Supreme Court rules that a confession in an FIR lodged by the accused is inadmissible under the Evidence Act, setting aside the conviction in a sensational murder case.
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NEW DELHI: The Supreme Court of India has held that a First Information Report (FIR) lodged by an accused person, if it contains a confession, cannot be used as evidence against him during trial. The Court clarified that such FIRs are hit by Section 25 of the Indian Evidence Act, 1872, which bars confessions made to police officers from being proved against the accused.
This decision came in the case of Narayan Yadav vs State of Chhattisgarh, where a two-judge bench comprising Justice J.B. Pardiwala and Justice R. Mahadevan set aside the conviction of the appellant, who had been initially sentenced for murder under Section 302 of the Indian Penal Code (IPC).
Background of the Case
The appellant, Narayan Yadav, had lodged an FIR himself in September 2019, narrating the sequence of events that allegedly led to the killing of his employer, Ram Babu Sharma, during a drunken altercation. In the FIR, Yadav admitted to attacking the deceased with a knife and a wooden log after a quarrel. He also mentioned stealing money and a vehicle from the crime scene.
The trial court convicted Yadav under Section 302 IPC (murder) and sentenced him to life imprisonment. On appeal, the Chhattisgarh High Court modified the conviction to Section 304 Part I IPC (culpable homicide not amounting to murder), citing sudden provocation under Exception 4 of Section 300 IPC.
However, the Supreme Court found the High Court’s reasoning flawed.
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Supreme Court’s Finding
The Court emphasized that a confessional FIR made by an accused person is inadmissible in evidence against him, except for very limited purposes. Citing precedents such as Aghnoo Nagesia vs State of Bihar (1966) and Faddi vs State of Madhya Pradesh (1964), the Court held:
- The contents of such an FIR cannot be used to corroborate or contradict the accused unless he appears as a witness.
- Only the fact of lodging the FIR can be considered under Section 8 of the Evidence Act as conduct.
- Any information that leads to the discovery of a fact may be admissible under Section 27, but only to that limited extent.
“An FIR of a confessional nature made by an accused person is inadmissible in evidence against him, except to the extent that it shows he made a statement soon after the offence, thereby identifying him as the maker of the report, which is admissible as evidence of his conduct under Section 8 of the Act of 1872.”
The Court criticized the High Court for corroborating medical evidence with the confessional FIR, observing that medical expert testimony is advisory in nature and cannot be the sole basis for conviction. The judgment noted:
“An accused cannot be held guilty of the offence of murder solely on the basis of medical evidence on record.”
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In this case, most panch witnesses turned hostile, and the investigating officer failed to prove the panchnamas properly. There was no legally admissible discovery under Section 27, leaving the prosecution’s case without substantive evidence.
The Supreme Court also faulted the High Court for applying Exception 4 (sudden fight) to Section 300 IPC without fulfilling all its ingredients. The Court clarified that:
- For Exception 4 to apply, the fight must be mutual, without premeditation, and without the offender taking undue advantage or acting in a cruel or unusual manner.
- Here, the deceased was unarmed, and the attack was indiscriminate, making Exception 4 inapplicable.
However, this analysis became academic as the Court ultimately acquitted the appellant for lack of evidence.
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The Supreme Court allowed the appeal, set aside the conviction, and acquitted Narayan Yadav of all charges, directing his immediate release if not required in any other case.
Appearance:
Appellant-accused: Advocate Manjeet Chawla
State: Advocate Sugandha Jain
Case Title:
Narayan Yadav vs State of Chhattisgarh
CRIMINAL APPEAL NO. 3343 OF 2025, SLP (Crl.) No. 10595 of 2025
READ JUDGMENT HERE
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