IOSR Journal of Biotechnology and Biochemistry (IOSR-JBB)

ISSN: 2455-264X, Volume 4, Issue 4 (Jul. – Aug. 2018), PP 76-82

[Link]

Polygraph Test and Its Relevancy in Criminal Justice System

Dr SeemaYadav,
Associate Professor, HOD, Law Department
SVD College, Aligarh

Dr SandhyaVerma
Assistant Professor, Law College Dehradun, Uttaranchal University,
Dehradun

Abstract
Law is dynamic and not static and therefore, as society evolves law has to keep in consonance with the changing
social order. Law is the instrument of societal change and the judiciary has the responsibility of interpreting the
law for the greater good. Therefore, it is clear that the judicial mind must stay in touch and keep in step with the
advancement of humanity. To combat organized crime, its detection, investigation and prevention method have
to be employed synchronously. If the criminal use new technology in committing the crimes, the enforcement
agencies need to use the new techniques in solving such crime. If the enforcement agencies do not use these
technologies for solving such complicated crimes, it would be very difficult to detect the perpetrators of such
crime. Therefore in the context of the changing organized modern criminal who are taking shelters behind and
making full use of the new sophisticated technologies. Krishna Iyyer J. remarked "the courts self-criminate
themselves if they keep the gates partly open forculprit to flee the justice under the guise of interpretative
enlargement of golden rule of criminal jurisprudence”. In present paper the efforts have been made by the
authors to disclose the relevancy of polygraph test in criminal justice system.

I. Introduction
For as long as human being have deceived one another, people have tried to enlarge techniques for
detecting dishonesty and finding truth. In early society it was believed that that goodness could be differentiated
from evil easily because it was believed that goodness was stronger, or that divine intervention would protect
the truth speaker. Tests were devise based on the assumption that a magical force would come into play to
identify or rescue the truth speaker. To find out the truth was known as corsnaed. It was used by Roman
Catholic priest during the inquisition to detect the guilt of the member of the priesthood. 1
In India same notion of divine intervention prevailed in the ordeal to find out the truth. In 1886
A’liIbra’hi’mkha’n describes nine ways in which the ordeal may be conducted. They included the balance, fire,
water, poison, rice, boiling oil, red hot iron, and image.2 Such technique to find out the truth is known as lie
detector or polygraph test.
Lie Detection took on aspect of modern science with the development in the 20th century of the
techniques proposed for the psycho psychological deception, most outstandingly Polygraph testing. The
Polygraph testing or instrumental measures several psychological method (ex. Heart rate) and changes in these
process. From the chart of those measures in response to question on a Polygraph test, sometime aided by
observations during the Polygraph test examiners infer a psychological state, namely, whether a person is telling
the truth or lying. Nevertheless in India this technique is not so trustworthy. In India the present day scenario of
crime investigation and prosecution of criminals is sad sight.
Modern Polygraph recording has become computerized. This consists of a computer, a combination
unit that provides for magnification of the physiological signals and their conversion to digital form, and a
printer. Lie detectors are called Polygraph because the test consists of at the same time a monitoring several of
the suspects psychological functions breathing, pulse, and galvanic skin response and printing out the result on
graph paper. The print out shows exactly when, during the questioning period, the biologic responses occurred
.If the period of maximum biologic reaction lines up with the solution question on the graph paper the question
that would associate the person as being involved with the crime stress is assumed .And along with this
assumption of stress comes a second assumption: that the stress indicate a lie.

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 Polygraph Test and Its Relevancy in Criminal Justice System

Polygraph test is the process which is used in medical practice for comprehensive study of functioning
of different body systems with particular reference to circulation, respiration and peripheral nervous response.
This technology has been attempted in forensic investigation process. The basis of its application is the fact that
mental excitation or stimulation there is alteration of these body functions due to autonomic, particularly
sympathetic excitation.3
The successful trial and conviction in the criminal cases depend very much on the proper investigation
and collection of evidence by the investigating agencies against the suspect. In complicated criminal cases
psychological test can be used by investigators to cross check their finding determine if a suspect is telling the
truth or make him reveal facts pertaining a care. A lot of criminal cases have been solved through this technique.
At modern time the criminal are taking in to consideration new techniques in commission of the crime
due to technological developments. Therefore, there is dire need that the prosecution agency rely on something
more reliable, more actual and more creative in terms of convictions without the police having to resort to the
third degree method that not only violates fundamental human rights but also fail to produce positive result
results most of the time. Recent times have witnessed an epidemic in the use of contemporary scientific
technique such as the Lie Detector, or polygraph test for use in criminal investigation.
The Courts in India have taken into account an incomplete consideration of the law, which is the reason
for their conclusion in favor of the tests. While the tests may be a realistic requirement, the sanction of the law
for some of them is difficult to find, and extensive safeguards need to be laid out to avoid their exploitation. It is
now upon the Supreme Court to define the limits of such tests in context of the rights affected, or vice-versa.

