SYMBIOSIS INTERNATIONAL DEEMED UNIVERSITY

FORENSIC SCIENCE
RESEARCH PAPER SUBMISSION

‘CRTITICAL ANALYSIS OF FINGERPRINT

EXAMINATION’

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Submitted by
Niharika Khanna
Division- ‘D’
PRN – 18010324093
Year – 3rd year
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In
May, 2021
Under the guidance of
Mr. Hifajatali Sayyed
 CHAPTER 1
INTRODUCTION & SCOPE
Fingerprints in the field of forensic science has been proved to increasingly form an essential
object and tool in aiding the system of law around the globe. It has been ensuring that the
ends of justice are met and that justice is provided to individuals on a completely fair basis.
This has been observed to be particularly true when it comes to the criminal legal system of
countries across the world. Fingerprints have been a great and major help to all the
investigating authorities in the identification, evaluation and in the location of the true culprit
responsible for the commission of crimes. This has motivated the scientists of the forensic
field to not only develop the already discovered areas and aspects of fingerprint and their
examination but also the unexplored fields of the object. Fingerprint examination is
considered to be so important because it helps to catch those who commit wrong as even the
most careful and shrewd person also tends to leave behind their fingerprints in majority of the
cases. Due to the unique features and characteristics possessed by them, they have gained a
lot of attention of the legal systems for the complete reliance that can be paced upon their
accuracy.
Evidence of fingerprints is one of the types of forensic evidence which is considered to form
an important part in the process of examining and investigating crimes. Examination of
fingerprints has been used as an essential tool in the process of criminal investigation. Since
long, it has been used as a standard to personally identify people in relation to the crime in
the sphere of forensic science. They are generally used as tools to understand and analyze the
person individually which helps in revealing their identity.1 There are generally three kinds of
fingerprints, namely, latent fingerprints, plastic fingerprints & fingerprints with unknown
matter. When it comes to examination of fingerprints, a particular process is adhered to and
certain techniques are followed and applied in the process. Even if one of the steps is not
adhered to and implemented in the proper manner, it would lead to wrongful results.
Wrongful results might mislead the investigation which would result in prosecuting an
innocent. Thus, fingerprints must be examined carefully so that no mistake is made in
identifying the right suspect of the crime. Some of the techniques that are used in the
examination of fingerprints include radiography, fuming of iodine, powder in the nature of
magnet, development of laser technique2, etc.
1
Fingerprints: A Forensic Tool For Criminal Investigation, , http://www.legalserviceindia.com/legal/article-
2463-fingerprints-a-forensic-tool-for-criminal-investigation.html (last visited Mar 1, 2021).
2
Sarah Sheridan, Techniques for Collecting and Analyzing Fingerprints, FORENSIC SCIENCE IN NORTH
CAROLINA (2013), https://ncforensics.wordpress.com/2013/06/20/techniques-for-collecting-and-analyzing-
Fingerprints are considered to be an essential evidence in the court of law and thus have an
evidentiary value under various acts and provisions. Thus, the scope of this research paper
extends towards analyzing the history, nature, classification, techniques of fingerprint
examination, its evidentiary value and various case laws.

RESEARCH OBJECTIVES
The objectives of the research paper are as follows: -
 The primary objective of the paper is to examine in detail the concept, history, types and
importance of fingerprint examination in investigation of crimes.
 The paper also aims to analyze the procedure involved in fingerprint examination.
 To study in detail the various techniques and methods developed for the process of
examination of fingerprints in investigation of crimes.
 To understand in detail the evidentiary value of fingerprints in India.
 To discuss the opinions and judgments of the courts in relation to examination of
fingerprints as an evidence & on its probative value.

RESEARCH QUESTIONS
The present paper aims to address the following research questions: -
1. What is the concept of fingerprint examination, its types, how has it evolved over the
period of time and what is its importance in investigation of crimes?
2. What is the procedure involved in the examination of fingerprints and what are the
different methods and techniques used to analyze the same?
3. What are the different methods and techniques developed for the process of examination
the evidentiary value of fingerprints in India?
4. What is the evidentiary value of fingerprints in India?
5. What are the judgements & opinions delivered by the courts in criminal cases with
respect to fingerprints in India?

