‘With a Heavy Heart’: Allahabad HC Grants Bail to Rape-Murder Accused, Blames UP FSL's Outdated Infrastructure
Allahabad High Court says incomplete DNA profiling due to outdated forensic infrastructure forces it to grant bail in serious cases; directs Chief Secretary to place order before Chief Minister Yogi Adityanath.
llahabad High Court flags forensic lapses while granting bail.
The Allahabad High Court recently granted bail to a man accused of raping and murdering a woman in Etah, while simultaneously raising serious concerns over the condition of Uttar Pradesh's forensic laboratories and directing that a copy of its order be sent to the Chief Secretary for the perusal of Chief Minister Yogi Adityanath.
Court said it was compelled to release the accused because the Forensic Science Laboratory (FSL) failed to generate a complete DNA profile from material collected during the investigation.
Describing the situation as a major flaw in the criminal justice process, court observed that outdated machines and inadequate infrastructure in state forensic laboratories were preventing the generation of reliable scientific evidence in serious crimes.
Granting bail to accused Manoj, Justice Arun Kumar Singh Deshwal remarked that the court was constrained to release him "with a heavy heart and great pain" despite the allegations involving the rape and murder of a woman.
The judge went on to state that the inability to generate DNA profiles was the result of obsolete equipment and inadequate infrastructure in forensic laboratories and observed that "no one can be blamed except the State Government" for failing to provide the necessary facilities.
Court expressed hope that the government would provide high-end machines and adequate staff to FSLs and directed that the order be forwarded to the Chief Secretary for the attention of the Chief Minister.
The case stems from the death of a woman whose body was found near a river in Etah district on November 18, 2025. According to the prosecution, the woman had left her house around 4 pm to dispose of cow dung in agricultural fields but never returned. Her family later found her body near the river.
An inquest was conducted the same day. However, when an FIR was lodged on November 19, it was registered against unknown persons.
What evidence did the prosecution rely upon against the accused?
The prosecution later named Manoj as an accused based primarily on statements recorded after the FIR. According to the case, a witness named Satendra claimed that he had seen Manoj going towards the river on the day of the incident and later returning from that direction wearing wet clothes.
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The first informant's statement was subsequently recorded, alleging that he had learnt about the accused's movements from Satendra. Statements of other witnesses were also recorded during the investigation.
Investigators additionally claimed that a wristwatch belonging to the deceased was recovered at the instance of the accused from an open field.
Counsel for the accused attacked the prosecution case by highlighting that Satendra was present during the inquest proceedings on November 18 but did not disclose any suspicion against Manoj at that stage. It was argued that if the witness had actually seen the accused near the scene, he would have informed the family immediately and the accused's name would have appeared in the FIR.
The defence further contended that recovery of a wristwatch alone could not establish involvement in rape and murder.
Most importantly, the defence pointed to the FSL report, which did not connect the accused to biological material recovered from the deceased. The accused also had no criminal history and had remained in jail since November 21, 2025.
What did the high court say about DNA evidence and forensic failures?
While granting bail, Justice Deshwal made a broader observation about recurring problems faced by courts in rape and murder cases.
The court noted that it had repeatedly come across cases where vaginal swabs and DNA samples were sent to forensic laboratories but reports ultimately stated that the source of DNA could not be determined because complete DNA profiles could not be generated.
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According to the court, the present case suffered from the same problem. The FSL report did not establish that the DNA found in the deceased's vaginal smear belonged to the accused because a complete DNA profile could not be generated.
Calling it "the biggest anomaly in investigation as well as incomplete facility in the FSL", the court referred to an earlier case in which the Director of the Uttar Pradesh FSL informed the court about staff shortages and the lack of advanced DNA-testing equipment in many laboratories.
Court observed that despite the allegations involving the rape and murder of a woman, it was left with no option but to grant bail because proper scientific evidence was unavailable. Justice Deshwal remarked that the order was being passed "with a heavy heart and great pain".
Holding that outdated equipment and inadequate infrastructure were at the root of the problem, the court expressed hope that the State Government would take corrective measures by strengthening forensic laboratories and providing them with modern machines and sufficient manpower.
Allowing the bail application, court directed Manoj's release on furnishing personal bonds and sureties, subject to conditions that he cooperate with the trial, refrain from influencing witnesses and not engage in any criminal activity. Court clarified that its observations would not affect the merits of the pending trial.
Case Title: Manoj v State of U.P.
Order Date: May 21, 2026
Bench: Arun Kumar Singh Deshwal