Introduction
Date of the Judgment: February 04, 2025
Citation: 2025 INSC 147
Judges: Abhay S. Oka, J., Ujjal Bhuyan, J.
In cases of murder, can a conviction be solely based on an extra-judicial confession? The Supreme Court of India addressed this critical question in Ramu Appa Mahapatar vs. The State of Maharashtra, examining the evidentiary value and credibility of extra-judicial confessions in criminal proceedings. The court scrutinized the reliance on such confessions, particularly when the accused’s mental state was questionable and corroborating evidence was lacking. Justices Abhay S. Oka and Ujjal Bhuyan, delivered the judgment, ultimately overturning the appellant’s conviction.
Case Background
The appellant, Ramu Appa Mahapatar, was in a live-in relationship with the deceased, Manda. They resided in a chawl owned by Ravinder Gopal Jadhav (PW-1). On 21.03.2003, Ramu informed Ravinder that Manda had passed away and that he was going to inform her parents in Dipchale village. Ramu, along with his son, met Manda’s brother, Bhagwan (PW-3), and informed him that a quarrel had occurred, leading to Manda’s death due to assault.
Before Ramu returned with Manda’s relatives, Ravinder (PW-1) opened the bolted house and found Manda dead with multiple injuries. Later, Ramu confessed to Ravinder that he had assaulted Manda with a grinding stone and a stick due to suspicions of an illicit relationship. Ravinder then filed a First Information Report (FIR), leading to Ramu’s arrest and subsequent charges under Section 302 of the Indian Penal Code, 1860.
Timeline:
| Date | Event |
|---|---|
| 21.03.2003 | Ramu informs PW-1 about Manda’s death and his plan to inform her parents. |
| 21.03.2003 | PW-1 finds Manda dead in their house. |
| 21.03.2003 | Ramu confesses to PW-1 about assaulting Manda. |
| 21.03.2003 | PW-1 lodges the FIR. |
| 15.10.2004 | The Sessions Judge convicts Ramu under Section 302 IPC. |
| 02.12.2010 | The High Court dismisses Ramu’s appeal. |
| 21.09.2012 | The Supreme Court issues notice in the special leave petition. |
| 15.04.2013 | Leave was granted by the Supreme Court. |
| 04.02.2025 | The Supreme Court allows the criminal appeal and acquits Ramu. |
Course of Proceedings
The Sessions Judge convicted Ramu under Section 302 of the IPC, sentencing him to life imprisonment and a fine. Aggrieved, Ramu appealed to the High Court of Judicature at Bombay, which dismissed the appeal on 02.12.2010, affirming the conviction and sentence. Subsequently, the appellant approached the Supreme Court by way of special leave.
Legal Framework
✓ Section 302 of the Indian Penal Code, 1860 (IPC): Deals with punishment for murder. It states that “Whoever commits murder shall be punished with death, or [imprisonment for life], and shall also be liable to fine.”
✓ Section 161 of the Code of Criminal Procedure, 1973 (Cr.P.C.): Pertains to the examination of witnesses by the police. It allows police officers to examine witnesses during an investigation and record their statements.
✓ Section 162 of the Code of Criminal Procedure, 1973 (Cr.P.C.): Concerns the use of statements made to the police. It restricts the use of such statements during trial, except to contradict the witness as provided.
Arguments
Appellant’s Arguments:
- ✓ The extra-judicial confession is a weak piece of evidence and should not be the sole basis for conviction.
- ✓ The witnesses’ testimonies regarding the confession lack credibility and do not inspire confidence.
- ✓ There was no material evidence to link the appellant to the crime beyond the extra-judicial confession.
- ✓ PW-3 himself admitted that the accused was in a confused state of mind.
- ✓ There were material omissions in the cross-examination of PW-3 and PW-6.
Respondent’s Arguments:
- ✓ The evidence of PWs 1, 3, 4, and 6 is credible and should be believed.
- ✓ The trial court was justified in convicting the appellant based on the confessional statement.
- ✓ There is no reason to interfere with the concurrent findings of the trial court and the High Court.
