Constitution of India, 1950 – Indian Evidence Act, 1872 – Code of Criminal Procedure, 1973 – Indian Penal Code, 1860

Extra-Judicial Confession – Evidentiary Value – The Supreme Court reiterated that an extra-judicial confession is a weak piece of evidence and cannot be relied upon solely for conviction unless it inspires confidence and is corroborated by other prosecution evidence – If an accused was in a confused state of mind at the time of confession, such a confession lacks credibility – Omission of key statements in the witness testimony recorded under Section 161 CrPC affects the reliability of the evidence (Para 17-22).

Circumstantial Evidence – Chain of Events – In a case resting on circumstantial evidence, the prosecution must establish a complete chain of circumstances leading to the guilt of the accused beyond reasonable doubt – No bloodstains found on the accused's clothes, absence of a recovered weapon linking the accused, and lack of corroborating evidence weakened the prosecution case (Para 16, 20-23).

Contradictions in Witness Testimonies – Prosecution witnesses gave inconsistent statements, with material omissions in their Section 161 CrPC depositions – The Supreme Court held that such contradictions strike at the root of the prosecution case and render the conviction unsustainable (Para 21-23).

Benefit of Doubt to the Accused – The Court observed that although suspicion pointed towards the accused, it could not replace substantive legal proof – Conviction and sentence under Section 302 IPC were set aside – Appellant ordered to be released forthwith unless required in another case (Para 24-26).

Acts and Sections Discussed:

• Indian Penal Code, 1860 – Section 302 (Punishment for Murder)
• Indian Evidence Act, 1872 – Section 24 (Confession caused by inducement, threat, or promise)
• Code of Criminal Procedure, 1973 – Section 161 (Examination of witnesses by police)

Subjects:

Extra-Judicial Confession – Circumstantial Evidence – Contradictions in Testimony – Benefit of Doubt – Section 302 IPC – Material Omissions – Weak Evidence

Facts:

1. Nature of the Litigation:
The appellant was convicted under Section 302 IPC for the murder of Manda, with whom he was in a live-in relationship. The prosecution relied on extra-judicial confessions made by the accused to various witnesses.

2. Who is Asking the Court and for What Remedy?
The appellant challenged the Bombay High Court’s decision affirming his conviction and sought acquittal based on weak and contradictory evidence.

3. Reason for Filing the Case:
The appeal was filed against the reliance placed on extra-judicial confession without corroboration and inconsistencies in prosecution evidence.

4. What Has Been Already Decided Until Now?

• The Trial Court convicted the appellant under Section 302 IPC and sentenced him to life imprisonment.
• The Bombay High Court dismissed the appellant’s appeal, upholding the conviction.
• The Supreme Court granted special leave and subsequently allowed the appeal, setting aside the conviction.

Issues:

• Whether the extra-judicial confession was voluntary, credible, and sufficient for conviction?
• Whether the prosecution had established a complete chain of circumstantial evidence linking the accused to the crime?
• Whether contradictions and omissions in witness testimonies rendered the prosecution case unreliable?

Submissions/Arguments:

Appellant:

• Extra-judicial confession was a weak piece of evidence and not corroborated.
• Contradictions in witness statements and material omissions affected the prosecution case.
• No forensic evidence directly linked the accused to the crime.

Respondent (State):

• The confessions made before witnesses were voluntary and credible.
• The Trial Court and High Court correctly appreciated the evidence.
• Circumstantial evidence pointed to the accused’s guilt.

Decision:

The Supreme Court found the extra-judicial confession unreliable due to contradictions and the accused's confused state of mind. The lack of corroborative evidence, material omissions, and inconsistencies in witness statements led the Court to acquit the accused, granting him the benefit of the doubt.

Ratio:

An extra-judicial confession, being a weak piece of evidence, must be corroborated by independent and reliable evidence. Suspicion, however strong, cannot replace legal proof.