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AARUSHI TALWAR: CRITICAL ANALYSIS FOR FORENSIC SCIENCE

ayush chandra
ChatGPT Image Jul 9, 2025, 12_03_48 PM
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This article has been written by Aaliya Noorudheen, a law student at Symbiosis Law School Hyderabad.

***This article has been selected for LegalOnus Law Journal (LLJ) Volume 1 Issue 9 2025

ABSTRACT

The Aarushi Talwar case is a landmark in the texts of Indian criminal justice, marked by its complex web of forensic evidence and legal complexities. This paper consists of an elaborate analysis of the forensic evidence that has been mentioned in the case, discovering various factors and the broader impact of forensic science in India. With the help of an in-depth analysis of the methods used in forensic science in this case like DNA testing, narco-analysis, and crime scene reconstruction, etc. This paper aims to analyse and interpret the intersection between science, law, and justice. By taking into factor the insights from forensic practices of different jurisdictions, the paper provides a view of the problems and opportunities present in forensic investigations particularly in high-profile cases like the Aarushi Talwar case. By incorporating legal precedents, ethical considerations, and scientific advancements, the paper dives into the dynamic area of forensic evidence, highlighting its importance in shaping decisions and guaranteeing justice.

Keywords: Aarushi Talwar Case, Forensic Evidence, DNA Testing, Narco-Analysis

 INTRODUCTION

The Aarushi Talwar murder case deals with many complex aspects of forensic science and legal proceedings in the judicial system of India. Because of the heinous nature of the murder of a young girl and Hemraj, who was the family’s domestic servant, the case had a large impact on the collective consciousness of everyone in the nation, which raised thought-provoking questions about what is fair and what is true. This paper goes into the complex forensic analysis of this case, and by going through the layers of investigation in order to unravel the complexities and controversies that surround this case.

The case had widespread attention due to lapses in investigation, conflicting theories, and controversies that revolved and surrounded the handling of evidence aspect, as well as the use of narco-analysis. The Parents of Arushi were initially convicted but they were later acquitted by the Allahabad High Court, highlighting the complex problems and struggles within the Indian judicial system.

This case was able to gain attention because of the investigative lapses and controversies that surrounded the handling of evidence. Further, it had also the controversial factor of use of narco-analysis, bringing the ethical and legal implications of such forensic techniques in question. by a comparative analysis of international jurisprudence, the paper explores different approaches to the forensic psychology, highlighting the delicate balance that exists between investigative necessity and the individual rights. When examining the examination of this case we face the challenges of balancing investigation, with legal obligations highlighting the significance of maintaining ethical norms and protecting constitutional rights in the quest for fairness.

RESEARCH OBJECTIVE

RESEARCH QUESTIONS

LITERATURE REVIEW

Narcoanalysis – A Legal Prospective, Bhavya Sharma

The paper takes a close look at how narcoanalysis is used in criminal investigations, especially in relation to cases like Aarushi Talwar’s. It points out the legal and ethical problems with narcoanalysis, stating that it is controversial and does not have clear rules. Ultimately, the paper asks for a balance between using science to resolve crimes and making sure fair treatment for everyone in the justice system.

NARCO VIDEOS, FORENSIC PSYCHOLOGISTS AND THE TRUTH-TELLING APPARATUS Tracing Evidence, Law and Media Trials, Jinee Lokaneet

The document offers a holistic analysis of the Aarushi-Hemraj murder case in India, with a focusing on the use of narco-analysis videos and the role of forensic psychologists in guiding legal narratives and public opinions. It talks about the Supreme Court of India’s landmark judgment barring the involuntary use of narco-analysis and other forensic techniques, while emphasising on the loophole allowing for their use in cases of corroborative evidence through “recovery.”

Critical analysis of Arushi Talwar murder case, Pragya Jain & Taniya Roy

The analysis conducted offers a holistic examination of the both the legal and forensic aspects that surrounds a high-profile incident. By critically analysing, the authors had devolved upon the investigative procedures, judicial proceedings, and the role of forensic techniques such as narco-analysis and polygraph tests in discovering evidence.

Narco-Analysis Test in Indian Criminal Justice System, Rahul Negi

the document offers a detailed analysis of the use of Narco-Analysis tests in the Indian criminal justice system. The document acknowledges the potential of the Narco-Analysis for aiding investigations by giving leads in challenging cases also highlighting the challenges. The document highlights the complexities between the useability of Narco-Analysis and its violation of constitutional rights, highlighting the need for strong safeguards to protect the rights of subjects.

