Supreme Court Overturns Conviction Based Solely on Extra-Judicial Confession in Murder Case: Chakarai @ Chakaravarthi vs. State (2019) INSC 48

LEGAL ISSUE: Whether a conviction under Section 302 of the Indian Penal Code can be solely based on an extra-judicial confession.

CASE TYPE: Criminal

Case Name: Chakarai @ Chakaravarthi vs. State Rep. by Inspector of Police

Judgment Date: 24 January 2019

Introduction

Date of the Judgment: 24 January 2019

Citation: (2019) INSC 48

Judges: Justice Mohan M. Shantanagoudar and Justice Dinesh Maheshwari

Can a person be convicted of murder based solely on their out-of-court confession? The Supreme Court of India recently addressed this critical question in a criminal appeal, ultimately overturning a conviction that relied exclusively on an extra-judicial confession. This case highlights the importance of corroborating evidence and the need for a thorough investigation in criminal cases. The judgment was delivered by a two-judge bench comprising Justice Mohan M. Shantanagoudar and Justice Dinesh Maheshwari.

Case Background

The deceased, Ramamurthy, worked as a collection agent for New Centurion Bank in Salem. The appellant, Chakarai, and another individual had taken out vehicle loans from the bank but failed to repay them. Ramamurthy, in his capacity as a collection agent, pressured the two to repay their loans. About six months before the incident, Ramamurthy had seized the vehicles of Chakarai and the other individual to force them to repay their loans. This led to animosity between Chakarai and the deceased. The prosecution alleged that Chakarai, along with other accused, conspired to kill Ramamurthy. On May 14, 2005, they called Ramamurthy to a location under the pretext of repaying the loans, forced him into a van, and killed him. His body was later found near an advocate’s house in Salem.

Timeline

Course of Proceedings

The Trial Court convicted all the accused. However, the High Court of Judicature at Madras upheld the conviction of the appellant (Accused No. 1) under Section 302 of the Indian Penal Code (IPC) while acquitting the other accused. The High Court primarily relied on the extra-judicial confession made by the appellant. The appellant then appealed to the Supreme Court.

Legal Framework

The primary legal provision involved in this case is Section 302 of the Indian Penal Code (IPC), which prescribes the punishment for murder. According to Section 302 of the IPC, “Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.” The case also revolves around the evidentiary value of an extra-judicial confession, which is a confession made by an accused outside of court to a person other than a police officer.

Arguments

The prosecution argued that the appellant had a motive to kill Ramamurthy due to the loan dispute. They presented evidence of the appellant being seen abducting the deceased, a conspiracy among the accused, and recovery of a Maruti van, weapon, and blood-stained clothes based on the appellant’s confession to the police. The prosecution also relied heavily on the extra-judicial confession made by the appellant to P.W.12, the Tahsildar. The defense argued that the extra-judicial confession was unreliable and appeared to be fabricated. They also pointed out that other evidence, such as the alleged abduction, conspiracy, and recovery of material objects, was not proven beyond a reasonable doubt.

The innovativeness of the defense argument lies in its focus on the unreliability of the extra-judicial confession, which was the primary evidence against the appellant. The defense successfully highlighted inconsistencies and implausibilities in the confession, raising doubts about its genuineness.

Issues Framed by the Supreme Court

The main issue before the Supreme Court was:

✓ Whether the conviction of the appellant under Section 302 of the IPC can be sustained based solely on the extra-judicial confession, especially when other circumstances remain unproven.

Treatment of the Issue by the Court

Authorities

The Supreme Court relied on the following authority:

✓ **Thangavelu v. State of Tamil Nadu, (2002) 6 SCC 498** – Supreme Court of India: This case was used to highlight the dangers of relying on extra-judicial confessions that are suspiciously detailed and appear to be fabricated. The Court in Thangavelu held that a detailed extra-judicial confession, which seems to anticipate prosecution evidence, is not reliable.

Judgment

The Supreme Court held that the extra-judicial confession in this case was unreliable because it was suspiciously detailed and appeared to be fabricated. The Court noted that the confession was recorded in nearly five full pages and included graphic details of the incident, the appellant’s background, and the actions of each accused. The Court found this to be unnatural conduct for someone making a voluntary confession. The Court also noted that the other circumstances relied upon by the prosecution were not proven beyond a reasonable doubt. The Court stated, “The extra-judicial confession gives us an impression that the same has been generated to make the courts believe the case against the appellant.” The Court also observed, “In a manner of speaking, if this confession is true the appellant had the foresight to guess as to who the prosecution witnesses are going to be and gives an impression, therefore, he was seeking to corroborate their future evidence.” The Supreme Court concluded, “…it would be unsafe to convict the accused and award life imprisonment to him based on the sole circumstance of an extra-judicial confession, more particularly since all the other circumstances remain unproved.” Therefore, the Supreme Court overturned the High Court’s decision and acquitted the appellant of all charges.

What weighed in the mind of the Court?

The Supreme Court was primarily influenced by the following factors:

✓ The suspiciously detailed nature of the extra-judicial confession, which appeared to be fabricated.

✓ The lack of corroborating evidence to support the confession.

✓ The failure of the prosecution to prove other circumstances, such as motive, abduction, conspiracy, and recovery, beyond a reasonable doubt.

✓ The need for a fair and impartial investigation.

Key Takeaways

✓ A conviction cannot be based solely on an extra-judicial confession.

✓ Corroborating evidence is essential to support a conviction.

✓ Extra-judicial confessions must be carefully scrutinized for reliability.

✓ The investigation process must be fair and impartial.

✓ This judgment reinforces the principle that the prosecution must prove its case beyond a reasonable doubt.

Directions

The Supreme Court directed that the appellant be released immediately if he was not required in any other case.

Development of Law

The ratio decidendi of this case is that a conviction cannot be based solely on an extra-judicial confession, especially when other evidence is lacking or unreliable. This judgment reinforces the need for corroborating evidence in criminal cases and highlights the importance of a thorough and impartial investigation. This case does not change the previous position of law but rather reaffirms the existing principles.

Conclusion

The Supreme Court’s decision in this case underscores the importance of reliable evidence in criminal cases. The Court’s ruling emphasizes that a conviction cannot be based solely on an extra-judicial confession, especially when other evidence is lacking or unreliable. The judgment serves as a reminder of the need for a thorough and impartial investigation and the importance of corroborating evidence in criminal proceedings.