In a significant ruling, the Kerala High Court overturned the conviction of Shyjal C., citing inadmissibility of police confession under the Indian Evidence Act.
In a pivotal judgment delivered on January 14, 2026, the Kerala High Court, presided by Justice M.B. Snehalatha, acquitted Shyjal C., the co-accused in a motorcycle theft case, reversing the prior conviction and sentence handed down by the Judicial First Class Magistrate Court, Mannarkkad, and upheld by the Sessions Court, Palakkad. The court highlighted the inadmissibility of confessions made to police officers under Section 25 of the Indian Evidence Act, 1872, as a central reason for the acquittal.
The case involved the alleged theft of a motorcycle, registration number KL-50-5087, from the residential premises of the complainant, PW1 Babu, during the night of September 2-3, 2016. The prosecution's case rested heavily on the confession of the primary accused, A1, obtained by police and implicating Shyjal C. as a co-conspirator. However, the High Court found that this confession was inadmissible, as it was made to a police officer and lacked any supporting evidence.
The original trial court had found both accused guilty under Sections 379 and 34 of the Indian Penal Code (IPC), sentencing them to three years of rigorous imprisonment and a fine of Rs. 5,000 each. The Sessions Court had upheld this conviction upon appeal by Shyjal C. Despite the prosecution's assertion that A1's confession implicated A2, the High Court underscored the absolute bar on such confessions under Section 25 of the Indian Evidence Act and clarified that Section 30, which allows for consideration of confessions against co-accused, cannot override this bar.
Justice Snehalatha meticulously analyzed the statutory provisions related to confessions, emphasizing the necessity for confessions to be both legally admissible and relevant. The judgment reiterated established legal principles, noting that confessions made to police officers cannot be considered evidence and must be corroborated by other admissible evidence, which was absent in this case.
The High Court's decision underscores the importance of adhering to evidentiary standards and statutory provisions in criminal proceedings, ensuring that convictions are based on admissible and substantial evidence. The acquittal of Shyjal C. serves as a reminder of the protections afforded to accused individuals under the Indian legal system, particularly concerning confessions made under police custody.
The judgment has broader implications for criminal jurisprudence, reaffirming the safeguards against potential misuse of police-induced confessions and ensuring that judicial determinations are grounded in legally sound evidence.
Bottom Line:
Confession made to a police officer is inadmissible in evidence under Section 25 of the Indian Evidence Act, 1872. Section 30 of the Evidence Act does not override the bar under Section 25 and cannot be invoked in respect of such confession.
Statutory provision(s): Indian Penal Code Sections 379, 34; Indian Evidence Act Sections 24, 25, 26, 27, 30; Code of Criminal Procedure Sections 41(1)(d), 102
Shyjal C. v. State of Kerala, (Kerala) : Law Finder Doc id # 2845335
