For purposes of clarity, a narco-analysis test is an interrogation method whereby a suspect of a crime is injected with a psychoactive drug under controlled conditions to suppress their reasoning power or ability to determine what is good/bad for themselves. Selvi v. State of Karnataka, (2010) 7 SCC 263 held involuntary administration of this test is to be hit by Articles 20(3) and 21. It is clear, under no circumstances is an involuntary or forced narco-analysis test permissible under law. While need for modern investigative techniques may be true, such investigative techniques cannot be conducted at cost of constitutional guarantees.
– Hon’ble Justice Sanjay Karol, Amlesh Kumar v. State of Bihar, [Special Leave Petition (Crminal) No. 5392 of 2024].