Procedure of conducting Polygraph test

Polygraph test is conducted is commonly known as Lie Detector test. In this test examination
conducted by the probe attached to the body of the person who is interrogated by the expert. 4. The person is
made to sit on a chair and the accessories of the instrument are properly attached on different parts of the body.
An arm cuff is placed around the arm for recording blood pressure and pulse rate and pulse features. An elastic
belt is placed around the chest to measure the rate and amplitude of respiration with deviations and an electrode
connection is placed, one on the tip of one side index finger for recording galvanic skin reaction (Galvanic
current is used for the purpose). The response is recorded graphically on a single paper from where different
adverse responses, the intensity of responses, and the time and extent of exciting reaction, can be studied.5
In the following table shows that the name of the instruments attached to the different parts of the body
for the purpose of various graphical measurements. The variation in the pulse rate, the heart rate, the skin
conductance, the blood pressure etc. are measured before conducting the Polygraph test, there are some steps
which the examiner has to prepare the subject and himself are to be followed –
● Go through the background of the case.
● Formatting questionnaire based on the background of the case.
● Apprise the subject on the objective of the test, the nature of the instrument, its various attachment and
recording.6
During the test the heart beat increase; blood pressure goes up, breathing and so on and so forth. In the
very beginning a baseline for the psychological characteristic is established by asking whose answer the
investigator known. Deviation from this pre-determined base line for truthfulness, measure by the Lie Detector,
is taken as a sign of life .This test does not involve any direct invasion of the body. The basically produces a
graph of multiple psychological parameters and hence the name Polygraph .In this test, the Polygraph taken
gives a reading of the deviation of the psychological parameter from the base line for truthfulness, which is
determined by the natural question asked it the very beginning. The graph that id produced after the
interrogation with target question, aimed to make a possible liar uneasy in his psychological reaction is
examined by an expert who would then explain their reaction, in the court and also to the law enforcement
officer to aid them in their investigation .His conclusion, which would flow from his reading of the Polygraph,
may be admitted or rejected by a judge on appreciation of the statements and the objection raised thereto by the
defense and other expert .In case of a Polygraph, the subject may or may not answer the question his
psychological reaction and the response of his answer to the analysis of that is sought to be tendered as
evidence if and when the occasion arises.7 During the Polygraph test an expert and skilled examiner will make
assessment of the following procedure –

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 Polygraph Test and Its Relevancy in Criminal Justice System

a) As assessment of examiner’s emotional state;

b) Medical fitness of the examinee;
c) To identify overly responsive behaviour specialised tests be conducted;
d) To asses overly responsive behaviour specialised test be conducted ;
e) To do factual analysis of case information and
f) To do pre-test interview and detail review of question. 8

In Polygraph three aspect of human physiology are tested viz

(a)Pneumograph tracing
(b)Electro dermal activity tracing, and
(c)Cardio vascular tracing.
The first relate to respiration, the second to skin conductor or skin resistance and the third with blood volume
and pulse rate.9

Scientific validity of Polygraph Test:

Advance in science and technology unlikely to leave our untouched, and the Polygraph is no exception.
The Polygraph is a scientific instrument which used for research in to bodily responses and their relationship
with psychological process. As an instrument, it reliable in producing a record of bodily event.10The “Validity of
Polygraph testing” means its ratio of accuracy regarding detection of deception and truthfulness. Polygraph test
take a number of form and it validity can be measured in a number of ways.11 The validity of Polygraph test is
based on the assumption that the test consistently measures the same properties. This consistency is its reliability
and it is the degree to which the test can be repeated. If on repetition the same result is obtained then it is
reliable. It also means that if the examiner on analysis of chart comes to a conclusion, the same conclusion on
the basis of same chart analysis should be drawn by another examiner. It means that the test should be
reviewable. Polygraph test is meant for lie detection; therefore, it is necessary that the test should adequately
measure the underlying trait it designs to assess. It is called “construct validity”. At present there are different
Polygraph based on different theories. This makes it difficult to established construct validity. 12 At present time
the significance of Polygraph test is going up with passing of the time. Because by the help of this technique it is
possible to detect the truth. The test is being conduct without any third degree method. In this technique the
question is put up from the accused person and the accused person has given answer of the question only in yes
or no. A Polygraph of the person subjected to test is taken and expert analyse the Polygraph and gives his/her
opinion in the court. Now the court has to decide about the admissibility of the test result. 13

