In criminal trials, the line between scientific assistance and constitutional violation is often thin and perilous. As investigative tools become more sophisticated, courts repeatedly confront a difficult and enduring question, How far may the state go in its pursuit of truth without compromising fundamental rights? The Lahore High Court’s judgment in Muhammad Imran, alias Gochhi, v. the State offers a timely and principled response, reaffirming that no advancement in forensic science can override the presumption of innocence or constitutional guarantees. The case involved a murder conviction based solely on circumstantial evidence. The prosecution attempted to establish an "unbroken chain" of guilt through last-seen evidence, CCTV footage, alleged recoveries, call data records (CDRs), and a polygraph examination. However, this chain unraveled at multiple points, most decisively through medical evidence. The prosecution claimed that the victim was killed on December 22, 2019. However, the post-mortem report indicated that death occurred nearly a month later. This inconsistency fatally undermined the prosecution’s timeline and its reliance on the last-seen theory. The court correctly described last-seen evidence as weak and requiring strong, independent corroboration. The court also rejected the call data records due to inadequate authentication and the absence of proper forensic verification. This aspect of the judgment reinforces the critical principle that, given their susceptibility to manipulation, digital evidence must strictly comply with established legal and forensic standards before it can be relied upon in a criminal trial. Most significantly, the judgment undertook a rigorous constitutional examination of polygraph tests and firmly circumscribed their legal value. The Court held that polygraph examinations conducted without free and informed consent violate Article 13(b) of the Constitution, which safeguards the right against self-incrimination. Even where consent is ostensibly given, the Court clarified that polygraph results do not constitute admissible substantive evidence, as the examinee lacks conscious control over physiological responses. At best, such tests may serve as investigative tools, but they cannot be treated as proof of guilt. The Court also condemned serious procedural irregularities in the present case, most notably the recording of a confessional statement on oath by a forensic expert,an act wholly beyond his legal authority. This procedural lapse alone rendered the polygraph exercise legally meaningless. By issuing detailed guidelines for the conduct of future polygraph examinations, the Court sought to strike a careful balance between investigative necessity and constitutional protection, ensuring that forensic science does not become a vehicle for coercion or abuse. Ultimately, the acquittal rested on a foundational principle of criminal justice: where the chain of circumstantial evidence is broken, the benefit of doubt must go to the accused. While the factual matrix of the case is specific, the legal questions it raises regarding the use of polygraph examinations are systemic. They reflect a broader uncertainty within Pakistan’s criminal justice system about the constitutional limits of emerging investigative techniques. Born out of early twentieth-century anxieties surrounding crime detection and truth-seeking, the polygraph was never conceived as a tool of adjudication. Rather, it emerged as an experimental attempt to interpret the human body as evidence. Polygraph examinations, if used at all, must be confined to investigative assistance and restrained by clear constitutional and statutory limits. The strength of a polygraph lies in its ability to record physiological responses under questioning, potentially highlighting inconsistencies. Yet these responses are equally influenced by anxiety, fear, and external stressors, making the technique inherently unreliable. A truthful individual may exhibit indicators associated with deception, while a deceptive individual may not. This judgment is therefore a timely reminder that criminal trials are not experiments in probability, but exercises in constitutional discipline. In an era increasingly shaped by forensic and digital technologies, the Lahore High Court has reaffirmed a vital principle: technology must serve justice, not overshadow it. A coherent reform framework now requires express statutory regulation governing polygraph examinations, clearly demarcating their investigative purpose and legal limits, and ensuring that the body is never compelled to testify against itself in violation of the Constitution. Forensic techniques, when detached from statutory regulation and judicial oversight, risk distorting the evidentiary process and shifting the burden of proof in impermissible ways. This ruling corrects that trajectory by reaffirming that legality, not innovation, determines evidentiary worth. As investigative methods continue to evolve, this ruling offers a principled framework for their constitutional containment. It affirms that the pursuit of truth cannot be divorced from the manner of its pursuit. In preserving this balance, the Court has not hindered criminal investigation, it has fortified the rule of law, ensuring that justice remains an expression of rights, not results.

