In Aparna Ajinkya Firodia vs. Ajinkya Arun Firodia, decided on July 1, 2025, the Bombay High Court (Nagpur Bench) set aside a Family Court order directing a DNA test to determine a child’s paternity. Justice R.M. Joshi held that a child born during a valid marriage is conclusively presumed legitimate under Section 112 of the Indian Evidence Act, unless the husband proves "non-access" during the period of conception. In this case, the husband alleged adultery but neither explicitly denied paternity nor produced evidence proving non-access. The Court emphasized that "access" means the possibility of sexual relations, not actual cohabitation, and that DNA tests cannot override the presumption without strong justification. The wife’s conditional willingness to comply with a court order was wrongly interpreted as consent. The Court reiterated that a child’s dignity and welfare must be protected, and DNA tests cannot be ordered routinely. Accordingly, the Family Court’s direction for DNA testing was quashed.