RESEARCH METHODOLOGY
The research methodology that will be undertaken for this project is the doctrinal form of
research. This study will include analysing the given case law, and will also discuss legal
statutes, provisions and sources. No primary source of collection of data will be taken up in

fingerprints/ (last visited Mar 1, 2021).

the present paper the researcher will focus the research on secondary sources of data. The
sources which have already been presented and published by various authors will be used in
the paper. The style of citation that the researcher will use throughout the project will be
‘Blue Book Law Review’. Other secondary sources of data such as journals, articles,
newspapers, magazines, etc will be referred. Additionally, opinions of the experts, research
papers, authorised websites, dictionary as well as book reviews will be looked upon to carry
out research to complete the paper.

LITERATURE REVIEW
The author has referred to various articles and books for conducting the present research.
1. The researcher has referred to a book named “Fundamentals of Fingerprint Analysis”3
for the present research. The book provides for and discusses in detail the evolution and
history of fingerprint as an evidence and also explains how this is presented before the
court of law.
2. The journal “Evidentiary Value of Forensic Reports in Indian Courts”4 gives an
understanding on the classification of fingerprints used as evidences helpful in the process
of investigation. It also presents the methods and techniques used to examine and analyze
fingerprints in the investigation procedure.
3. An international journal named “Evidentiary value of Forensic Fingerprints in India”5
discusses the importance of forensic fingerprints in the field of criminal law and in the
process of providing justice to the innocent and punishment to the person responsible for
the commission of the crime.
4. The research paper “Evidentiary value of DNA and fingerprints in criminal justice
system: A study with special reference to India” 6 provides a detailed explanation of the
concept of fingerprint examination in India. Majorly, the paper presents for the
evidentiary and probative value of fingerprints in India. All the laws as well as principles
that enable the court of law to accept the evidence of fingerprints as relevant and
admissible has been discussed in the paper.

3
HILLARY MOSES DALUZ, FUNDAMENTALS OF FINGERPRINT ANALYSIS, SECOND EDITION (second edition ed.
2018), https://www.routledge.com/Fundamentals-of-Fingerprint-Analysis-Second-Edition/Daluz/p/book/
9780367778743 (last visited Mar 1, 2021).
4
Himanshu Setia, Evidentiary Value of Forensic Reports in Indian Courts, Vol. 4(6), 2016
5
Evidentiary-value-of-Forensic-Fingerprints-in-India.pdf,https://www.ijlmh.com/wp
content/uploads/Evidentiary-value-of-Forensic-Fingerprints-in-India.pdf
6
Akansha Madan, Evidentiary value of DNA and fingerprints in criminal justice system: A study with special
reference to India, National Law University Delhi (India)
5. A book named “Forensic Science in Criminal Investigation and Trials” 7 book
discusses in detail the importance and kinds of fingerprints used as an evidence in
criminal cases and & trials before the court of law. All the techniques used in collection
and examination of fingerprints during the period of criminal investigation has been
presented in detail in the book. Further, the book also discusses the procedure to be
followed in the examination of fingerprints to be used as an evidence.
6. The research paper “Evidentiary value of Expert opinion under Indian Evidence
Act”8 presents for the statutory recognition of fingerprints in India and gives a list of all
the laws that govern the same. It also provides for various case laws and opinions of
experts which have discussed the importance of fingerprint as an important tool in the
process of investigation and has also presented the opinions of various judges regarding
the same.

CHAPTER 2
Nature, history, classification, and importance of fingerprint examination in
investigation of crimes.
Fingerprints is considered to be one of the types of physical evidence and plays an important
role in establishment of commitment of a crime and also helps in drawing a link between the
victim and the suspect. It is usually associated as a type of object that can be found in the
crime scene in several types of cases. Fingerprints can help to identify a criminal to a great
extent and it was considered to be the most essential evidence in investigation of criminal
cases. They have been used as “means of identification” since a very long time dating back
to a period of 100 years. In the field and community of forensic science it has been an
important medium of development and personal identification. It is considered to be so
important because of its unique and distinct characteristics that it possesses.
2.1 History of fingerprints:
One of the first and early countries to use fingerprints as a tool in criminal investigations was
India. It was used as an object to establish a crime. It was William Herschel who first
considered and proposed that apart from business transactions and signing of contracts,
fingerprints could also be used for the purpose of personally identifying crimes. During the

