined except where desirable. Any of the following
incisions may be followed to open the body (Fig. 2.1).

The usual incision is drawn from just above the thyroid cartilage to the pubic symphysis
avoiding the umbilicus and any injuries in the line of incision (I-shaped incision). This method
is mainly followed as a routine on account of its simplicity and convenience. In the second
method, two incisions are made, commencing on either side of the chest from anterior axillary
fold, curving under the breasts/nipples to meet at xiphisternum and to be continued as a single
vertical incision down to pubic symphysis (modified Y-shaped incision).

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This is desirable in those cases (especially females) where it is customary to restore the body
in a reasonable cosmetic condition for view for some time after death. In the third method, the
two incisions commence on either side of the neck from 2 to 3 cm behind the lobe of each ear
to meet at manubrium sterni and then continued as a single incision down to pubic symphysis
(Y-shaped incision). This method is especially suited when a detailed study of neck organs is
desired. The choice of opening the skull or the other body cavity first is left to the dissector.

In cases of head injury, it is a common practice to open the skull first and then the thorax and
the abdomen. In deaths due to compression of neck, it is preferable to open the skull first. The
draining out of blood from neck vessels due to prior removal of skull and brain provides a
comparatively clearer field for the study of neck structures and will avoid congestive-
artefactual haemorrhages in the neck structures as cautioned by Prinsloo and Gordon. The
following instruments should be at hand before commencing the examination: —

1. Scalpel.
2. Large Section knife.
3. Dissecting forceps.
4. Scissors.
5, Saw.
6 Costotome.
7. Enterotome.
8. Blunt probe.
9. Blow pipe.
10. A pair of iron hooks.
11. Curved needles.
12. Strong twine.
13. A measuring tape.
14. Measuring and graduated glass containers.
15. China plates.
16. Basins to contain water.
17. Sponges.
18. At least two wide mouthed, white glass bottles (with glass stoppers) of about one litre
capacity, to contain portions of viscera.10

10
Jaising P. Modi, A Textbook of Medical Jurisprudence and Toxicology. 301 (Lexis Nexis, Gurugram, 26th
Edition, 2019).

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PROCEDURE OF INTERNAL EXAMINATION

If there be a fatal wound leading to one of the cavities, that cavity should be opened first, or
the head should be opened first, and then the thorax and the abdomen. Professor Harvey Little
John1 recommends the examination of the head first in cases of alleged infanticide so that the
examiner may have an opportunity of inspecting the contents of the skull before the blood can
possibly drain away during the examination of the thorax and trunk, and also because he will
be better able to interpret appearances in the lungs when they are examined. Every organ
contained in the cavities must always be examined, but the spinal cord need not ordinarily be
examined unless there is suspicion of some injury to the vertebral column or the alleged cause
of death is due to some spinal poison or some such disease as tetanus. In that case it should be
examined last of all.

1. HEAD: A transverse incision across the vertex should be made from ear to ear and,
after reflecting the flaps anteriorly up to the orbits and posteriorly up to the occipital
protuberance, the inner surface of the scalp should be examined for extravasation of
blood and the skull bones should be examined for evidence of any fracture or separation
of sutures after the periosteum is denuded and the temporal muscles have been dissected
off. In a doubtful case the skull should be tapped with a hammer; it would elicit a ringing
note if there is no fracture. To remove the skull cap a circular cut is then made with a
saw round the cranium keeping close to the reflected flaps.
Its inner surface should then be examined for fracture of the inner plate, or effusion of
blood, which may be found on the dura mater. The longitudinal venous sinuses should
be examined for evidence of laceration or thrombosis The dura mater should be
removed by cutting longitudinally along both the sides of its middle line noting any
effusion of blood or serum, or the presence of pus. The brain should now be removed
by raising the anterior lobes with the fingers of the left hand and cutting through the
various nerves at its base and the medulla as low down as possible.11

11
C.K. Parikh, Textbook of Medical Jurisprudence, Forensic Medicine and Toxicology. 441 (CBS Publishers &
Distributors Pvt. Ltd., New Delhi, 7th Edition, 2017).