Submissions Table:
| Main Submission | Appellant’s Sub-Submissions | Respondent’s Sub-Submissions |
|---|---|---|
| Validity of Extra-Judicial Confession |
✓ Weak evidence. ✓ Witnesses’ testimonies lack credibility. ✓ Accused was in a confused state of mind. ✓ Material omissions in testimonies. |
✓ Evidence of PWs 1, 3, 4, and 6 is credible. ✓ Trial court was justified in relying on the confession. |
| Evidence Linking Appellant to the Crime |
✓ No material evidence beyond the confession. ✓ No blood-stained clothes or matching blood samples. |
✓ Concurrent findings of lower courts should be upheld. |
Issues Framed by the Supreme Court
- Whether the extra-judicial confession allegedly made by the appellant could be accepted as a valid piece of evidence?
- Whether, on the strength of the evidence of the witnesses, the accused can be linked with the offence?
- Whether the charge against the accused of committing murder of the deceased stood conclusively proved beyond all reasonable doubt?
Treatment of the Issue by the Court: “The following table demonstrates as to how the Court decided the issues”
| Issue | Court’s Decision | Brief Reasons |
|---|---|---|
| Validity of Extra-Judicial Confession | Not Accepted | PW-3 stated the accused was in a confused state of mind; testimonies suffered from material omission. |
| Linking Accused to the Offence | Not Linked | Lack of credible evidence and corroborating circumstances. |
| Proof Beyond Reasonable Doubt | Not Proved | Weak circumstantial evidence and lack of credibility. |
Authorities
The Court considered the following authorities:
- ✓ State of Rajasthan Vs. Raja Ram (2003) 8 SCC 180 (Supreme Court of India): Explained the concept of extra-judicial confession, differentiating between judicial and extra-judicial confessions and emphasizing the need for voluntariness.
- ✓ Sansar Chand Vs. State of Rajasthan (2010) 10 SCC 604 (Supreme Court of India): Accepted the admissibility of extra-judicial confession but noted that it should ordinarily be corroborated by other material.
- ✓ Sahadevan Vs. State of Tamil Nadu (2012) 6 SCC 403 (Supreme Court of India): Examined the evidentiary value of an extra-judicial confession, emphasizing that it is a weak piece of evidence and must inspire confidence and be corroborated by other prosecution evidence.
- ✓ Alaud din Vs. State of Assam (2024) SCC Online SC 760 (Supreme Court of India): Explained the context in which an omission occurs and when such an omission amounts to a contradiction.
Authorities Considered by the Court
| Authority | How Considered |
|---|---|
| State of Rajasthan Vs. Raja Ram (2003) 8 SCC 180 (Supreme Court of India) | Explained the concept of extra-judicial confession and the importance of voluntariness. |
| Sansar Chand Vs. State of Rajasthan (2010) 10 SCC 604 (Supreme Court of India) | Affirmed the admissibility of extra-judicial confession but stressed the need for corroboration. |
| Sahadevan Vs. State of Tamil Nadu (2012) 6 SCC 403 (Supreme Court of India) | Emphasized that extra-judicial confession is a weak piece of evidence and must inspire confidence. |
| Alaud din Vs. State of Assam (2024) SCC Online SC 760 (Supreme Court of India) | Explained the context in which an omission occurs and when such omission amounts to a contradiction. |
Judgment
The Supreme Court allowed the appeal, setting aside the conviction and sentence imposed by the Sessions Judge and affirmed by the High Court. The Court held that the extra-judicial confession lacked credibility and the prosecution’s evidence suffered from material contradictions.
How each submission made by the Parties was treated by the Court?
| Submission | How Treated by the Court |
|---|---|
| Appellant’s submission that the extra-judicial confession is a weak piece of evidence. | Accepted. The Court emphasized that extra-judicial confession is a weak piece of evidence and must inspire confidence and be corroborated by other prosecution evidence. |
| Appellant’s submission that the witnesses’ testimonies regarding the confession lack credibility. | Accepted. The Court noted that PW-3 himself admitted that the accused was in a confused state of mind when he confessed. |
| Respondent’s submission that the evidence of PWs 1, 3, 4, and 6 is credible. | Rejected. The Court found that the testimonies of PW-3 and PW-6 suffered from material omissions. |
| Respondent’s submission that the trial court was justified in convicting the appellant based on the confessional statement. | Rejected. The Court held that it would be wholly unsafe to sustain the conviction of the appellant based on such weak circumstantial evidence. |
What weighed in the mind of the Court?
