Confession Made To A Police Officer Or In Custody - Inadmissible Unless Made In Presence Of A Magistrate
Supreme Court Overturns Conviction in Karnataka Murder Case. Lack of Unbroken Circumstantial Evidence Chain Leads to Acquittal in High-Profile Murder Case
News Report:
In a significant judgment, the Supreme Court of India has acquitted Nagamma @ Nagarathna and her co-accused in a high-profile murder case in Karnataka, underscoring the importance of an unbroken chain of circumstantial evidence in criminal convictions. The case, which revolved around the brutal murder of a policeman over a loan dispute, was initially decided by both the trial court and the High Court, with convictions based largely on circumstantial evidence and extra-judicial confessions.
The Supreme Court bench comprising Justices K.V. Viswanathan and K. Vinod Chandran meticulously analyzed the evidence presented and found substantial gaps in the prosecution's case. The judgment highlighted the absence of a motive, unreliable extra-judicial confessions, and doubts surrounding the presence of the dead body at the accused's premises, all of which weakened the prosecution's narrative.
Key to the Supreme Court's decision was the reliance placed by the lower courts on circumstantial evidence, which, according to the apex court, did not form a complete and unbroken chain leading to the guilt of the accused beyond reasonable doubt. The judgment emphasized that mere failure of the accused to provide an explanation under Section 106 of the Indian Evidence Act, 1872, could not sustain a conviction without a full chain of incriminating circumstances.
Furthermore, the court scrutinized the extra-judicial confessions made by the accused within the confines of a police station, ruling them inadmissible under Sections 25 and 26 of the Indian Evidence Act, 1872. The confessions were deemed inadmissible as they were made to police officers and not in the immediate presence of a magistrate, thus failing the legal standards for such evidence.
The judgment also questioned the recovery of the alleged murder weapon, which was purportedly discovered based on confession statements. The recovery lacked independent corroboration and was further undermined by the hostile nature of key witnesses. The court noted that without forensic evidence linking the weapon to the crime, the recovery could not be deemed an inculpatory circumstance.
In conclusion, the Supreme Court’s judgment underscored the necessity of establishing an unbroken chain of evidence in cases reliant on circumstantial evidence, reaffirming the principle that conviction must be based on proof beyond reasonable doubt. The acquitted individuals will be released from custody unless required in other cases, and any pending applications related to the case have been disposed of.
Bottom Line:
Conviction based on circumstantial evidence requires a complete chain of cogent and reliable material, linking the accused to the crime unequivocally. Absence of motive, credible extra-judicial confessions, and failure to establish presence of the dead body at the accused's premises weakens the prosecution's case.
Statutory provision(s): Indian Penal Code, 1860 Sections 302, 34; Indian Evidence Act, 1872 Sections 25, 26, 27; Section 106 of the Indian Evidence Act, 1872
Nagamma @ Nagarathna v. State of Karnataka, (SC) : Law Finder Doc Id # 2782202
