Chaturbhuj Pradhan's Appeal Dismissed, DNA Test Ordered to Resolve Paternity Dispute
In a significant ruling, the Supreme Court of India has dismissed the appeal filed by Chaturbhuj Pradhan, thereby upholding the decision of the lower courts to mandate a DNA test to determine the paternity of Amar Pradhan. The judgment was delivered by a bench comprising Justices Sanjay Karol and Nongmeikapam Kotiswar Singh in Civil Appeal No. 8272 of 2026, stemming from Special Leave Petition (Civil) No. 4016 of 2026.
The controversy revolves around the paternity of Amar Pradhan, who claims to be the son of Chaturbhuj Pradhan, born out of a relationship between his mother and Chaturbhuj in 1999. Amar seeks to establish his paternity in order to claim a share in Chaturbhuj's property. Despite Chaturbhuj's acquittal in a previous criminal case concerning the same allegations, the Supreme Court found the need for a DNA test indispensable to conclusively resolve the paternity question.
The court's decision emphasized that DNA tests should not be ordered routinely but are permissible in exceptional cases where no other evidence suffices to resolve the controversy. The judgment also highlighted the need to balance individual privacy rights against the child's legitimate interest in knowing their biological parentage, especially when inheritance rights are at stake.
The Supreme Court referred to several precedents, including the landmark cases of Goutam Kundu v. State of W.B. and Dipanwita Roy v. Ronobroto Roy, which outline the principles under which DNA tests can be ordered. The court underscored that the legitimacy of a child should not be jeopardized without compelling reasons and that privacy rights, while significant, are not absolute.
In rejecting the appeal, the court noted that Chaturbhuj's consistent denial of paternity left no other recourse but to order a DNA test. The court dismissed the argument of res judicata, as previous findings in maintenance proceedings did not constitute a proper determination of paternity.
This judgment is expected to have far-reaching implications on similar paternity disputes, reaffirming the judiciary's role in balancing the rights of individuals with the pursuit of truth and justice.
Bottom Line:
DNA test can be ordered in civil cases when the question of paternity is directly in issue and no other evidence is sufficient to resolve the controversy.
Statutory provision(s):
Indian Evidence Act, 1872 Section 112, Civil Procedure Code, 1908 Section 11, Section 125 CrPC, Indian Penal Code, 1860 Section 376
Chaturbhuj Pradhan v. Amar Pradhan, (SC) : Law Finder Doc id # 2909755