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2. THORAX: Before examining the thorax, both the cavities, the thorax and the abdomen,
should be opened by making a longitudinal incision from above the middle of the
sternum to the pubic bone, keeping wide away from any wounds existing in its line. In
infant bodies the incision should be carried a little to the left of the umbilicus. The
integument, fascia and muscles should now be reflected and examined for extravasation
of blood in their inner surface. The abdominal cavity should be examined before the
chest cavity is opened. The colour and appearance of the abdominal viscera, as also the
position of the diaphragm with respect to the ribs (especially in full term newly-born
infant bodies) should be noted. It should also be noted if there is any collection of blood,
serum, pus, or faecal matter in the cavity.
3. ABDOMEN: The peritoneum should be first examined for evidences of adhesions,
congestion, inflammation, or exudation of lymph or pus. The abdominal and pelvic
cavities should then be examined for the presence of a serous, bloody or purulent fluid.
Now the abdominal organs should be removed and examined separately as below: —

 Stomach.—Under ordinary circumstances the stomach is examined by making


a cut while in situ for the contents as regards their quantity and quality, and the
degree of their digestibility. But in suspected poisoning the stomach should be
removed after tying a double ligature at both ends. It should then be opened in
a thoroughly clean plate; after emptying the contents its mucous surface should
be carefully examined noting its appearance, and any suspicious particles found
adherent thereto should be picked off with a pair of forceps and placed in a
separate small phial for chemical analysis. The contents of the stomach should
also be examined as regards their smell, colour and character and for the
presence of any foreign particles or lumps ; these, if present, should be felt
between the thumb and index finger as to their roughness or smoothness,
 Intestines.—The intestines should be removed after ligaturing at both ends and
should be cut longitudinally to examine the inner surface for the presence of
congestion, inflammation, erosions, ulcers, perforation or any other lesion. In
cases of suspected poisoning the contents should be preserved and sent for

Page | 13
chemical analysis wherever possible, as they may, sometimes give valuable
clues as to the nature of the poison. 12
 Liver.—The surface of the liver should be examined as regards its smoothness
or roughness. If there is any injury to the liver, its nature and dimensions should
be noted as well as the size and weight of the liver. Normally the liver measures
12" X 7" X 3". The organ should be cut open by deep incisions in several places,
and the colour, consistence and blood supply of its tissue should be carefully
marked; at the same time the presence of an abscess, new growth or amyloid
degeneration should be observed.
 The gall bladder should be opened and the presence or absence of bile stones
and the character and quantity of the bile should be noted.
 Spleen.—The size, colour and consistence of the organ should be noted as well
as the condition of its capsule. In the case of a rupture of the spleen, its size and
position should be described, as well as the size and weight of the spleen. The
normal spleen in the adult measures 5" X 3" X 1".
 Kidneys.—The size, colour and weight of the kidneys should be noted.
Normally the size of a kidney is 4" X 2" X 1". Its capsule should be examined
as to whether it is adherent or strips off easily. The kidney should be cut open
and the internal cut surface should be examined for the presence of Bright's
disease or amyloid degeneration; the pelvis should be examined for calculi and
evidence of inflammation.
 Uterus.—In female bodies the uterus should always be examined for its size
and shape. The normal size of the organ is 3"x 2" X 1" and weight, from one to
one-and-a-half ounces; but the size and weight vary considerably during
pregnancy or when there is any tumour. The condition of its mucous membrane
and the thickening of its wall should be examined after the uterus is opened
longitudinally. During menstruation the mucous membrane is thickened, softer
and of a darker colour, and covered with blood and detritus. In old age it
becomes atrophied, and paler and denser in texture.
If the uterus contains a foetus, the age of its intra-uterine life should be noted.
The ovaries and Fallopian tubes should also be examined. The ovaries should

12
Jaising P. Modi, A Textbook of Medical Jurisprudence and Toxicology. 309 (Lexis Nexis, Gurugram, 26th
Edition, 2019).

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be chiefly examined for corpora lutea. The vaginal canal should be opened and
examined for the presence of a foreign body or marks of injury. The colour of
its mucous membrane and the condition of the hymen should also be noted. In
fatal cases of suspected criminal abortion the uterus and its appendages together
with the upper part of the vagina should be preserved for chemical analysis, if
thought necessary. Sticks or other foreign bodies found in the genital tract
should be preserved in a separate bottle after removal and drying when
practicable. 13

4. SPINE AND SPINAL CORD.— The spinal canal need not be examined unless there
is any indication of disease or injury. If necessary, the body should be turned over on
the face with a block beneath the thorax and an incision made along the entire length
of the vertebral column extending from the occiput to the lower end of the sacrum.
After reflecting the integuments, dissecting away the muscles and noting extravasation
of blood in the soft tissues, the laminae should be sawn through vertically on each side
and the detached portions removed, when the dura mater would be exposed.
After noting its appearance, the dura mater should be opened and an examination made
for the presence of haemorrhage, inflammation, suppuration or tumour. The cord should
now be removed, laid on the table, cut transversely in several places, and examined for
evidences of haemorrhages, softening and inflammatory lesions.
The vertebral column should be examined for the presence of fractures or dislocations
after the cord has been removed. As soon as the post-mortem examination is finished,
the body should be thoroughly washed, the organs should be replaced into the cavities,
and the dissected flaps should be brought in apposition and well sutured with strong
twine. The body should then be covered with a cloth before it is returned to the relatives
or friends so as to avoid hurting their feelings.
In the absence of the relatives or friends the body should be returned to the police
constable accompanying it, who should cremate or bury it according to the religious
customs of the deceased, but should never throw it into a running stream or river as is
often done.

