Unreadable Post-Mortem Reports Undermine Justice; Rajasthan High Court Mandates Digital Medico-Legal Reports From Feb 2026 While Hearing Bail Plea In Murder Case
Sanchayita Lahkar
The High Court of Rajasthan Single Bench of Justice Ravi Chirania, while deciding a bail request in a murder case involving allegations against a brother, ordered the applicant’s release after noting the absence of direct evidence and the failure of key family witnesses to support the prosecution. During the hearing, the Court faced considerable difficulty in interpreting the handwritten post-mortem report and observed that medico-legal documents were being prepared in an unacceptable and deficient manner. Highlighting the problematic state of such reports, the Court directed the State to ensure that all medico-legal documents are generated through the Medico Legal Examination and Post-Mortem Reporting (MedLEaPR) software, making the digital system mandatory from February 1, 2026, to secure clarity and reliability in future records.
The matter concerns a bail application filed by an accused who was alleged to have killed his brother. The incident was initially reported by the accused himself, who lodged an FIR against unknown persons stating that he had discovered his brother dead. During investigation, the police recovered a firearm and other articles on different dates in August 2024. These materials remained at the police station for nearly a month before being sent to the forensic laboratory, raising questions about handling and preservation of evidence.
The prosecution alleged that the accused committed the offence, relying on the recovery of the weapon said to be made at his instance. The post-mortem report, prepared by doctors at the government hospital, became a central point of concern because it was handwritten and difficult for the Court to decipher. Statements of key family witnesses, including a cousin and the mother of both the accused and the deceased, did not support the prosecution’s allegations and they were declared hostile.
The accused argued that he was falsely implicated, citing lack of motive, cordial relations between the brothers, and inconsistencies in the investigation. The matter involved offences under the relevant provisions of the Bharatiya Nyaya Sanhita as well as the Arms Act, and the Court examined the evidentiary material submitted during investigation.
The Court recorded that the post-mortem report in the present case was “not readable” and that the document appeared to have been prepared “for their own understanding and use,” which posed difficulties for courts, lawyers, and investigating agencies. It was noted that despite the availability of a robust digital system, “Doctors are preparing medical reports in a casual and negligent manner by hand which are illegible and incomprehensible.” After examining the scanned pages of the report, the Court remarked that they demonstrated a “casual and negligent attitude” in preparing essential medico-legal documents.
When the Additional Advocate General was questioned, he informed the Court that although most documents in criminal cases were typed, medico-legal documents such as injury reports, age-determination reports, and post-mortem reports continued to be handwritten. The Court recorded his submission that typed reports would assist all stakeholders. The Court observed that “almost all Courts in the country are facing the problem of not able to understand the medical reports… for the common reason that they are pen down by the doctors in writing which is illegible in almost all cases.”
The Court referred to directions issued by the Punjab & Haryana High Court, noting that the MedLEaPR software had been operational since 2011–12. The Court also recorded that many States already used it, whereas Rajasthan had not implemented it completely “even after 14 years.” Upon being informed that partial implementation had begun in January 2025, the Court noted that only those cases in which the police generated online requests were processed through MedLEaPR, while all remaining medico-legal reports continued to be handwritten. The Court stated that this practice was “highly unacceptable,” observing that it “frustrated” the purpose for which the system had been developed.
The Court further observed that illegible medical documents caused serious hindrance to justice and that medico-legal documentation must be readable and systematically prepared. It recorded written submissions stating that reports should contain clear descriptions of injuries, proper diagrams, and typed copies where necessary. After reviewing submissions, interactions with senior officials, and previous judicial directions from other High Courts, the Court recorded that there was an “urgent need” for Rajasthan to adopt complete digital documentation to ensure clarity, reliability, and timely investigation.
The Court stated that “this Court is inclined to enlarge the petitioner on bail, considering the overall facts and circumstances of the case,” and that “this bail application filed by the petitioner under Section 483 B.N.S.S. is allowed.” The petitioner “shall be released on bail in connection with FIR No.121/2024 registered at P.S. Mathili Rathan, District Sri Ganganagar provided he executes a personal bond in a sum of Rs.1,00,000/- with two sound and solvent sureties of Rs.50,000/- each to the satisfaction of learned trial court for his appearance before that court on each and every date of hearing and whenever called upon to do so till the completion of the trial.”