Constitutional validity of Polygraph test

The main legal provision which govern the expert evidence (Lie Detector test), are in Indian
Constitution, Code of Criminal Procedure, Indian Evidence. In Indian Constitution there are various provisions
which are related with the protection of the accused person .In Indian Constitution the provision of life, liberty
and freedom has been given under Article 20 and 21. According to Article 20(3) “no person accused of any
offence shall be compelled to be a witness against himself”. This article applies only to an accused and only
speaks of self-incrimination evidence by way of compulsion. Under this Article only an accused person can
avail the protection if he is compelled to be a witness to be a witness against himself. 14Every civilized society
guarantees the right against self-incrimination as a fundamental of fair trial in a criminal offence. According to
this principle, a person accused of a criminal offence cannot be forced to incriminate himself or yield evidence
against himself. The right against self-incrimination is designed to prevent the use of law or the legal process to
force from the lips of the accused the evidence necessary to convict him. Despite the fact that the right as been
defined broadly its scope as been confined by judicial interpretations evidence that is testimonial in nature. In
other words, it has been held that the protection is available only to evidence which required a volitional act on
the part of the accused person thus rendering it testimonial or communicative in nature and it will not protect
taking of blood sample, fingerprint etc. from the accused. The protection would be available only from the time
the person is charged of an offence it does not extend to the pre-accusation or investigation stage if a strict

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 Polygraph Test and Its Relevancy in Criminal Justice System

interpretation of Article 20(3) is done. The immunity will not be available to a person against whom no
accusation has been made when a compulsory process or notice is notice is issued directing him under pain or
penalty to produce a document tough ultimately it may incriminate him for the commission of an offence. 15 The
Constitutional embodiment invigorating the ban on self-incriminating has been enshrined in Article 20(3) of the
Constitution of India.16Article 20(3) provides protection to the accused person in respect of the conviction. In
case of Sidhartha Vashist v. state17it was held by the court that the interrelationship between the ‘right against
self-incrimination and the ‘right to fair trial ‘ has been recognised in most jurisdiction as well as international
human rights instrument. The guarantee of ‘presumption of innocence’ bears a direct link to ‘right against self-
incrimination’ since compelling the accused person to give evidence would place the burden of proving
innocence on the accused instead of requiring the prosecution to prove guilt .thus right to refusal to answer
question that may incriminate a person is a procedural safeguard which has gradually evolved in common law
and bears a close relation to right to fair trial. When the question arise that that when a person may claim the
protection against self-incrimination under Article 20(3) of the Indian Constitution. In the case of State of
Bombay v. Kathi kalu Oghad18, the court observed that conducting the Polygraph by the police without the
consent of accused person is violation of article 20(3) of the Indian Constitution. The right against forced self-
incrimination is enshrined in Article 20(3) of the Indian Constitution as well as in the Criminal Procedure Code.
In this case the Bombay High Court had to decide whether compelling the accused person to undergo this test
would violate their right to silence and compel him to provide evidence against himself. In this case Palshikar j.
held that the right against self-incrimination applies only to court proceeding and not to police interrogation.
In case of M.P. Sharma v. Satish Chandra19, the Supreme Court has measured the principle
underlying Article 20 (3) of the Indian Constitution, which says that no person accused of any offence shall be
compelled to be a witness against himself. In this case it was contented before the court that that guarantee
under Article 20(3)of the Constitution against testimonial compulsion is confined only to oral evidence of a
person standing his trial for an offence when he is called to the witness stand. The Supreme Court has said by
rejecting this contention that there is no reason to confine the content of the Constitution guarantee to its barely
literal import, and therefore, to limit it would be to rob the guarantee of its substantial purpose and to miss the
substance for the sound as stated in American decision. After saying this, the Supreme Court has made the
following observation:
“To be a witness is nothing more than to furnish evidence and such evidence can be furnished though
the lips or by production of a thing or of a document or in other modes”.
These observation shows that a person can be a witness and can provide evidence against himself by
different varieties of modes. One method would be to appear for medical examination and, thus, to enable the
prosecution to some evidence against him.
In Ram JawayyaKupar’s case20it was held by the court that in absence of any law any infringement in
fundamental right must be struck down as unConstitutional Lie detection test comes under the general power of
investigation (section 160-167, Cr.P.C) But it must be realised that it is a choice of the person to allow
himself/herself to be put to Polygraph test or not and it should not be left to the discretion police. Except it is
allowed by the law it must be seen as illegal and unconstitutional. But if this test is conducted by the
investigating authority, it must be conduct with the free consent of the person. Free consent means that it is
chosen and is not given under coercive circumstances for example if a person says that “ I wish to take a Lie
Detector test because i wish to clear my name” it shows that he want to undergo with Polygraph test but it is
still to be shown that whether this voluntariness under coercive circumstances. If a police officer told to a
person “take a Lie Detector test and we will let you go”, it shows that the police officer has linked up the
freedom to go with the Lie Detector test and as such it cannot be held voluntary. These kinds of statement are
held to be self-incriminatory.
If a person has committed a heinous crime and he is lying or his act is against the security of Country,
such person can not take the benefit of right against the self-incrimination under the Article 20(3) of the Indian
Constitution. It means that under such circumstances this test may be conducted by the investigating agency to
find out the truth. In case ofNandinisathpathivP.L.Dani21 , the (a former Chief Minister of Orissa) has made
complaint that she was being prosecuted for her refusal to answer police question about a corruption case lodged

