In case of Vijay Pandey vs. State of UP, the Supreme Court has held mere Production of a laboratory report of a sample tested by Narcotics cannot be conclusive proof in a case of Narcotic Drugs and Psychotropic Substances Act, 1985. SC allowed the petition and acquitted the appellant.
The bench of Justice Ashok Bhushan and Justice Navin Sinha observed:
The failure of the prosecution in the present case to relate the seized sample with that seized from the appellant makes the case no different from failure to produce the seized sample itself. In the circumstances the mere production of a laboratory report that the sample tested was narcotics cannot be conclusive proof by itself.