The Investigation and the First Forensic Narrative
The investigation initially developed around circumstantial evidence and forensic findings.
One of the important circumstances was the allegation that Anokhilal had been seen with the child before her disappearance. Investigators also collected physical and biological exhibits during the investigation.
Among the evidence relied upon by the prosecution were hairs allegedly recovered from the victim’s hand, biological material obtained from the victim and clothing, and other exhibits submitted for forensic examination.
The scientific evidence subsequently became an important part of the prosecution’s attempt to establish a connection between Anokhilal and the crime.
However, the first trial provided very limited opportunity for detailed examination of this evidence.
The Supreme Court later noted that the proceedings had moved at an extraordinary pace. Charges were framed on 19 February 2013, and all 13 prosecution witnesses were examined within seven days.
The DNA report was received towards the end of the proceedings. The report was placed on record, and the trial proceeded to conclusion.
Anokhilal was convicted and sentenced to death on 4 March 2013.
The Madhya Pradesh High Court subsequently upheld the conviction and sentence.
The Supreme Court Orders a Fresh Trial
The case eventually reached the Supreme Court.
In its 2019 judgment, the Supreme Court expressed serious concern about the manner in which the first trial had been conducted.
The Court observed that the legal representation available to Anokhilal had not been real and meaningful. The advocate appointed to represent him had been appointed on the same day that charges were framed.
The Court also noted the extraordinary speed with which the evidence had been recorded.
Of particular significance was the treatment of the forensic evidence.
The DNA report had arrived near the end of the trial, yet the proceedings moved almost immediately towards final arguments and judgment.
The Supreme Court therefore set aside the earlier judgments and directed a fresh consideration of the case.
This provided an opportunity for the forensic evidence to be examined in considerably greater depth.
Looking Beyond the DNA Report
The later proceedings demonstrated an important principle in forensic science:
A forensic report is the conclusion of an examination, not the examination itself.
During the subsequent proceedings, the defence was able to examine the underlying forensic evidence and question the experts responsible for interpreting it.
This allowed the court to consider not merely what the original DNA report stated, but how the conclusions had been reached.
The examination included questions concerning the biological samples, DNA profiles, reference samples, laboratory records and the handling of physical evidence.
This deeper examination became particularly important because several findings contained in the original forensic narrative did not withstand the same level of scrutiny.
The DNA Evidence From the Victim
One of the most significant findings concerned male DNA detected in samples collected from the victim.
Male DNA was detected in vaginal and anal samples.
However, during the final trial, the forensic evidence established that Anokhilal was not the source of that male DNA.
This was a critical development.
The presence of male DNA demonstrated the presence of male biological material.
It did not, however, establish that Anokhilal was the contributor.
This distinction is fundamental in forensic DNA interpretation.
A DNA examination must answer two separate questions:
Is biological material present?
and
Whose biological material is it?
The first question may be answered positively while the second excludes the accused.
In the Anokhilal case, the male DNA detected in the relevant samples did not provide the prosecution with the expected genetic connection to the accused.
The Hair Evidence
Hair strands allegedly recovered from the victim’s hand were another important part of the forensic evidence.
The prosecution relied upon DNA findings from these hairs to connect them to Anokhilal.
However, during the later proceedings, the handling of this evidence came under serious scrutiny.
Questions arose concerning the seizure, sealing and subsequent examination of the hairs.
The quantity and description of the material received for examination also raised discrepancies when compared with the evidence reportedly collected during the investigation.
These issues were significant because DNA analysis can only establish a scientific association with the material actually examined.
The laboratory can determine the genetic profile of a sample.
It cannot independently establish that the sample received by the laboratory is exactly the same material that was originally recovered unless the chain of custody supports that conclusion.
The Chain of Custody Question
The case demonstrates why chain of custody is one of the most important components of forensic evidence.
For biological material, the evidentiary trail should establish:
Collection → Packaging → Sealing → Storage → Transportation → Laboratory Receipt → Examination
Every stage should be properly documented.
The purpose is not merely administrative.
A continuous chain allows the court to have confidence in the identity and integrity of the exhibit.
In the Anokhilal case, questions surrounding the handling of the hair evidence created uncertainty about the continuity of the material from the victim to the laboratory.
That uncertainty affected the evidentiary value of the resulting DNA findings.
The Reference DNA Profile
Another important forensic issue concerned the reference profile used for the victim.
The court questioned why a stain from the victim’s pyjamas had been used as her DNA reference profile when the victim’s body was available.
A reference profile is fundamental to DNA comparison.
The questioned DNA profile is compared against a known reference profile to determine whether the genetic characteristics are consistent or inconsistent.
Therefore, the reliability of the reference sample is an essential part of the reliability of the comparison.
