Date of the Judgment: 24 October 2018
Citation: (2018) INSC 969
Judges: A.M. Khanwilkar, J., L. Nageswara Rao, J.
Can family members be held guilty for concealing a murder committed within their household? The Supreme Court of India addressed this question in a case involving the murder of a woman and her son, where the step-son confessed to the crime and revealed the location of the bodies. The court examined the extent to which circumstantial evidence and the conduct of the accused could establish guilt, particularly when direct evidence is lacking. This judgment, authored by Justice A.M. Khanwilkar, clarifies the legal standards for circumstantial evidence and the implications of concealing a crime.

Case Background

On January 24, 2004, Shababul (PW-7), a village watchman, informed the Dedoli Police Station that Zahida Begum, the second wife of Akhtar Mohammad (appellant No. 3), and her 11-year-old son, Ishlam, had been missing for two months. Despite their disappearance, no family member had reported the matter to the police. Asar Mohammad (appellant No. 1) and Asraf Mohammad (appellant No. 2), the sons of Akhtar Mohammad from his first wife, were Zahida’s step-sons. Upon investigation, Asar Mohammad confessed to the police that he, along with his brother Asraf and their father Akhtar, had murdered Zahida and Ishlam and dumped their bodies in the septic tank in their backyard. The police recovered the highly decomposed bodies from the septic tank, with Zahida’s body tied with a nylon cord. The post-mortem examination revealed that both Zahida and Ishlam died due to asphyxia caused by fractures of the hyoid bone.

Timeline

Date Event
January 24, 2004 Shababul (PW-7) informs the police about Zahida Begum and Ishlam’s disappearance.
January 24, 2004 Police visit the village and Asar Mohammad (appellant No. 1) confesses to the murder and reveals the location of the bodies.
January 25, 2004 Post-mortem examination of the bodies is conducted.
January 26, 2004 Statements of Begum Banu (PW-1) and Akram are recorded.
February 10, 2004 Akhtar Mohammad (appellant No. 3) is arrested.
February 11, 2004 Charge sheet is submitted to the jurisdictional court.
August 5, 2004 Charges are framed against the appellants by the Sessions Court.
March 1, 2008 Sessions Court awards death sentence to the appellants.
July 30, 2009 High Court commutes the death sentence to life imprisonment for the offense under Section 302 of the Indian Penal Code (IPC).
October 24, 2018 Supreme Court delivers its judgment.

Course of Proceedings

The Additional Sessions Judge/Special Judge, J.P. Nagar, found all three appellants guilty under Section 302 (murder) and Section 201 (causing disappearance of evidence) of the Indian Penal Code (IPC), sentencing them to death and two years imprisonment, respectively. The High Court of Judicature at Allahabad upheld the conviction but commuted the death sentence to life imprisonment. The High Court reasoned that while the prosecution had proven the homicidal deaths and the involvement of the accused, the case did not qualify as the ‘rarest of rare’ to warrant a death sentence. The High Court also affirmed the conviction under Section 201 of the IPC.

Legal Framework

The key legal provisions in this case are:

  • Section 302 of the Indian Penal Code (IPC): This section defines the punishment for murder. It states, “Whoever commits murder shall be punished with death, or imprisonment for life, and shall also be liable to fine.”
  • Section 201 of the Indian Penal Code (IPC): This section deals with causing the disappearance of evidence of an offense or giving false information to screen the offender. It states, “Whoever, knowing or having reason to believe that an offence has been committed, causes any evidence of the commission of that offence to disappear, with the intention of screening the offender from legal punishment, or with that intention gives any information respecting the offence which he knows or believes to be false, shall be punished with imprisonment of either description for a term which may extend to seven years, and shall also be liable to fine.”

Arguments

Appellants’ Arguments:

  • The appellants argued that the prosecution’s evidence was insufficient to prove their guilt beyond a reasonable doubt, especially since the case was based on circumstantial evidence.
  • They contended that the motive for the crime was not established.
  • They questioned the identification of the deceased, claiming there was no solid proof that the recovered bodies were those of Zahida and Ishlam.
  • They argued that PW-7, the informant, was a police plant and his testimony should be disregarded.
  • They asserted that the police reports were tailored to fit the prosecution’s narrative.
  • They claimed that the statement made by Asar Mohammad to the police was inadmissible and could not be used against the co-accused.