7
B. R. SHARMA, FORENSIC SCIENCE IN CRIMINAL INVESTIGATION AND TRIALS 6TH EDITION 2020 (Sixth edition
ed. 2019).
8
ARETI KRISHNA KUMARI, Evidentiary Value of Expert Opinion Under Indian Evidence Act (2007),
https://papers.ssrn.com/abstract=956231.
reign of colonials, it was decided and a resolution was passed in relation to making
fingerprinting officially the method to identify suspects involved in crimes in India.
In India, fingerprints were further developed into various types. This was done by developing
a system of classification which was named as the “Henry Classification System”. 9 The first
place in India where a bureau and lab for fingerprints was built was in Kolkata. Today,
fingerprints act as a very crucial object in the field of forensics as well as crimes because it
helps in determining whether a particular person has committed a crime.
2.2 Nature of fingerprints:
The nature characteristic of fingerprints is considered to be unique and distinct. The very
basic nature of fingerprints is generally filled of patterns. 10 The exterior i.e. the surface of the
hands has what is known as the friction ridges. These ridges are the raised portions of the
skin between furrows on the either side.11 These are also popularly known as papillary.
These ridges are said to flow in different and various directions which in turn gives rise to
innumerable patterns. There are various small pores present in the ridges which are
considered to be part of the sweat gland for the purpose of secreting water to the surface &
exteriors of the skin wherein the body is cooled off through evaporation. Every time
somebody’s hand comes in contact with the surface, the evaporated material is left as a
residue. It is this deposit that imbibes the pattern of ridges leaving marks which are known as
latent prints.
2.3 Classification of fingerprints:
Fingerprints are classified primarily on the basis of patterns of their own. There are various
ridges present in a fingerprint. These ridges are distinct from each other depending upon their
lengths, bifurcation, joinings, and turnings.12 The patterns of the fingerprints have been
classified into several categories and groups on the basis of their shapes. Primarily there
exists 3 systems which classified fingerprints. They are the Henry system, Roschler system
and the Vucetich system. These systems were vastly used in India, Germany and South
America respectively.13

9
Shantanu Basu, Fingerprinting in India (08:19:09 UTC),
https://www.slideshare.net/shantanu_leo/fingerprinting-in-india.
10
The Nature of Fingerprints and Their Importance in Solving Crimes | Kibin, , https://www.kibin.com/essay-
examples/nature-of-fingerprints-and-their-importance-in-solving-crimes-pLIVpMQs.
11
NATURE OF FINGERPRINTS FINGERPRINT composite of the ridge outlines which appear | Course
Hero, , https://www.coursehero.com/file/piqov5/NATURE-OF-FINGERPRINTS-FINGERPRINT-composite-
of-the-ridge-outlines-which-appear/
12
Fingerprint classification, , 29 PATTERN RECOGNITION 389–404 (1996),
https://www.sciencedirect.com/science/article/abs/pii/0031320395001069.
13
The Science of Fingerprints, , https://www.crime-scene-investigator.net/fbiscienceoffingerprints.html.
In India, it the Henry system of classification that is used to classify the fingerprints based
upon their patterns and shapes.14 The below table presents a broad individual classification of
fingerprints:

Plain Arch Tented Arch Ulnar Loop Radial Loop Plain Whorl

Central Pocket Loop Double Loop Whorl Accidental Whorl

2.3.1 Arches- This is the type of classification where the ridges are usually found to be in
shape or formation of an arch. In plain arch, the arch’s height is usually small and in that
of tented arch, the height is usually considerably long. This type of fingerprint pattern
doesn’t have any ridges which are turned or twisted in nature. Arch patterns are observed
in about 5% of the total population of humans.
2.3.2 Loops- In this pattern, a loop is usually formed by one or more number of ridges by
curving in the backward direction. A delta and a core type of pattern is generally
observed in this type of classification. 15 The fingerprint’s centre line is usually referred to
as the core and the point that lies within the structure of the fingerprint that is shaped like
a triangle is referred to as delta. It is the ridge’s part which is nearest to the point of
divergement of lines of ridges flowing around the loop.
The sub-division of the loops are the left slant and right slant loops which are also known
as the ulnar and radial loops respectively. This division is made usually on the basis of the
ridge’s flow. If the flow of the ridge is towards the ulna bone i.e. towards the little finger,
it is known as ulnar and if the flow is towards the radius bone, i.e. towards the thumb, it is
referred to as the radial loop. The patterns of loops are considered to be the most common
and is found among 65% of the total human population.

