CASE COMMENT: AMLESH KUMAR V. STATE OF BIHAR (2025)

The use of scientific methods in criminal investigations always raises very grave constitutional issues in India. In terms of these methods of investigation, Narco Analysis stands as one of the most controversial ones, since it infringes upon the person's right to mental autonomy and personal liberty. Although investigative bodies may justify their actions by saying that it helps them uncover the truth, however, the constitutional courts have always held the position that criminal investigation is subordinate to the fundamental rights of individuals. Amlesh Kumar v. State of Bihar (2025) is another important case that needs mentioning within the field of Indian constitutional and criminal jurisprudence. Issues addressed in this case included the legality of carrying out narco-analysis on bail applications, the legal basis of conviction based on voluntary narco-analysis, and whether the defendant has an unrestricted right to undergo such analysis.