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 Polygraph Test and Its Relevancy in Criminal Justice System

against her. She that she can not compel to give answer of the question asked by the police officer as she has
right against self-incrimination under Article 20(3) of Indian Constitution and she has also protected under
section 161(2) of Cr.P.C. In such circumstances it depend upon the nature corruption .if the lady has committed
simple mistake or not a heavy corruption then its ok otherwise she may compel to undergo the Lie Detector test.
There must be Article 20(3) but there is loss in using Lie Detector test depending upon the gravity of facts of the
cases.
In Ramchandra Reddy v. State of Maharashtra22, It was held by the court that“The Lie Detector test is
an examination which is conducted by various probe attached to the body of the person who is interrogated by
the Expert. In this test the heart rate, the skin conductance is measured. The underlying theory of this test is that
when people lie they become nervous. The heart beat increases, blood pressure goes up, breathing rhythm
changes, perspiration increases, etc. A baseline for this physiological characteristic is established by asking the
subject questions whose answers investigators know. Deviation from the baseline for truthfulness is taken as a
sign of lie. Consequently, there is no direct incursion of the body. In this test the Polygraph is taken which gives
this reaction and an expert would then explain these reactions in the Court which would be his reading of the
Polygraph from which would flow this conclusion which are to be admitted or not admitted by a judge on
appreciation of the statement and the objections raised thereto. In this case the witness may answers or may not
answers the questions. The response of his answers to questions as recorded on the Polygraph analysis of which
is required to be tendered as evidence if and when the occasion arises.”
In D.K. Basu v. State of West Bengal23, the Honn’ble court has emphasised on the importance of the
preventing the cruel, inhuman, degrading treatment while a person is taken into custody. In the present context
involuntary and forcibility administration of any of the tree scientific techniques like Narco-Analysis test,
Polygraph test and Brain Mapping in a forensic laboratory or in a hospital, physically confining the subject will
fulfil the requirement of custodial environment and thus will attract the provision under Article 20(3) and
Article 21 of the Constitution .This is applicable not only for the accused ,suspect ,witness but also for
investigation who questioned in the of investigation without being brought in the record as witness. It is clear
that each of the three of the tree scientific techniques causes the subject to lose his control over his responses. It
is clear from the language of the Article 20(3) and Article 21 of the Constitution that the involuntary
administration of the above three scientific techniques will amount to cruel, inhuman and degrading treatment in
the context of Article 21.24
In the case of Jitubhai Patel v. State of Gujarat25, since the state had filed affidavit that it shall not
conduct the test on the accused person without his consent the issue of admissibility of scientific evidence
becomes academic only. It may be decided at some different occasions. In this case it was held that scientific
tests such as Polygraph test, Narco-Analysis test can be conduct without taking the consent of the accused
person. it should be kept in the mind that there has been great scientific advances and there is subtle difference
between old test methods of blood testing or fingerprinting and Polygraph and Narco-analysis test. Old tests
were of the nature of physical tests, but the new scientific tests are something more than physical tests. A
general opinion is being formed that these tests should be applied not only to ordinary criminal but even to
VVIPs. If these scientific methods are not encouraged then use of third degree methods would be encouraged
tests.
The principle of protection from self-incriminating evidence is founded on the presumption of
innocence; the maxim “Nemoteneturseipsumprodere” which means no one is bound is bound to accuse
himself.26As far as the Indian law regarding this is concerned the protection against self-incrimination continues
to be more or less same as in the English common law. 27 The protection has been given to the accused person
accused from self-incrimination In Article 20(3) of the Indian Constitution and section 161(2) of Code of
Criminal Procedure. It has been given under Article 20(3) and section 161(2) code of criminal procedure that,
“No person accused of an offence shall be compelled to be a witness against himself” and “Such person shall be
bound to answer truly all questions relating to such case put to him by such officer, other than questions the
answers to which would have a tendency to expose him to a criminal charge or to a penalty or forfeiture”
respectively. In the Polygraph test no force is used. The underlying principle of the Article is presumption of
innocence of the accused person in every criminal prosecution, where the burden of proving the guilt lies on the
prosecution. According to this principle, it is the duty of prosecution to discover facts and produce evidence to

