Chaturbhuj Pradhan v. Amar Pradhan 2026 INSC 600 - DNA Test Direction Upheld

Evidence Law - DNA test - When the Court is confronted with the question whether or not to order a DNA test, the only test to be satisfied is whether the result of the DNA test is directly in issue and whether any other evidence-on-record can substitute for the answer that may be arrived at through this scientific process. Also, whether it is in the best interest of the parties and/or justice. [Context: SC upheld concurrent orders of the trial court and the Chhattisgarh High Court directing a DNA test of the respondent X to determine his paternity vis‑à‑vis the appellant, Applying the “balance of interests” and “eminent need” tests from prior precedents, the Court held that paternity is directly in issue in civil suit for declaration and share in property, there is no other adequate evidence on record, and earlier maintenance proceedings did not operate as res judicata. Emphasising that CP’s privacy must be balanced against Amar’s lifelong quest for closure and potential inheritance rights, the Court dismissed the appeal and directed the civil court to proceed with the DNA test and then the suit based on its result.]