Following the bail order, the Court issued directions regarding medico-legal reports. The Court directed that the State, through the Principal Secretary Medical Education and the Principal Secretary Medical and Health, “shall jointly/independently issue a detailed notification or circular within 15 days from the date of this order for preparation of all MLR, PMR, age determination test, sex determination test, all other medico legal reports etc. through MedLEaPR software by all doctors of Government and private establishment etc. strictly without any fail w.e.f. 01.02.2026.”
The Additional Chief Secretary, Home, “is directed to issue circular to all police officials, Investigating Agencies and Investigating officers of all cases to generate request for preparation of all MLR, PMR etc., in all cases through CCTNS compulsorily,” adding that “in no case the medical reports shall be prepared by hand after 01.02.2026” and stipulating that “in any case, if MLR, PMR etc. are prepared by hand or without use of MedLEaPR software, after 01.02.2026, then the investigating officer, concerned SHO, the Superintendent of Police of the respect of districts and Commissioners of the respective Jaipur and Jodhpur Commissionerate would be personally responsible.”
“Till the system is completely put in place, all MLR, PMR etc. would be prepared in capital letters with clean and legible handwriting and would be accompanied by a typed copy of the document… and must be in fully comprehensible after 08.12.2025.”
The new formats must be issued with “sufficient space and extra columns” and that these formats “must be available to all PHCs, CHCs, SDHs and district hospitals etc. within 10 days.” All circulars and notifications be widely publicised and that notice be published “in English and Hindi newspaper of the State.”
“All medical reports after 08.12.2025 must be prepared in capital letters up to 31.01.2026 and from 01.02.2026 only through MedLEaPR software “ and “are uploaded with a proper QR Code” and that medical lab reports “must contain specific opinion and conclusion… with physical signature (not digital).”
All samples collected during investigation “must be deposited… in FSL, maximum within five days,” with reasons given if delayed, and that sending/receiving of samples “must be communicated with self generated E-mails and SMS.” It required e-accessibility of reports, tracking features, and protection against unauthorized sharing, with responsibility fixed for breaches. Provision of infrastructure including “Computer… printer, scanner and UPS” and “High speed internet connectivity, 24/7” within 30 days, and directed that “all required doctors/Medical Jurists are registered on MedLEaPR within 20 days.”
The Additional Chief Secretary (Home), the Director General of Police, the Principal Secretary (Medical and Health), and the Principal Secretary (Medical Education) to file a compliance report within 45 days. The report must specify the notifications or circulars issued, the number of doctors and medical jurists registered and trained, the dissemination of information through newspapers, the infrastructure provided, and the updated formats for medico-legal reports. It must also include affidavits from all Chief Medical and Health Officers, heads of government hospitals, and authorised heads of private hospitals and clinics confirming their awareness of the directions and the steps taken to comply with them.
The notification or circular must expressly state that if any medico-legal report prepared after February 1, 2026 is handwritten instead of generated through the MedLEaPR software, disciplinary action will be initiated under the Rajasthan Civil Services (Classification, Control and Appeal) Rules, 1958 and other applicable regulations against the responsible government doctors, officials, and authorised personnel of private establishments. The Court further held that any breach of its directions would amount to contempt, and suo motu proceedings under the Contempt of Courts Act, 1971 would be initiated against those found responsible.
Advocates Representing The Parties
For the Petitioner: Mr. S.R. Godara
For the Respondents: Mr. Deepak Choudhary, Additional Advocate General-cum-Government Advocate; Mr. Urja Ram Kalbi, Public Prosecutor; Mr. Vineet Jain, Senior Advocate assisted by Mr. Pravin Vyas; Mr. Dhirendra Singh Champawat, Senior Advocate assisted by Mr. Jagdish Singh.
Case Title: Mukesh Kumar @ Mangej v. State of Rajasthan
Neutral Citation: 2025: RJ-JD:46368
Case Number: S.B. Criminal Miscellaneous Bail Application No. 173/2025
Bench: Justice Ravi Chirania