The case illustrates an important point:
Forensic accuracy begins before laboratory analysis.
Correct identification and selection of reference material are as important as the technology used to analyse it.
When the Laboratory Evidence Was Re-examined
The later proceedings allowed greater scrutiny of the underlying forensic material.
The forensic experts were examined and questioned about the DNA findings.
This exposed discrepancies between the biological findings and aspects of the original DNA report.
The court was therefore able to evaluate the evidence at a deeper level than had been possible during the first trial.
This is particularly important in forensic cases because a report may contain a definitive conclusion while the underlying evidence may contain limitations, exclusions or inconsistencies that are not immediately apparent.
The Anokhilal case demonstrates why courts must be able to examine the scientific foundation behind an expert conclusion.
The 36-Hour Gap
The forensic evidence was not the only aspect of the prosecution case that came under scrutiny.
The court also examined the “last seen” theory.
The prosecution alleged that Anokhilal had been seen with the victim before her disappearance.
However, the court identified an approximately 36-hour gap between the alleged last sighting and the time relevant to the discovery and death of the victim.
This created an important evidentiary gap.
The last-seen circumstance could not, by itself, establish what occurred during the intervening period.
The possibility that another person could have become involved therefore could not be excluded.
From a forensic reconstruction perspective, establishing a reliable timeline is essential.
A suspect’s presence at one point in time does not automatically establish involvement in an offence that occurred considerably later.
When the Forensic Picture Changed
By the time the third trial was conducted, the evidentiary picture had changed substantially.
Male DNA had been detected from the victim.
But the DNA did not belong to Anokhilal.
Hair evidence had been presented as connecting him to the victim.
But questions existed concerning the continuity and handling of those hairs.
A reference DNA profile had been used.
But the court questioned the manner in which that reference profile had been obtained.
The prosecution relied on the last-seen theory.
But a substantial gap remained in the timeline.
The significance of the case therefore lay not in one isolated forensic finding but in the cumulative effect of several evidentiary weaknesses.
The Third Trial
The third trial provided a much more detailed examination of the forensic evidence.
Experts were examined.
The DNA findings were scrutinised.
The handling of biological evidence was questioned.
The reliability of the reference profile was examined.
The prosecution’s circumstantial evidence was also reconsidered.
The forensic evidence ultimately failed to establish the connection between Anokhilal and the sexual assault that was necessary to sustain the conviction.
On 19 March 2024, the Khandwa court acquitted him.
He was released from custody the following day after approximately 11 years in prison.
Forensic Significance
The Anokhilal case is not a case against DNA profiling.
Instead, it demonstrates the importance of proper forensic practice.
DNA profiling is one of the most powerful tools available to modern forensic science. But its evidentiary value depends upon every stage of the process.
A scientifically valid DNA technique cannot compensate for:
- improperly collected evidence;
- inadequate preservation;
- broken chain of custody;
- inappropriate reference samples;
- incomplete laboratory documentation;
- incorrect interpretation; or
- conclusions that extend beyond what the data supports.
The strength of forensic evidence therefore depends not only on the technology but on the entire evidentiary pathway.
Lessons for Forensic Investigators
The Anokhilal case offers several lessons for forensic practitioners.
- Preserve the original evidence
Biological evidence should be properly packaged, sealed, labelled and stored immediately after collection.
Maintain the chain of custody
Every transfer of an exhibit should be documented.
Use appropriate reference samples
Reference profiles must be reliably associated with the individual from whom they are said to originate.
Preserve laboratory data
Raw analytical data and supporting records should be retained so that forensic conclusions can be independently evaluated.
Distinguish detection from identification
Finding DNA is not equivalent to identifying its contributor.
Treat exclusions seriously
An accused being excluded from a relevant biological profile may fundamentally alter the direction of an investigation.
Avoid confirmation bias
Forensic examinations should be capable of disproving an investigative theory.
Explain limitations
A forensic conclusion should clearly state what the evidence establishes and what it cannot establish.
Conclusion
The Anokhilal case demonstrates the importance of questioning forensic evidence at every stage.
The case moved through three trials, two convictions carrying the death penalty and approximately 11 years of incarceration before the forensic evidence was examined with greater depth.
The eventual acquittal was not the result of a single scientific test.
It followed a broader examination of DNA findings, biological samples, reference profiles, chain of custody, expert testimony and the circumstantial timeline.
The case provides an important lesson for forensic science:
The presence of scientific evidence does not automatically make a prosecution case scientifically reliable.
Forensic evidence must be properly collected, preserved, analysed, interpreted and challenged.
Most importantly, forensic science must remain independent of the investigative theory.
Its purpose is not to prove what investigators believe happened.
Its purpose is to determine what the evidence can actually establish.
And sometimes, the most important forensic result is not a match.