14
Bhupeshkumar Nanhe, Fingerprint Classification (15:03:05 UTC),
https://www.slideshare.net/BhupeshkumarNanhe/fingerprint-classification.
15
Fingerprint Analysis in Forensic Science,, NEWS-MEDICAL.NET (2020),
https://www.azolifesciences.com/article/Fingerprint-Analysis-in-Forensic-Science.aspx.
 2.3.3 Whorls- The identification of this type of fingerprint pattern is known to be
simplest. This pattern has at least one ridge that forms and develops a complete oval or a
circle. They usually have 2 deltas and at least 1 or more cores. The percentage of
population that they are usually found in is 35%.
2.3.4 Accidental- This is the type of fingerprint pattern that cannot be placed or classified
under any one of the patterns abovementioned. Accidental patterns usually have a
combination of 2 or more patterns that are stated abbe and have 2 or more number of
deltas.
2.4 Importance of Fingerprints:
Identifying suspects and criminals through that of fingerprints was considered to be the most
essential breakthrough in the field of forensic science and criminal investigations. The
recognition of fingerprints as an important tool in these aspects is worldwide. Fingerprints are
considered to be essential tools in investigation of crimes and in various other fields due to
the special features and characteristics they possess.16 The following are the features that
make fingerprints an important piece of evidence:
2.4.1 Uniqueness- Fingerprints are considered to be the most unique from of evidence.
No two fingerprints can be exactly the same which makes it even easier to trace the
suspect of the crime. Each human finger consists of papillary ridge which are shaped into
complex patterns. Every pattern is said and believed to have its own individuality. The
most amusing thing about these patterns is that not only 2 people have distinct and unique
patterns of their own but even the different fingers of 1 individual have varied patterns
that can never be the same.17 No duplicity in the patterns of the fingerprints of 2
individuals or 2 fingers of one individual has been observed till date.
2.4.2 Permanence- Another characteristic of fingerprints that make them important is that
they are permanent in nature. The pattern of an individual’s finger remains the same
throughout their life and these patterns develop even before an individual is born. These
ridges remain unchanged even till the death of the person until the epidermal skin of the
individual is burnt or destroyed with the use of fire or is consumed by any kind of
creature.18 Due to this permanence any individual can be investigated and identified easily

16
Fingerprint Analysis: Introduction, , http://www.forensicsciencesimplified.org/prints/ (last visited May 5,
2021).
17
The Importance of Fingerprints in Crime Solving | 123 Help Me, , https://www.123helpme.com/essay/The-
Importance-of-Fingerprints-in-Crime-Solving-314936 (last visited May 5, 2021).
18
The Importance of Fingerprints in Forensic Science, , https://legalbeagle.com/6498833-importance-
fingerprints-forensic-science.html.
 as they cannot change their basic fingerprints. Thus, this characteristic of fingerprints
makes them an essential object in investigation of crimes and identification of criminals.
2.4.3 Universality- Fingerprints is used to identify criminals universally, i.e. in all the
types of criminal cases. All the criminals are human beings and have the universal mode
of identification which is used to track down suspects involved in crimes. Thus, this type
of identification is accepted universally across nations and especially in India where
criminals are seen to have a record of leaving their fingerprints unintentionally in the
process of their criminal activity.
2.4.4 Inimitability- This refers to the ability of not being able to be copied. This is one of
the most attractive features of fingerprints which increase their importance in any aspect
of their usage. Till today, no report of forging fingerprints has been ever reported which
shows that the patters and the ridges of any other individual cannot be copied. However,
there have been cases where fingerprints have tried to be forged and copied. Thus, it is
the judge and the lawyer that must ensure that proper tools are used in the process of
checking the fingerprints so that criminals can be identified on the basis of proof and data
that is adequate and reliable in nature.
2.4.5 Classifiable- Although the classification of types of fingerprints is vast, the work
involved in the process of examination of fingerprints is very simple. Millions of records
can be saved and kept easily with easy restoration access. All the data can be classified in
through the use of computers and is kept at one place increasing the efficiency of finding
any record if necessary.
Thus, due to the above characteristics and features of fingerprint examinations, they are
considered to be the most efficient, reliable and important tool in the process of scientific as
well as criminal investigations.

