In Smt. Bhauri Devi v. The Rajasthan High Court, Mahendra Kumar and Ors. were involved in a rare case involving an elderly woman of 93 who refused to admit that a woman who had declared herself heir in the ancestral property was her daughter. The petitioner wanted a DNA test to be carried out in accordance with the Order 26 Rule 10-A CPC to establish that she was the biological daughter of the deceased property owner. The trial court denied the request on the grounds of privacy. Justice Bipin Gupta observed that the Indian Evidence Act,1872 (and the Bharatiya Sakshya Adhiniyam, 2023) provided a presumption in favor of paternity but did not provide any presumption in favor of maternity and thus, this was a rare case. The Court also indicated that DNA testing is a good scientific evidence in determining parentage and required in establishing the right to inheritance. To safeguard privacy and truth-finding, the Court decided that one cannot be forcibly tested, but can renounce the test and this may cause an unfavorable presumption. The High Court overturned the order of the trial court and ordered the DNA test.