The Supreme Court of India recently revisited the admissibility and reliability of extra-judicial confessions in criminal cases. The ruling addressed the legal standing of a Village Police Patil as a non-police officer, emphasizing the stringent care required when evaluating such confessions. This decision came during the case of Sadashiv Dhondiram Patil v. The State of Maharashtra (Criminal Appeal No.1718 of 2017), where a judgment by the Bombay High Court was overturned. The Bench comprised Justices J.B. Pardiwala and R. Mahadevan.
What is an Extra-Judicial Confession?
An extra-judicial confession is a statement made outside the formal court or investigative environment, often considered a "weak form of evidence." The Supreme Court reiterated that such confessions require careful scrutiny, especially when surrounded by dubious circumstances. Their admissibility depends on the absence of coercion, inducement, or manipulation and must be made voluntarily by the accused.
Case Background
In this case, the prosecution alleged that the appellant (husband) murdered his wife due to a troubled marital life. The deceased's body was recovered from the couple’s home after she went missing. The trial court acquitted the accused, citing insufficient evidence. However, the High Court reversed this decision based on an extra-judicial confession made to a Village Police Patil.
Key Findings by the Supreme Court
- Village Police Patil Not a Police Officer: The Court clarified that a Village Police Patil does not hold the authority of a police officer. Therefore, confessions made to them can qualify as extra-judicial confessions and are admissible in court.
“Even if admissible, the evidence must be credible, trustworthy, and free of coercion or inducement,” the Court observed.
- Weakness of Extra- ConfessionsJudicial: Upon analyzing the accused's confession, the Court found it vague and ambiguous, lacking the credibility needed for conviction.
“Suspicious circumstances surrounding such confessions diminish their importance,” the judgment noted.
- Burden of Proof: Section 106 of the Evidence Act: The Court emphasized that the prosecution bears the primary burden of proof. Section 106 of the Indian Evidence Act applies only when foundational facts are established. It does not allow the prosecution to shift the entire burden of proving innocence onto the accused.
“If the husband is accused of killing his wife within their home during the night, he must provide some explanation. However, this principle is contingent on the prosecution first proving foundational facts.”
- Role of Investigating Officers and Witnesses: The Court criticized the lack of credible evidence presented by the Investigating Officer (IO) and the reliance on a panchnama that was not adequately corroborated by witnesses.
- Motive Alone Insufficient: While the prosecution highlighted marital discord as a motive, the Court clarified that motive cannot solely establish guilt in serious offenses like murder. Motive must be corroborated with reliable evidence.
Final Judgment
The Supreme Court concluded that the High Court erred in relying solely on the extra-judicial confession and failed to substantiate the other claims of the prosecution. It quashed the High Court’s judgment and restored the trial court’s decision to acquit the accused.
“Motive may assist in forming a chain of incriminating circumstances but cannot independently determine guilt,” the Court stated.
Conclusion
This landmark ruling underlines the nuanced approach courts must adopt when handling extra-judicial confessions. The case reaffirms that while such evidence is admissible, it must be approached with caution, ensuring it is free of doubt and supported by other corroborative elements.