CHAPTER 3
The procedure involved in the examination of fingerprints and different methods and
techniques used to analyze the same.
Examination of fingerprints is not a cumbersome process and is in fact very simple. Even so,
a particular procedure needs to be and must be followed during its examination to avoid any
case of discrepancy. The following is the procedure involved in the examination process:
1. Fingerprint locating- The first and foremost step involved in the process of
examination of fingerprints is identifying its location which asks for a search that is
 calculative and vigilant enough. There might be cases where the fingerprints are
visible to the naked eye and in such circumstances, the process of its location
becomes much easier. In-depth searches of the fingerprints take place when the print
is there on the surface but isn’t visible enough to the naked eye. There are usually
three kinds of fingerprints that need to be located namely patent prints, plastic prints
and latent prints. Where patent prints are the ones that can be located without any kind
of efforts, it is the latent prints that requires the most amount of efforts to locate them.
Plastic prints though easily locatable are usually less common. The first step though
of examination of fingerprints though easy, must be carefully done without leaving
zero chances of error.
2. Photography of fingerprints- The second step after location involves taking pictures of
the photographs before they are lifted from the crime scene. Photographing the
fingerprints enables the capturing of the location of the print and tells where the
fingerprint was exactly oriented. Additionally, photographing can help identify the
type of print which can later be matched with its source. Photography is also essential
to avoid and prevent any form of tampering in the evidence collected from the crime
scene.
3. Fingerprint lifting- This step is said to be the most crucial one in the process of
fingerprint examination. This process refers to making a permanent mark of the
fingerprint obtained or identified at the crime scene. This step can be completed either
by imprinting the fingerprint on a surface that is completely flat or on surfaces which
are round. This step involves the usage of a rubber tape along with an adhesive
surface that enables the lifting of fingerprint. This process is needed to be
accomplished very carefully because if any error is made in the process of lifting the
fingerprint, it can altogether damage the evidence.
4. Fingerprint comparison- The last step that is involved in the process of examination of
fingerprints involves closely studying the features and characteristics of that
fingerprint. At this step, the fingerprint is carefully compared which determines the
identification of the person or the suspect or with whosoever the fingerprint matches.

CHAPTER 4
The various techniques and methods developed for the process of examination of
fingerprints in investigation of crimes.
There are various techniques used to examine the fingerprints. Some of the techniques that
have been developed for the same include the following:
1. Powder technique- This technique is also popularly referred to as the nonporous
surface technique which is principally and generally used in the identification process
of latent prints. These prints usually appear on objects such as glasses, plastic, metals,
wood, etc.19 This technique involves the powder to get adhered to the residue which
enables the investigator to locate the fingerprint.
2. Fuming technique- This technique is also popularly known as the porous surfaces
technique. On porous platforms and surfaces such as fabrics, paper, etc. the technique
of using powder doesn’t prove to be very effective. This technique is thus used by
investigators wherein chemical products and methods such as the process of fuming,
ninhydrin, etc. are used for the purpose of locating the fingerprints. In this process,
whenever any chemical touches the chemical of the residue of the fingerprints such as
oil, natural fats, etc. the print becomes visible to the naked eye. The chemical
processes such as fuming of the iodine must be done in a chamber or a lab that is
formed for that purpose. One of the disadvantages of the process of fuming of iodine
is that the print that is located quickly fades away after the process is completed and
thus the photography of the fingerprints must be done immediately and as soon as the
process of fuming is completed. Other fuming techniques such as the fuming of
cyanoacrylate and that of metallic vapor is also used on surfaces such as plastic,
polythene, and on alloys.
3. Chemical technique- This technique is used by investigators wherein chemical
products such as ninhydrin, sodium chloride, etc. are used for the purpose of locating
the fingerprints and developing the latent fingerprint. There are various chemicals that
mix and react with each other giving rise to the formation and creation of colors. Such
as the chemical ninhydrin when mixed with amino acid reacts to form pink color and
mixing of osmium tetroxide with oils gives rise to black color.
4. Laser development technique- This method is usually adopted for the development of
prints on objects such as human skin, glass, metals, etc. Some of the advantages of
this technique are that there is no prior treatment necessary for the usage of this
technique, this particular technique can be used even after all the other methods have
been used and in this method the surface on which the fingerprint is adhered or

