When the police recover charas, a pistol, empties or a blood-stained cloth, they send a sample to a laboratory, and the laboratory's short report is often treated as the end of the matter. The Supreme Court and the Peshawar High Court read it more carefully. The report speaks only about the article that reached the laboratory, so the prosecution must prove, link by link, that it is the same article that was seized.
This research paper studies 102 reported judgments from 1994 to 2026: 46 on narcotics reports and the chain of custody, 38 on firearm, empties, blood and serology reports, and 18 on audio and video recordings, CCTV, voice, mobile phones, DNA, fingerprints, handwriting and section 510 Cr.P.C.
The law has moved in four phases: from treating expert reports as mere corroboration, to the Supreme Court's chain-of-custody decisions in narcotics cases from 2018, to its decisions on crime empties sent to the laboratory only after the accused was arrested (from 2022), and finally to the 2025–2026 decisions that insist on the register, the carrier and the Moharrir.
For the defence: put every date on one line, from recovery and sealing to dispatch, receipt and report; insist that the Moharrir, the carrier and the seizing officer are produced; ask whether the empties went to the laboratory before the weapon was recovered; and test any recording against PLD 2019 SC 675.
The paper also sets out the cases that go the other way, where a delay or a gap was held not to be fatal, and explains one hundred terms used in the judgments. The full paper is free to download:
https://arbitratorandlaw.com/resources/research/6/file
For more research papers like this one, visit the Resources page:
https://arbitratorandlaw.com/resources
Adv. Syed Zeshan Hashmi, Advocate High Court
The Arbitrator & Law Associates, Opposite Prime Hospital, Ring Road, Peshawar | 0313-4859592
Blog
The Forensic Science Laboratory Report in Pakistani Criminal Trials: Chain of Custody, Firearm, Blood and Digital Evidence
13 Oct 2026
An FSL report looks scientific, but the courts read it only as a report on what reached the laboratory. 102 judgments show how the chain of custody decides the case.