In Brief
The appellant was convicted under the NDPS Act after police recovered opium from him. The central issue was whether the informant-police officer could also investigate his own case. The Supreme Court held that a fair investigation is a constitutional right under Article 21. The investigator and informant must be different persons to avoid bias and ensure justice appears fair. The prosecution must establish a prima facie case beyond reasonable doubt before the statutory reverse burden of proof shifts to the accused. Procedural safeguards—deposit of seized material in the station, timely sample dispatch, witness examination—must be substantially complied with. Finding multiple procedural violations and conflicts of interest, the Court allowed the appeal and acquitted the appellant.
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