19
Fingerprints, , CRIME MUSEUM ,
https://www.crimemuseum.org/crime-library/forensic-investigation/fingerprints/.
 imprinted doesn’t get disturbed. However, some of the disadvantages of this
technique is that it requires very heavy equipments and is thus very costly.

CHAPTER 5
The evidentiary value of fingerprints in India.
Fingerprints are not only recognized as an essential tool in the field of Indian forensic science
and in the investigation of crimes, but also carries an evidentiary value. This means that there
are various statutory laws that recognize and legally validate the use of fingerprint and its
examination in the process of criminal investigation such as The Indian Evidence Act, 1872,
The Identification of Prisoner’s Act, etc. Fingerprint being the object of evidence of forensic
science is governed by the principles of admissibility and relevancy.
5.1 Identification of Prisoner’s Act, 1920:
The Identification of Prisoner’s act provides immense powers to collect the ‘measurements’
of anyone who is imprisoned rigorously. The term ‘measurement’ exclusively includes
fingerprints in the particular act. The act thus allows and gives powers to the magistrate to
collect the fingerprints of criminals whenever required. This law was primarily introduced for
the purpose of avoiding any kind of refusals that could be made by the prisoner’s in the
process of collection of their fingerprints in necessary and important cases.
5.2 The Indian Evidence Act, 1872
Under the IEA, 1872, the provision which is relevant to that of fingerprints is section 45.
Under this section, an expert’s opinion in relation to fingerprints becomes relevant when an
opinion related an impression of a finger has to be formed and made by the court of law. In
that case, the expert’s opinion regarding the fingerprint becomes a relevant fact before the
court. Fingerprint as a piece of evidence under this section and act is corroborative and not
substantive in nature.20 Where it is found that the even though the fingerprints have been
secured without any infirmity but the print has been collected in a suspicious way then the
opinion will become not important altogether.21 Additionally, under section 73 of the act, the
court is given the power to ask an individual to write anything for the purpose of comparing it
to any evidence provided by that individual. This section in addition to writing, also includes
it finger impressions. In these types of cases it becomes the duty of the court to carefully

20
Musheer Khan v. State of M.P, (2010) 2 SCC 748
21
Chandran v. State of Kerala, 1991 Supp (1) SCC 39
analyze the experience and report presented by the expert to decide whether it is safe and
reliable.22
5.3 The Code of Criminal Procedure, 1973
The provision under the abovementioned code that is relevant to fingerprint is section 293.
This section states that documents claiming or appearing to be a report of the scientific expert
under the government can be used as an evidence in trials, inquiries or any other type of
proceeding under this code. One of the government scientific experts to whom this section is
applicable includes the Director of Bureau of Finger Print.