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prove the guilt before the court .The natural inference would e that extracting information of facts from the
accused person through Lie Detector devices would clearly come under and hit the principle of self-
incrimination, provided under Article 20(3).
The idea behind the protection against self incrimination is to support a free situation in which the
accused can be certain to furnish evidence in courts and be of significant aid in elucidating truth in a case, with
reference to material within their awareness and in their possession.28 Anything caused, by any kind of threat or
inducement by a person directed towards the accused or likely to be accused of any offence, which causes him
to act involuntarily and further the case against himself in any prosecution against him or which results or is
likely to result in the incrimination of that person qua any offence, is violative of the fundamental right
guaranteed under clause (3) of Article 20 of the Constitution of India.29 Involuntary is defined as an admission,
especially by an individual who has been accused of a crime that is not freely offered but rather is precipitated
by a threat, fear, torture, or a promise.30
The phrase compelled testimony is read as evidence procured not merely by physical threats or
violence but by psychic torture, atmospheric pressure, environmental coercion, tiring interrogative prolixity,
overbearing and intimidatory methods and the like.31The purpose of lie detection is to elicit the truth from the
suspects devoid of any physical coercion.
Protection against self incrimination was instrument for the protection of the innocent and not intended
for the acquittal of the guilty.32 The framers of the Bill of Rights believed the rights of society were supreme to
the rights of the criminal.
In case of Selvi v. State of Karnataka33, there was question before the court relating with the relevancy
of Polygraph test. In this case the court has to decided that whether conducting the Polygraph test on the subject
without his/her consent is constitutionally valid or not. The court held that Article 20(3) protects an individual
choice between speaking and remaining silent, irrespective of whether the subsequent testimony proves to be
inculpatory or exculpatory. The main object of Article 20(3) is to prevent the forcible ‘conveyance of personal
knowledge that is relevant to the facts in issue’. The result obtained from each of the impugned test bear a
‘testimonial’ character and they cannot be categorised as material evidence. In this case the Supreme Court has
laid down some guidelines regarding Polygraph test also. Supreme Court further held that polygraph test should
not be conduct on the accused person without taking his/her consent. If such test conducts without taking the
consent of the accused person, it would be violation of Article 20(3) of Indian Constitution.
InNajeebcase 34,the court had on March 15 reserved its order after the counsel appearing for the
students submitted that the “lie detector test is unconstitutional and illegal unless it is voluntary.”

Evidentiary Value of Polygraph Test

Section 3 of the Indian Evidence Act defines evidence as “Evidence” means and includes
(1) All statement which the court permits or requires to be made before it by witnesses, in relation matter
of fact under inquiry ;
(2) All document including electronic records produced for the inspection of the court;
Such documents are called documentary evidence. 35
According to above mentioned definition of ‘Evidence’ answers recorded during Narcoanlysis or
Polygraph tests cannot permit them to be admitted as they do not fulfil required conditions, Factors and
provisions of law. Court may, according to the given definition ‘permit’ a statement which at the most may be
called as evidence but that would not render it to become admissible automatically. The court may either admit
the permitted statement or reject it on definite consideration, principles and rules of law, as its admissibility
depends on number of factor.36
The statement recorded of the person put under Lie Detector test hit the principle and rule of
voluntariness, because they are either recorded in the state of semi-consciousness or information are extracted
through so called scientific equipment and methodologies which scientist themselves question for reliability.