EVIDENTIARY VALUE OF NARCO ANALYSIS TEST IN INDIA Anand Rukmanagoud Patil

The document offers an in-depth analysis of narco-analysis, exploring its legal, ethical, and practical aspects. By scrutinizing narco-analysis in the broader frameworks, raises concerns about coercion, consent, and human rights violations. It also talks of challenges for investigating agencies, offering practical solutions to address them.

CRIME SCENE INVESTIGATION WITH REFERENCE TO AARUSHI TALWAR CASE

Background of the case:

Nupur Talwar v. State of UP’ is commonly known as the “2008 Noida double murder case or the Aarushi Talwar case”. In this case, Aarushi Talwar, 14-year-old girl and her family’s domestic helper, Hemraj Baniade, were both found callously murdered at Aarushi’s residence.

Based on the reports of the 2 CBI teams, The court of sessions of Ghaziabad has held the Talwar couple liable for the alleged commission of crime. The conviction was challenged in the High Court of Allahabad, which overturned the conviction of the couple on October 12th 2017. The HC also criticized the Central Bureau of Investigation regarding the handling of the case, particularly the theory behind Hemraj’s Murder.

Timeline of important events with respect to the Crime Scene Investigation

On May 16th2008, Aarushi was found dead on her bed with signs of sharp-edged weapons on her neck by her parents. Rajesh Talwar (father of the deceased) asked the security of their flat to inform the police about the commission of the crime and the absconding of his domestic helper. Before the investigating officers arrived at the crime scene, the primary focal point was crowded by curious onlookers. After completing the inquest proceeding, the dead body was sent to the mortuary for post-mortem procedures; afterwards, it was handed over to the parents for performing the last rites.

On May 17th, 2 of the acquaintances (PW13 & PW14) of Mr Talwar, noticed some blood stains on the staircase leading to the terrace; the same was informed to the S.I. Data Ram. On opening the terrace door, the body of Hemraj was seen lying in a pool of blood. After the inquest proceeding, his body was also sent to the mortuary for post-mortem analysis.

On May 23rd, Rajesh (father of the deceased) was arrested by the police for being the prime suspect in the double murder.

On May 31st, the Govt of UP, through a notification, transferred the case investigation from local police to CBI.

On June 13th, based on the Polygraph and narco-analysis tests conducted at CFSL Delhi, Krishna, the compounder of Dr Rajesh was arrested by the CBI. He was further subjected to a Polygraph and narco-analysis test at FSL Bangalore.

On June 14th, Krishna was produced before the magistrate, and the magistrate granted 3 days of police custody for further investigation. Later on, 17th June granted 6 more days of police custody.

Subsequently, the narco-analysis was conducted on 3 other suspects other than Dr Rajesh has confessed their collusion in the crime, on the basis of which CBI seized a blood-stained khukhri and a pant. As the investigating team couldn’t extract DNA from the blood on the khukhri, all three of them were released.

Lapses in the Crime Scene Investigation conducted:

In this particular case, the reports submitted by the investigating team shows the lack of care in the examination of the crime scene. The investigating officer failed to gather proper information regarding the internet usage from the router and overlooked vital areas such as the terrace on the first day, and thus missing crucial evidence and the presence of Hemraj’s body on the terrace. Additionally, important items including the clothing worn by the Talwars at the time and the alleged murder weapon- a golf club- were not seized until much later. Furthermore, inadequate measures to secure and preserve the crime scene allowed unauthorized individuals to enter, posing a risk of evidence tampering which could significantly impact future investigations. The CBI also disregarded additional evidences like a handprint with blood in the outdoor wall or a blood-stained khukhri found elsewhere.

The reporters and journalists were permitted to roam freely on the terrace and take photographs, leading to the contamination of the evidence. The CBI gathered bloodied water from the cooler and removed blood stains from the roof that had been overlooked by the Noida police. The investigation team caused significant confusion regarding Hemraj’s blood found on a pillow cover. The defence claimed that the pillow cover was discovered in Krishna’s room, while the prosecution asserted it was found in Aarushi’s room. Consequently, one of the most condemning pieces of evidence was also compromised.