13
Jaising P. Modi, A Textbook of Medical Jurisprudence and Toxicology. 311 (Lexis Nexis, Gurugram, 26th
Edition, 2019).

Page | 15
LEGAL ASPECTS AND CONCLUSION

Section 174 of Criminal Procedure Code, 1973 empowers police to enquire and report on
suicide, etc. The Supreme Court in Pedda Satya Narayana v. State of A.P14 stated that the object
of this section is to ascertain:

 Whether a person has died under suspicious circumstances


 If so what is the cause of the death

When the officer in-charge of a police station some other police officer specially empowered
by the State Government in that behalf receives information that a person has committed
suicide, or has been killed by another or by an animal or by machinery or by accident, or has
died under circumstances raising reasonable suspicion that some other person has committed
an offence, he immediately gives intimation about it, to the nearest Executive Magistrate
empowered to hold inquests, and proceeds to the place where the body of such deceased person
is.

There, in the presence of two or more respectable persons (panchas) make an investigation He
prepares a report of the apparent cause of death, describing wounds, fractures, bruises, and
other marks of injury found on the body, and stating in what manner, or by what weapon or
instrument, such injuries appear to have been inflicted. The inquest report (panchanama) is then
signed by the investigating police officer and by the panchas.

The report is forwarded to the Magistrate.15 Inquest report is not evidence at the presentation
but can be used to test the veracity of the witness if he makes contradictory statements in the
inquest and at the trial.16 If the statement of a witness is recorded under Section 174, the
provisions of Section 162 shall apply.17

In the following cases, such authorised person subject to rules prescribed by the State
Government in this behalf, forward the corpse to the nearest civil surgeon or other qualified
medical man appointed in this behalf by the State Government surgeon, if the state of the

14
Pedda Satya Narayana v. State of A.P , AIR 1975 SC 1252
15
Section 174, Criminal Procedure Code, 1973
16
Kuldeep Singh v. State of Punjab, AIR 1992 SC 1944
17
Razik Ram Chaudhary v. Chaudary Jaswant Singh, AIR 1975 SC 667

Page | 16
weather and the distance admit of its being so forwarded without the risk of such putrefaction
on the road as would render such examination useless:

 The cases involving suicide by a woman within seven years of her marriage
 If a woman dies within seven years of her marriage under suspicious reasons
 If a woman dies within seven years of her marriage and a relative of her made a request
to conduct post mortem in this behalf
 If any doubt exists regarding the cause of the death
 If the police officer considers it necessary to do so. 18

If no foul play is suspected, the corpse is handed over to the relatives for disposal. Private
medical institutions can undertake medico-legal examination and treatment of the living, but
autopsies can be conducted only with the permission of the State Government. After
proceeding under S.174, a police officer may by order in writing summons 2 or more persons
for the purpose of the said investigation who appear to be acquainted with the facts of the case.

The section 176 provides for inquiry by magistrate (judicial magistrate or metropolitan
magistrate) where the cases involves suicide or death of a woman within seven years of her
marriage under suspicious circumstances and in the cases where a person dies or disappears or
rape is alleges to have been committed on any women while such person or woman is in the
custody of the Police or in any other authorised custody and if he considers it expedient to
make an examination of the dead body of any person to discover the cause of his death, the
Magistrate may cause the body to be disinterred and examined.19

In any case of death, a Magistrate may conduct an inquest, instead of or in addition to the police
inquest (S.176, Cr.P.C). Whenever police claims that it has killed a person in an encounter,
inquiry by Magistrate is mandatory. 20

What we see is that all the legal and medical conditions have to be necessarily followed.

18
Section 174, Criminal Procedure Code, 1973
19
Section 176, Criminal Procedure Code, 1973
20
Hari Krishna Maheswari v. Union of UP , 1997(1) Crimes 432 (All)

Page | 17
REFERENCES

1. C.K. Parikh, Textbook of Medical Jurisprudence, Forensic Medicine and Toxicology.


(CBS Publishers & Distributors Pvt. Ltd., New Delhi, 7th Edition, 2017).

2. Jaising P. Modi, A Textbook of Medical Jurisprudence and Toxicology. (Lexis Nexis,


Gurugram, 26th Edition, 2019).

3. Krishan Vij, Textbook of Forensic Medicine and Toxicology. (Elsevier, Gurugram, 5th
Edition, 2011).

4. Medico-Legal Autopsy, available at: https://www. https://legaldesire.com/medico-legal-


postmortemautopsy-in-india-purpose-benefits/ (last visited on December 15, 2020)

Page | 18

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