CHAPTER 6
Opinions and judgments of the courts in relation to examination of fingerprints as an
evidence & on its probative value.
There have been various case laws wherein fingerprint, its examination and print as a tool of
evidence has been in question before the court of law. The tools of forensic science are vastly
used in investigation of crimes, solving criminal cases or for the evaluation and deduction of
commitment of a tort by an individual. Fingerprints is considered to the most essential tool in
field of forensic science and even the Supreme court of India in the case of Ritesh Sinha v.
The State of Uttar Pradesh & Ors 23 acknowledges the need of the use of the tools of forensic
science, especially the fingerprints in the legal system of India. In the case of Jaspal Singh v.
State of Punjab,24 it was held and stated that the science which is related to identification of
impressions of thumb is considered to be an exact science without arising any doubt or
mistake. The court further stated that it is in fact considered to be a very good incriminating
circumstantial evidence. Fingerprints were given the same importance in the case of Madan
Mohan Raj v. State of Orissa25, which held the accused on the basis of evidence of
fingerprints.
On the question the arose before the court of law whether a person can be convicted purely
and solely relying upon the opinion of the expert, it was held in the case of Harendra Nath
Sen v. Emperor26 that no rule can be laid down saying that convicting a person solely based
upon the expert’s opinion of fingerprints is unsafe. The judge stated that caution is to be
maintained while relying on the opinion and report presented by the expert. A similar opinion

22
Ranjit Singh Brahmajeet Singh Sharma v. State of Maharashtra, (2005) 5 SCC 294
23
Ritesh Sinha v. The State of Uttar Pradesh & Ors, (2013) 2 SCC 357, in Para 52
24
Supra
25
Madan Mohan Raj v. State of Orissa, 1996 Cr LJ 2578
26
Harendra Nath Sen v. Emperor, AIR 1931 Cal 441 (442).
was presented in Public Prosecutor v. Virammal27, wherein the court observed that
conviction of an accused cannot be refused on the reasoning that it is unsafe to convict him
merely relying upon the evidence provided by the fingerprint expert. He concluded stating
that the expert’s opinion on fingerprints must be given the same value as that of a report
presented by any other expert like that of a medical officer. An opposite view of the same
contention has also been observed in the case of Emperor v. Ramrao Mangesh Burde28
stating that in the absence of any other corroborative evidence to be presented for conviction,
the court cannot solely and entirely rely upon the report or evidence of fingerprint presented
by the expert.
In Shashi Kumar Banerjee v. Subodh Kumar Banerjee 29, it was stated and held that expert’s
evidence in relation to fingerprints is merely a substantive one and is supposed to be
presented along with either a strong direct evidence or one of a circumstantial evidence to
consider the conviction of the accused. A similar view was held in the case of Ladi
Jagannadham v. Padmabati Baurani30 wherein it was stated that the expert’s opinion in
relation to fingerprint cannot override or outweigh the direct evidence presented before the
court of law.
The accused in the case of Himachal Pradesh Administration v. Om Prakash 31 was charged
for the offence of murder and reliance was placed upon the fingerprints of the accused which
were found on the flask and glass present in the crime spot. However, the court refused to
rely completely on such an evidence.
In relation to delay made in the process of examination of the fingerprints, the case of Shyam
Sunder v. State of Haryana32 is a live example wherein the officer collected the evidence of
fingerprints from the place of crime and was immediately sent for examination without any
delay. Thus, even though the accused was arrested after a long period of investigation, his
fingerprints matched because no delay was made preventing any chances of tampering the
evidence.
Although mixed opinions with regards to the admission of the fingerprint examination and
evidence produced by the experts have been produced by various courts, its relevancy and
admissibility largely depends upon the circumstances and the facts of a particular case.

27
Public Prosecutor v. Virammal, AIR 1923 Mad 178
28
Emperor v. Ramrao Mangesh Burde, (1932) 34 BOMLR 598
29
Shashi Kumar Banerjee v. Subodh Kumar Banerjee, LNIND 1963 SC 402
30
Ladi Jagannadham v. Padmabati Baurani, AIR 1962 Ori 7
31
Himachal Pradesh Administration v. Om Prakash, 1972 AIR 975
32
Sunder v. State of Haryana, (2005) 4 Crimes 553 (DB) (P& H)
 CHAPTER 7
CONCLUSION
Thus, it can be concluded that fingerprints form an essential tool and object of forensic
science and in providing aid to the criminal legal justice systems across countries. The
examination of fingerprints is carefully done by the experts through a proper procedure and
using various methods as well as techniques. The investigating officer must collect samples
without any delay as a result of which accurate results can be provided for the identification
of criminals before the court of law. Fingerprint examination has assumed a great level of
importance in various aspects of sciences and law due to its characteristics such as
uniqueness, permanent nature, easily classifiable nature, etc.