The court has concluded that at least one of the accused was awake on the tragic night based on the internet usage. However, this contradicts the testimony given by the telecom witness. The records indicate a similar pattern of activity between the fateful night and May 16th from 6 a.m. to 1 p.m. Additionally, in cross examination, the telecom witness admitted not being certain as to whether data would transfer between modem and ISP if they are on while the computer and laptop are switched off. This implies that it is possible for CBI to obtain internet surfing history from the service provider if the internet was active; thus, this could have served as evidence.

The clothing of the suspect was sized almost a month later. There is a strong possibility that by that time, the garment has been washed, dried, and ironed. This highlights the lack on the CBI’s part as they should have seized the clothes on the day of discovery. Subsequent testing revealed only Aarushi’s blood on the clothes, indicating their contact with her body after she was found murdered in bed. Furthermore, since there was no trace of Hemraj’s blood on their clothing, it rules out their involvement as suspects in his case.

The reason behind the crime has been determined based on the reconstruction of the crime scene.[1] Dr Dahiya’s report, which present his findings, served as the basis for this determination. The CBI concluded from Dr. Dahiya’s report that Hemraj’s blood was found on Aarushi’s pillow and this inferred that her father killed both individuals after seeing them in a compromising situation. However, this inference can be dismissed as forensic scientist B.K Mahapatra testified that no evidence of Hemraj’s blood was found in Aarushi’s room. Without establishing intent, the accused cannot be convicted. In this instance, the prosecution failed to prove any motive of the parents to harm their own daughter. Their hypothesis was that they discovered their daughter in a compromising position with their servant and subsequently harmed both out of anger; however, no supporting evidence was presented for these claims. In the case of Jagannath v State of West Bengal[2] and M. Mammutti v. State of Karnataka[3], it was established that accused intent can be established by evidence but cannot be presumed.

In conclusion, it is observed that “the success or failure of criminal investigations starts and ends at the scene”[4] according to Locard’s Principle when 2 objects come in contact, there is always an exchange of material, one may succeed in avoiding the being seen or heard at the scene, but he cannot avoid coming in contact with his environment. The crime scene is the wealth of clue materials and other evidences, the opportunity to do the examination is available once only, so if it is not fully exploited the wealth of the information about the crime is lost. This particular case is a perfect example of non-exploitation of the crime scene, as a result of which no has been committed for the double murder case till date.

NARCO-ANALYSIS WITH REFERENCE TO AARUSHI TALWAR CASE

Narco-analysis is a Chemo-Physiological Test conducted as a type of interrogation on a suspect to extract information, which could aid the criminal investigation. It involves the administration of a psychoactive drug, typically sodium pentothal or sodium amytal. This drug, famously known as truth serum induces a state of semi-consciousness and the person becomes for susceptible to suggestions and inhibition, leading to disclosure of information that they might otherwise withhold consciously.

In this case, Narco-Analysis played a very important role in attempting to unravel the mystery of this case. This test was conducted on three of suspects, which were Rajkumar, Krishna and Vijay Mandal. And as a result, unique insights surrounding the murders.

As per Krishna’s Narco-analysis, the trio, including Hemraj, were drinking together on the night of the murders. He made a mention of a type of knife, Khukri. Which, according to him, was the weapon with which the murder of Arushi and Hemraj was committed. He also alleged that Rajkumar and Vijay were responsible for the killings, possibly motivated by Rajkumar’s purported interest in Arushi. He suggested that there was quarrel which led to the death of Arushi and then to Hemraj.

In Vijay’s test, provided with corroborating details indicating his presence with Hemraj and Krishna on the night of the murder. His evidence aligned with Krishna’s account mentioning the presence of the murder weapon and suggesting Hemraj was killed after Arushi.  He also indicated Krishna and Rajkumar, claiming they got caught in a drunken altercation that turned fatal.

Rajkumar’s session corroborated involvement of Krishna in the murders. According to him, Krishna was the main perpetrator, indicating Krishna attempted to assault Arushi which led to her ultimate death. After her death, Hemraj confronted Krishna, leading to his death as well.

However, admissibility of such evidence in court remains a hot topic. In India, the apex court has made it clear that narco-analysis alone are inadmissible in the court of law. The validity of this test is often challenged in court, but concerns regarding its ethical implications and potential violation of suspects rights. Thus, while Narco-analysis might be a tool for getting investigative leads, its evidentiary value in court remains limited and required to have some corroborative evidence to be considered admissible.

