In some cases the brain mapping techniques are used for commercial purposes, lie detection, or medical diagnosis in ways which have not been scientifically validated. In the late 1980s in the United States, the Institute of Medicine of the National Academy of Science was commissioned to establish a panel to investigate the value of integrating neuroscientific information across a variety of techniques. Of specific interest is using structural and functional magnetic resonance imaging (fMRI), diffusion MRI (dMRI), magnetoencephalography (MEG), electroencephalography (EEG), positron emission tomography (PET), Near-infrared spectroscopy (NIRS) and other non-invasive scanning techniques to map anatomy, physiology, perfusion, function and phenotypes of the human brain. Both healthy and diseased brains may be mapped to study memory, learning, aging, and drug effects in various populations such as people with schizophrenia, autism, and clinical depression. This led to the establishment of the Human Brain Project. It may also be crucial to understanding traumatic brain injuries (as in the case of Phineas Gage) and improving brain injury treatment. Following a series of meetings, the International Consortium for Brain Mapping (ICBM) evolved. The ultimate goal is to develop flexible computational brain atlases. On May 5, 2010 the Supreme Court in India (Smt. Selvi vs. State of Karnataka) declared brain mapping, lie detector tests and narcoanalysis to be unconstitutional, violating Article 20 (3) of Fundamental Rights. These techniques cannot be conducted forcefully on any individual and requires consent for the same. When they are conducted with consent, the material so obtained is regarded as evidence during trial of cases according to Section 27 of the Evidence Act. Brain mapping is the study of the anatomy and function of the brain and spinal cord through the use of imaging (including intra-operative, microscopic, endoscopic and multi-modality imaging), immunohistochemistry, molecular & optogenetics, stem cell and cellular biology, engineering (material, electrical and biomedical), neurophysiology and nanotechnology.