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Karnataka HC Quashes DNA Test Order, Reaffirms Strict Limits on Paternity Testing

The bench directed stricter adherence to Section 112 so courts order DNA tests only upon pleaded and proven non-access.

Overview

  • The High Court set aside a Channarayapatna civil court’s April 2025 direction permitting a DNA test in a partition dispute.
  • Justice M. Nagaprasanna underscored the Section 112 presumption of legitimacy for children born in wedlock and the need to first plead and prove non-access.
  • The ruling cautioned that forcing genetic testing without imminent need can violate Article 21 rights to privacy and dignity and threaten marital sanctity.
  • The court faulted the trial judge for treating the request “as a frolicsome act,” noting no material showed non-access even as the child was born of a subsisting marriage.
  • The judgment ordered circulation of its observations to subordinate courts to prevent DNA tests being directed as a routine or “for the asking” measure.