In the present case, it was inadmissible in the court since it was standalone evidence with no corroborative evidence whatsoever. Apart from being standalone evidence, there were a lot of issues that were flagged down once the videos of the Narco-analysis were made public.

The video that came in public was only partially available and was potentially very edited. This raised concerns regarding authenticity, accuracy and credibility of the information extracted from the suspects and the possibility of tampered and manipulated evidence as well.

While under the drug-induced state, the subjects were seemed to have limited to no control over themselves. In the video its clear how the examiner had to constantly try and keep her subjects awake and coherent. This raised ethical concern about the validity of the information obtained, as in the state the subjects where they were susceptible to suggestion or coercion.

The question technique employed by the examiner was also very concerning since rather than sounding interrogative, it appeared to be suggestive and coercive. The subjects were seen to be forced or pushed to give specific answers.

The narratives given in the Narco-analysis seemed contradictory and certain gaps in the story that didn’t seem to fill. Subjects provided conflicting accounts and speculative statements.

Keeping all these in perspective, challenges regarding this forensic technique are highlighted in this case. The ethical and legal concerns, lack of corroborating evidence, along with potential for coercion raises creates doubt about the validity and admissibility of this evidence.

Narco-Analysis is not considered to very reliable, according various studies conducted by medical association in US which adhere to the fact that truth serums do not induce truthful statements and subjects are in condition of trance might not eliminate false and misleading answers[5]. In the case of Twonsend v. Sain[6], the court held that confession given by the petitioner was held constitutionally inadmissible, since during session of narco-analysis, his will was overborne by the truth serum drug.

This forensic technique is very controversial and their admissibility of evidence obtained through the technique raises legal and constitutional concerns in India. The admissibility of this evidence is a subject of debate, primarily due to its potential infringement of Article 20(3) of the constitution.

This section guarantees protection against self-incrimination, a fundamental principle in criminal jurisprudence. Courts have held that compelling individuals to undergo this test against their will violates their constitutional rights.

In the landmark case of Selvi vs. State of Karnataka[7], the apex court ruled that conducting this test without prior consent of the accused violated Article 20(3) of the constitution. The judgement highlights the need of consent of the subjects and strict presence of experts during the test. Though the information obtained through this method is not conclusive in nature and must be corroborative with the other evidences.

In the case of Santokben Sharmabhai Jadeja v. State of Gujarat[8], the court held that due care and supervision of medical professionals is an imperative while conducting the narco-analysis and subjects must be under minimum health risk. However, the concerns regarding the infringement of individual rights still persist.

There have been times when courts have recognized the utility of this technique, especially in cases where traditional interrogation methods have not yielded any results. As iterated in the case of Rojo George v. Deputy Superintendent of the police[9], where the court acknowledged the need of a scientific techniques to investigating new leads in complex case, provided they were conducted under the supervision of experts.

In case of Dinesh Dalmia v. State[10], it was established the test is not inherently violative of constitutional rights of an individual, unless the information extracted from the subjects are incriminatory in nature. This case highlights that subject must be a part of the test voluntarily and the test should be conducted with adherence of constitutional principles.

Despite the legal concerns of the practice, there have been successful and effective use of this forensic technique in solving high-profile such as the Malegon Blast Case and the Mumbai 1992 Blast Case.

In the significant ruling in the Fake Stamp Paper Case[11], 2004 Bombay High Court addressed the issue of narco-analysis stating that the test in itself is not against self-incrimination under article 20(3) of the Constitution, however the evidence collected through this technique is not admissible in the court of law. But it can be used as an investigative tool to recover information and that evidence can be used as corroborative evidence. The court passed a special court order to allow the Special Investigation Team (SIT) in order to conduct these tests on the accused person, The verdict deemed the evidence obtained through this method admissible, differentiating between statements made to police and testimonies given under oath.

Another significant case of Ramchandra Reddy & ors. v. State of Maharashtra[12], the Bombay High Court upheld the legality of using P300 or Brain Finger-printing, lie-detector tests and narco-analysis. This ruling established the validity of using narco-analysis along with other scientific tests as well.

To conclude, narco-analysis as an interrogative tool has raised several eyebrows in India and sparked multiple debates. In recent times integration of these techniques in criminal investigations, there remains a lack of clear legal sanction and safeguards to prevent potential abuse.

