Amlesh Kumar vs The State Of Bihar

The Supreme Court examined whether the High Court's order to conduct narco-analysis tests on the accused violated the constitutional right to personal liberty under Article 21. The Court reaffirmed the principle from Selvi v. State of Karnataka that forceful narco-analysis infringes on personal liberty and cannot be conducted without adhering to legal safeguards. The Court set aside the High Court's order, emphasizing the importance of individual rights during investigation procedures. The judgment underscores the need to balance investigative interests with constitutional protections.