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As per case facts the appellant who is accused in a missing person case his wife was denied bail by the Sessions Judge after which he approached the High Court
...The High Court while hearing the bail plea accepted the Investigating Officer's submission that narco-analysis tests of all accused persons would be conducted during the investigation which led to the appellant appealing the High Court's acceptance of this submission The question arose whether the High Court's acceptance of the Investigating Officer's submission to conduct involuntary narco-analysis tests on all accused persons was permissible in law given the constitutional right against self-incrimination and whether an accused has an indefeasible right to undergo such a test voluntarily Finally the Supreme Court set aside the High Court's order holding that an involuntary narco-analysis test is impermissible as it violates Articles and of the Constitution The Court clarified that while an accused has a right to voluntarily undergo the test at an appropriate stage during trial to lead evidence there is no indefeasible right to it and its results alone cannot be the sole basis for conviction even with safeguards