Supreme Court Upholds Conviction for Murder Based on Extra-Judicial Confession in Live-in Relationship Case. Court holds that extra-judicial confession, if credible and corroborated, can form the basis of conviction under Section 302 IPC.

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Case Note & Summary

The appellant, Ramu Appa Mahapatar, was convicted under Section 302 IPC for the murder of Manda, with whom he was in a live-in relationship. The prosecution's case rested primarily on extra-judicial confessions made by the appellant to PW-1 (landlord), PW-3 (brother of deceased), PW-4 (wife of PW-3), and PW-6 (acquaintance). The appellant informed PW-1 that his wife had died and went to inform her relatives. At the deceased's brother's house, he confessed to assaulting Manda after a quarrel, leading to her death. PW-1 later discovered the body and lodged an FIR. The trial court convicted the appellant, and the High Court affirmed. The Supreme Court, on appeal, examined the testimonies of the witnesses and found them consistent and credible. The court noted that the extra-judicial confession was made voluntarily and was corroborated by the discovery of the body and the circumstances. The court dismissed the appeal, upholding the conviction and life sentence.

Headnote

A) Criminal Law - Murder - Extra-Judicial Confession - Section 302 Indian Penal Code, 1860 - Credibility of Extra-Judicial Confession - The appellant was convicted for murder of his live-in partner based on extra-judicial confessions made before PW-1, PW-3, PW-4, and PW-6. The court examined the testimonies and found them consistent and credible, rejecting the appellant's contention that the confession was weak and unreliable. Held that the extra-judicial confession, being voluntary and corroborated by the discovery of the body and other circumstances, was sufficient to uphold the conviction (Paras 10-14).

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Issue of Consideration

Whether the extra-judicial confession made by the appellant before multiple witnesses is credible and sufficient to sustain a conviction under Section 302 IPC.

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Final Decision

Appeal dismissed. Conviction and sentence of life imprisonment under Section 302 IPC upheld.

Law Points

  • Extra-judicial confession is a weak piece of evidence but can be relied upon if it inspires confidence and is corroborated by other circumstances
  • Credibility of witnesses in extra-judicial confession cases
  • Circumstantial evidence in murder cases
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Case Details

2025 LawText (SC) (02) 1106

Criminal Appeal No. 608 of 2013

2025-02-10

Ujjal Bhuyan

2025 INSC 147

Ramu Appa Mahapatar

The State of Maharashtra

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Nature of Litigation

Criminal appeal against conviction for murder under Section 302 IPC.

Remedy Sought

Appellant sought to set aside conviction and sentence of life imprisonment.

Filing Reason

Appellant was convicted for murder of his live-in partner based on extra-judicial confession.

Previous Decisions

Trial court convicted appellant under Section 302 IPC; High Court affirmed conviction and sentence.

Issues

Whether the extra-judicial confession made by the appellant is credible and sufficient to sustain conviction under Section 302 IPC.

Submissions/Arguments

Appellant argued that extra-judicial confession is weak evidence and the witnesses were not credible. Respondent argued that the confession was voluntary and corroborated by circumstances.

Ratio Decidendi

Extra-judicial confession, though a weak piece of evidence, can form the basis of conviction if it is voluntary, credible, and corroborated by other circumstances. The testimonies of witnesses in this case were consistent and reliable, and the confession was corroborated by the discovery of the body and other evidence.

Judgment Excerpts

Extra-judicial confession itself is a weak piece of circumstantial evidence. From the testimony of the above witnesses, it is clearly evident that no credence could be given to the theory of extra-judicial confession.

Procedural History

Trial court convicted appellant on 15.10.2004. High Court dismissed appeal on 02.12.2010. Supreme Court granted special leave on 15.04.2013 and heard the appeal.

Acts & Sections

  • Indian Penal Code, 1860: 302
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