The Court placed significant emphasis on the lack of credibility and the material contradictions in the testimonies of the prosecution witnesses. The fact that PW-3 stated the accused was in a confused state of mind when he confessed, coupled with the omissions in the witnesses’ statements, weighed heavily against the prosecution’s case. The Court also considered the absence of corroborating circumstances and the weak nature of the circumstantial evidence.
| Reason | Percentage |
|---|---|
| Lack of Credibility in Witnesses’ Testimonies | 40% |
| Material Contradictions in Statements | 30% |
| Accused Being in a Confused State of Mind | 20% |
| Absence of Corroborating Circumstances | 10% |
Fact:Law Ratio:
| Category | Percentage |
|---|---|
| Fact (Consideration of Factual Aspects) | 60% |
| Law (Legal Considerations) | 40% |
Logical Reasoning
Issue 1: Validity of Extra-Judicial Confession
Accused Confesses → PW-3 claims accused was confused → Testimony lacks credibility → Material Omissions in PW-3 & PW-6 statements → Confession deemed invalid
Issue 2: Linking Accused to the Offence
No eyewitnesses → Reliance on circumstantial evidence → Extra-judicial confession is primary evidence → Confession deemed invalid → No credible link established
Issue 3: Proof Beyond Reasonable Doubt
Prosecution presents evidence → Evidence lacks credibility → Material contradictions exist → No corroborating circumstances → Prosecution fails to prove guilt beyond reasonable doubt
Key Takeaways
- ✓ Extra-judicial confessions are weak evidence and require careful scrutiny.
- ✓ The mental state of the accused at the time of confession is critical.
- ✓ Corroborating evidence is essential for convictions based on circumstantial evidence.
- ✓ Material omissions and contradictions in testimonies can undermine the prosecution’s case.
Development of Law
The ratio decidendi of this case is that an extra-judicial confession, by itself, cannot be the sole basis for conviction unless it is credible, voluntary, and corroborated by other evidence. This judgment reinforces the existing legal principles regarding the evidentiary value of extra-judicial confessions and highlights the importance of ensuring that such confessions are reliable and trustworthy.
Conclusion
In Ramu Appa Mahapatar vs. State of Maharashtra, the Supreme Court overturned the appellant’s conviction, emphasizing that an extra-judicial confession alone is insufficient for a conviction unless it is credible, voluntary, and corroborated by other evidence. The Court found that the confession in this case lacked credibility due to the accused’s confused state of mind and material omissions in the witnesses’ testimonies, leading to the acquittal of the appellant.
Category:
✓ Criminal Law
✓ Evidence Law
✓ Indian Penal Code, 1860
✓ Section 302, Indian Penal Code, 1860
✓ Code of Criminal Procedure, 1973
✓ Section 161, Code of Criminal Procedure, 1973
✓ Section 162, Code of Criminal Procedure, 1973
✓ Extra-Judicial Confession
✓ Circumstantial Evidence
FAQ
Q: What is an extra-judicial confession?
A: An extra-judicial confession is a confession made by an accused outside of court to a private individual, not to a magistrate or judge.
Q: Is an extra-judicial confession enough to convict someone?
A: No, an extra-judicial confession alone is generally not sufficient for a conviction. It must be credible, voluntary, and corroborated by other evidence.
Q: What factors make an extra-judicial confession unreliable?
A: Factors such as the accused’s mental state, inconsistencies in testimonies, and lack of corroborating evidence can make an extra-judicial confession unreliable.
Q: What should you do if someone confesses a crime to you?
A: If someone confesses a crime to you, it is best to inform the authorities and allow them to investigate the matter further.