NARCO-ANALYSIS TEST: COMPARATIVE ANALYSIS

Nacro-analysis test is one of the most beneficial and self-incriminatory methods of collecting evidence using forensic psychology. This entrails with a lot of social, legal and moral issues and such a test have been restrictive in a lot of supranational countries like UK, USA but again in comparison to Israel, Japan and India they are taken into consideration to advance the criminal investigation and finding out new information.

It is known as the “Truth Serum Test” and has not received any judicial support from ab initio since an individual has no control to what extend it can self-incriminate thus it does not come within the status of competent evidence to be admissible in court of law or even to facilitate in the crime scene investigation. It is also held inadmissible as it is not an involuntary confession and there is a preponderance against self-incrimination in US Constitution and is a violation of the Fifth-Amendment i.e. right to remain silent.

Court has often excluded such confessions under the influence of drugs. One such famous case is Townsend v. Sain in which the US Supreme Court ruled that confessions produced by admission of drugs are unconstitutional and are coerced in nature thus not reliable[13]. In Frye v. United States where evidence of lie detector test was produced before court and the same was rejected as the technique was not in general acceptance[14] and in another case of People v. Jones it was clearly retaliated that without general acceptance that would not be enforced[15].

The US Supreme court reasoned in Lindsey v. US that such statements other than being self-incriminatory will also be scientifically unreliable, self-serving and hearsay evidence[16]. In State v. Hudson where the accused was convicted of raping a woman, the physician introduced his testimony that under the influence of truth serum he denied guilt but then such a test is not absolute certainty as per science such test bore shadows of manipulation[17].

But again, expert opinion based on the test can be admissible in court and subjected to cross-examination and in line to the same contention in Brown v. State it was said that expert opinion is not just based on the tests but also their own psychiatric analysis and thus admissible[18].

Narco-analysis in UK disrupts two most essential fundamental rights one being the privilege of self-incrimination and the other right to fair trial. The test has no place in any part of the investigation let alone the admissibility in courts. In R v. Turner[19], the court gave its observations on expert opinions and stated that in order of it being admissible it must provide the court with information that is likely outside the knowledge of court helps the court in forming the judgment, secondly, the person witnessing must be an expert in that particular field, third being impartial to the entire case and lastly, the opinion should meet the conditions of satisfactory reliability.

The Full code test under UK law has two stages to convict an accused. First being the evidentiary stage where the prosecutor has to ascertain the reliability and assess the evidence. Second, being the public interest stage where the prosecutor has to ascertain whether the case is of public interest if this test is not sufficiently applied then comes the threshold test where the prosecution has to assess all the evidence available to him to ascertain if they are reliable. UK is a signatory to ICCPR and under Article 7 of the same, “No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment[20]“ so even in line with that India and its legal implications with narco-analysis works.

Use of narco-analysis in Israeli legal proceedings dates back long back to 1960s. In a want to improve the national security the government introduced polygraphs and narco-analysis as it is one of the useful tools for identifying and preventing harm to the country. They started using these techniques in interrogation of suspected criminals. Initially in 1966 these evidences were not admissible in the court of law but they were used to gather information and build cases against the suspects.

Then these techniques evolved to be admissible in the court of law, the Israeli Supreme Court in 1995 ruled that polygraph and narco-analysis could be admitted as evidence in criminal cases but only under certain conditions. It was up for the court to analyse such evidence and they were mandatorily be corroborated with other evidences. But the country still believes it use to be controversial. In 2001 the Apex court of the land established guidelines for the use of these techniques in criminal proceedings if the test is conducted voluntarily with the consent, conducted by a qualified practitioner, a written report has to be submitted, the examiner has to testify alongside cross-examination and lastly corroboration is mandatory.

In 2003 specially the Polygraph law was passed where licensing, training and regulatory body was established. Now-a-days it is accepted in criminal, employment and in civil litigations too but again it is accepted only to the rarest of the rare circumstances and also, they are not considered conclusive proof.

Narco-analysis tests are not legally permitted in Japan. The use of such techniques for criminal investigations is generally prohibited due to ethical and legal concerns regarding individual rights and reliability. Japan primarily relies on other investigative methods that are considered more legally sound and reliable. But in citing these other techniques like polygraph tests are used only in criminal investigations and Japan first introduced it in Japanese Police Agencies in 1956. Since the Japanese Supreme Court submitted a decision regarding the admissibility of polygraph evidence in 1968 such evidence is generally accepted in legal proceedings[21].

