In a custody and visitation dispute where the mother alleged the father had sexually abused their daughter (then about two years old) and later returned to India with the child after an alleged domestic assault, Justices Sanjay Karol and N.
Kotiswar Singh laid down 19 guidelines governing when and how courts may order psychological evaluation of a minor child in custody, visitation and POCSO-adjacent proceedings. The Court held that such evaluation cannot be ordered routinely, must be justified by specific, recorded reasons showing necessity, must follow a principle of minimum intrusion, should ordinarily be conducted by a single independent expert rather than a panel, and must never be used as an adversarial tool to vindicate either parent's claims, given the risk of re-traumatisation from repeated evaluation.