H eld: The case arises from an interim order of the Patna High Court accepting the investigating officer’s submission to conduct narco-analysis tests on the Appellant and other accused persons during the pendency of a bail application under Section 439 CrPC in a dowry-related disappearance case — The Appellant challenged the order, contending that it violated fundamental rights under Articles 20(3) and 21 of the Constitution — The Supreme Court framed three issues: first, whether the High Court was justified in accepting such a submission at the bail stage; second, whether results of a voluntary narco-analysis test could independently support a conviction; and third, whether an accused has an indefeasible right to undergo such a test — On the first issue, the Court held that the High Court erred by converting a bail hearing into a mini-trial and permitting investigative methods constitutionally impermissible at that stage — On the second, it held that the outcome of a voluntary narco-analysis test, even if conducted with consent and safeguards, cannot form the sole basis of conviction, though derivative evidence obtained under Section 27 of the Indian Evidence Act may be admissible — On the third, it held that while an accused may request to undergo such a test at the appropriate stage (e.g., while leading defence evidence), it is not a matter of right; courts must evaluate voluntariness, safeguards, and necessity before granting such a prayer — The Court reiterated the binding authority of Selvi v. State of Karnataka and the NHRC guidelines governing such tests — Held, the High Court’s acceptance of the submission for narco-analysis was unconstitutional, lacked judicial justification, and stood in violation of settled legal standards — Impugned order set aside; appeal allowed.