Annual Report 1999-2000 it may consider necessary for the promotion of human rights' [see Section 12(j)]. The National Human Rights Commission is therefore required to lay down guidelines from time to time, for the effective implementation by tire State authorities or other public functionaries of the constitutional guarantees and international human rights norms, as interpreted and applied under the judgments of the Supreme Court of India. These further the objectives of protection and promotion of human rights of ordinary men and women in this country. The guidelines for conducting the Polygraph Test, which requires prior injection of a drug, are meant only to protect and prevent violation of the human rights of the person to be examined; his rights to this effect being guaranteed under Article 21 and Article 20(3) of the Constitution. The guidelines merely spell out in detail the protection available under these constitutional provisions and have been formulated in the discharge of the functions entrusted upon the Commission by Clause (j) of Section 12 of the Act. The effect of conducting the Polygraph Test without the voluntary consent of the person is a serious violation of his human rights guaranteed under the Constitution. Moreover, these guidelines are in the form ofrecommendations, and non-compliance with the same would result in the evidence recorded becoming inadmissible in a Court of Law, and also violative of the provisions of the Constitution and the Statutes governing the field. Thus guidelines help to establish the 'best practices' for law enforcing agencies to follow and have usually been accepted and acted upon by the concerned authorities. In fact, the guidelines also help the concerned authority to ensure that is does not act in a manner that is unconstitutional or illegal and violative of human rights. Human rights violations: ]ail custody Death of Bihari Babu due to negligence of the doctor: Madhya Pradesh (Case No. 6096/96-97/NHRC) The Commission received a complaint from Shri ^ay Jain of Bhopal, Madhya Pradesh, referring to a news item in the MP Chronicle, alleging that one Bihari Babu had died in the Morena Jail premises under mysterious circumstances. The death was attributed to the negligence of the doctor in-charge of the Jail. The reports received from the Deputy Secretary, Government of Madhya Pradesh, indicated that Dr. R.S. Sharma was found guilty of dereliction of duty and a strong warning was given to him. The Commission considered the matter and held that a punishment limited to a warning to the doctor for dereliction of duty was grossly inadequate and recommended to the Chief Secretary, Madhya Pradesh, that disciplinary action be taken against the doctor and compensation in the amount of Rs. 2 lakhs be paid to the next of kin of the deceased. 118