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 Polygraph Test and Its Relevancy in Criminal Justice System

Cardinal rule of evidence and criminal jurisprudence as well, is that the person making the statement must be in
a fit state of mind.37

Confession and Polygraph test under Indian Evidence Act, 1872

The main object of putting a suspect /accused to Polygraph test is to take out or at least to know how
far she or he has awareness or information about the crime under enquiry and also to extract acknowledgement
of guilt of the person.
Some people contend and try to widen the scope of confession to include oral and written statement in
reference to Polygraph test etc., which in their view amount to confession. The contention is based on false
notion and contradicts clear provision of law.

II. Conclusion
By and large, lie-detector evidence has limited judicial recognition. In a few courts Polygraph test
results have been recognized for their value as an aid to investigation and in some cases the expert evidence
relating to Polygraph has been accepted. The experts in areas like fingerprints, firearms, identification
questioned documents etc. have been widely acclaimed. But the Polygraph experts have not received acceptance
and recognition from the court. It is unfortunate because the Polygraphists have established 95 to 98% accuracy
of the Lie Detector in detecting deception or the truthfulness of the subjects in criminal investigations. On the
basis of relevant scientific data on Lie Detector, it is strongly felt that the courts should accept deception test
because it can furnish a fairly effective method and technique for the exposure of deception in a subject. Since
Polygraph interrogation is the best available method to detect deception, the time has come for the courts to
admit this type of evidence.

Reference
[1]. Donald Krapohl and Pamela Shaw, Fundamentals of Polygraph Practice 2(Elsevier, UK, 2015).
[2]. Ibid.
[3]. Dr. Ganapati M. Tarase, Dr. Prakash D. Haveripeth& Dr. M. S. Ramadurg, “Scientific and Legal Procedure of Polygraph Test” 2(1)
[Link].Innov5(2013).
[4]. “Constitutional validity of and evidentiary validity of scientific test”49:4 Journal of Indian Law Institute 529 (2007).
[5]. Supra 2 at 7.
[6]. “In Focus Lie Detector” Law Z 10(2010).
[7]. Supra6,550.
[8]. Satyendra K. Kaul and Mohd. H. Zaidi, Narco analysis, Brain mapping, Hypnosis and Lie Detector Test, In Interrogation of suspect
594 ( Alia Law Agency, Allahabad, 2008).
[9]. Ibid.594.
[10]. Antony Gale (ed.), The Polygraph Test, Lies Truth and Science 8(Sage Publication, London,1988)
[11]. Deepak Ratan and Mohd. H. Zaidi, Forensic Science in India and the World 493(Alia Law Agency, Allahabad, 2008).
[12]. Id.494 .
[13]. Supra 6,580.
[14]. “Constitutional and evidentiary validity of new scientific tests”,49:4Journal of the Indian Law Institute 532,(2007).
[15]. A search warrant leading to discovery of contraband is a perfect example.
[16]. Supra20,533.
[17]. AIR 2010 SC 2352.
[18]. AIR 1961 SC 1808.
[19]. AIR 1954 SC 300.
[20]. 1955 (2) SCR 225.
[21]. AIR 1978 SC 1025.
[22]. 2005 (1) CCR 335 (DB).
[23]. AIR 1997 SC 610.
[24]. Supra 1, 110.
[25]. 2005 (10) SCC 545.
[26]. Noor Mohmed Jamal Bhai Latiwala v. State of Gujarat MANU/GJ/0131/2004
[27]. M.P. Sharma and Ors. v. Satish Chandra, District Magistrate, Delhi and Ors. 1954 INDLAW SC 154
[28]. Wigmore on Evidence, Vol. III, page 307
[29]. The State of Bombay v. Kathi Kalu Oghad and Ors. AIR 1961SC 1808
[30]. Supra 44
[31]. Nandini Satpathy v. P.L Dani and Another AIR 1978 SC 1025
[32]. Dr. R.E. House , First Annual Meeting of the Eastern Society of Anaesthetists 1925, Herzog A.W. ,Medical Jurisprudence
Indianapolis
[33]. AIR 2010 SC 1974
[34]. Court to pass JNU students’ polygraph test order on Mar 30 available on [Link]
pass-jnu-students-polygraph-test-order-on-mar-30 4588281/( visited on date 08/02/2018)
[35]. Section 3,Indian evidence Act, 1872.
[36]. YawerQazalbash, Law of Lie Dtectors,166 (Universal Law Publication,Allahabad,2011).
[37]. Id.,167

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