Forensics in Drug Cases: How Mandatory Forensic Procedure Operates under the Narcotic Drugs and Psychotropic Substances Act, 1985

Author(s)	Akhila Sawan, Shivanshu Katare
Country	India
Abstract	In a drug case under the Narcotic Drugs and Psychotropic Substances Act, 1985 (NDPS Act), the laboratory report is often the heart of the prosecution. The report is only as reliable as the steps that come before it: weighing, sampling, sealing, inventory, storage and dispatch. This article explains those steps in simple terms and asks how far the law treats them as mandatory. It traces the Supreme Court's movement from a strict reading of section 52A in Union of India v. Mohanlal to the "substantial compliance" approach in Bharat Aambale v. State of Chhattisgarh. It then reviews recent decisions from 2025 and 2026 to see where courts forgive lapses and where they acquit. The article argues that the present law is fairer to the prosecution than before, but that the test is still vague and the burden of proof is unclear. It closes with practical suggestions for investigators, defence lawyers and courts.
Keywords	NDPS Act; section 52A; forensic evidence; chain of custody; sampling; substantial compliance; Standing Order 1/89
Discipline	Other
Published In	Volume 4, Issue 5, September-October 2026
Published On	2026-10-22

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Advanced International Journal of Multidisciplinary Research