In conclusion, the comparative study across various jurisdiction reveals a nuanced landscape shaped by legal, ethical and scientific considerations. While countries like USA and UK have largely rejected the admissibility of such evidence due to concerns of constitutional rights infringement. While countries like Israel, have integrated these techniques under strict guidelines, primarily for national security purposes. Japan on the other end, maintains a strict prohibition on narco-analysis tests, opting for alternative investigative methods. This highlights the diverse approaches employed around the globe in forensic psychology and underscores the importance of balancing investigative tools with legal safeguards along with ethical considerations in pursuit of justice.

CONCLUSION AND SUGGESTIONS

In conclusion, the Aarushi Talwar case and the use of narco-analysis highlights the complex intersection of forensic techniques, legal systems, and ethical considerations that exist in a criminal investigation. Globally, differing legal landscapes reflect nuanced approaches to forensic psychology, emphasizing the need for clear frameworks that balance investigative needs with individual rights and ethical standards.

To enhance the reliability and ethical integrity of narco-analysis, several critical measures must be implemented. Firstly, unbiased third-party experts without compromising with the standards, should be engaged to conduct the tests, ensuring impartiality and credibility throughout the process. Dosage regulation is essential and should be professionally managed, with individual evaluations guiding appropriate dosing to prevent potential harm or coercion. Moreover, questions posed during narco-analysis sessions must be carefully crafted to be non-leading and non-coercive, preserving the integrity of the information obtained. While narco-analysis remains unrecognized globally, certain countries like Israel and Japan have acknowledged the utility of polygraph tests. India should consider similar recognition, ensuring that the procedure is conducted voluntarily and without self-incrimination, with informed consent from participants. It should only be utilized as a last resort in rare cases to gather additional investigative information. However, it is crucial to emphasize that narco-analysis results should never be admissible in court to convict accused individuals, thereby upholding fairness and due process in legal proceedings.

[1] Bhavya Anand & Lalima Das, “Forensic Criminology: A Revolutionary Parameter for Legal Fraternity”, 28 SUPREMO AMICUS [173] (2022).

[2] Jagannath Mondal v. State of W.B., 2018 SCC OnLine SC 3076.

[3] M. Mammutti v. State of Karnataka, (1979) 4 SCC 723.

[4] BR Sharma, Forensic science in crime investigation and trials, 6th edition 2020.

[5] Sharma, B. (2022) Narcoanalysis – a legal propesctive, SSRN. Available at: https://deliverypdf.ssrn.com/delivery.php?ID=605091068094076001123125112082098065040056008022062094030095098087126029007103024007011010029007119043019127001020098113093092056082000035040125087071122097083096119088000049065071087114127027127101066080004110003067029096127079030114002114086095112127  (Accessed: 05 April 2024).

[6] 372 U.S. 293 (1963)

[7] Selvi vs. State of Karnataka, AIR 2010 SUPREME COURT 1974

[8] Santokben SharmaBhai Jadeja v. State of Gujarat, (2008)1GLR497

[9] Rojo George V. Deputy Superintendent of the police, 2006(2) KLT197.

[10] Dinesh Dalmia v. State, 2006CRILJ2401.

[11] Sri Abdul Kareem Telgi vs The State of Karnataka, 2018 (2) AKR 82.

[12] Ramchandra Reddy & Ors. V. State of Maharashtra, (2004 ALL MR (Cri) 1704).

[13] Townsend v. Sain, 372 U.S. 293 (1963).

[14] Frye v. United States, 293 F. 1013.

[15] People v. Jones, 184 Cal. App. 2d 464.

[16] Lindsey v. US, 301 U.S. 397(1937).

[17] State v. Hudson, 11 U.S. 32(1812).

[18] Brown v. State, 356 U.S. 148 (1958).

[19] R v. Turner, [1975] 1 All ER 70.

[20] UN General Assembly, International Covenant on Civil and Political Rights, United Nations, Treaty Series, vol. 999, p. 171, 16 December 1966, https://www.refworld.org/legal/agreements/unga/1966/en/17703  [accessed 04 April 2024].

[21] Yamamura T. and Miyata Y., Development of the Polygraph Technique in Japan for Detection of Deception, 44 J. Forensic Sci. Int. 257, 261 (1990).


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