In R. Rajendran vs. Kamar Nisha & Others, the Supreme Court examined whether a DNA test could be directed to determine paternity when such determination had no direct nexus with the alleged criminal offence. The respondent alleged an extramarital relationship with the appellant and sought a DNA test to establish paternity in support of charges of cheating and harassment. The Madras High Court allowed the request, prompting an appeal. Allowing the appeal, the Supreme Court set aside the DNA test order. The Court reiterated the primacy of Section 112 of the Indian Evidence Act, which creates a conclusive presumption of legitimacy of a child born during a valid marriage, rebuttable only by proof of non-access. It held that DNA testing is an exceptional measure and cannot be ordered as a routine or roving inquiry. The Court emphasized that compelling a DNA test seriously intrudes upon the right to privacy under Article 21 and must satisfy strict necessity and proportionality. Since paternity was only a collateral issue with no direct relevance to the criminal charges, the DNA test was held unwarranted.