State’s Arguments:

  • The State argued that the concurrent findings of the lower courts were correct and no interference was warranted.
  • The prosecution had established a complete chain of circumstances that pointed towards the involvement of the appellants in the crime.
  • They contended that the circumstances ruled out any other possibility of the crime being committed by someone else.
Main Submission Sub-Submissions (Appellants) Sub-Submissions (State)
Sufficiency of Evidence
  • Evidence is circumstantial and lacks quality.
  • Motive not established.
  • Identification of deceased not proven.
  • Informant (PW-7) is unreliable.
  • Police reports are tailored.
  • Statement of accused is inadmissible.
  • Concurrent findings of lower courts are correct.
  • Chain of circumstances is complete.
  • Circumstances point to the involvement of the appellants.

Innovativeness of the argument: The appellants innovatively argued that the police informant was planted and that the police reports were tailored to suit the prosecution’s case, thereby attempting to discredit the very foundation of the prosecution’s case.

Issues Framed by the Supreme Court

The Supreme Court considered the following key issues:

  1. Whether the prosecution had sufficiently established the guilt of the accused based on circumstantial evidence.
  2. Whether the confession of one accused could be used against the co-accused.
  3. Whether the appellants could be convicted under Section 201 of the IPC for concealing the crime.

Treatment of the Issue by the Court

Issue Court’s Decision Brief Reasons
Sufficiency of Circumstantial Evidence Upheld the conviction of Asar Mohammad (Appellant No. 1) but not for Asraf and Akhtar (Appellant Nos. 2 and 3) for murder. The court found that the circumstances, including Asar’s confession and leading the police to the bodies, established his guilt. However, there was no independent evidence against Asraf and Akhtar for murder.
Use of Co-accused Confession Ruled that the confession of a co-accused cannot be the sole basis for conviction. The court reiterated that a confession can only be used to support other evidence against a co-accused.
Conviction under Section 201 IPC Upheld the conviction of all appellants under Section 201 IPC. The court found that the appellants had knowledge of the murder and failed to report it, intending to screen the offender.
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Authorities

The Supreme Court relied on the following authorities:

Authority Court Legal Point How Applied
Padala Veera Reddy vs. State of Andhra Pradesh (1989) Supp. (2) SCC 706 Supreme Court of India Principles for assessing circumstantial evidence The court reiterated the tests for circumstantial evidence, emphasizing that the circumstances must be cogently established, point unerringly to guilt, and form a complete chain.
Gambhir v. State of Maharashtra (1982) 2 SCC 351 Supreme Court of India Tests for circumstantial evidence Cited as one of the cases that laid down the tests for circumstantial evidence.
Rama Nand v. State of Himachal Pradesh (1981) 1 SCC 511 Supreme Court of India Tests for circumstantial evidence Cited as one of the cases that laid down the tests for circumstantial evidence.
Prem Thakur v. State of Punjab (1982) 3 SCC 462 Supreme Court of India Tests for circumstantial evidence Cited as one of the cases that laid down the tests for circumstantial evidence.
Earabhadrapa alias Krishnappa v. State of Karnataka (1983) 2 SCC 330 Supreme Court of India Tests for circumstantial evidence Cited as one of the cases that laid down the tests for circumstantial evidence.
Gian Singh v. State of Punjab 1986 Supp (1) SCC 676 Supreme Court of India Tests for circumstantial evidence Cited as one of the cases that laid down the tests for circumstantial evidence.
Balwinder Singh v. State of Punjab (1987) 1 SCC 1 Supreme Court of India Tests for circumstantial evidence Cited as one of the cases that laid down the tests for circumstantial evidence.
Mulakh Raj & Ors. Vs. Satish Kumar & Ors. (1992) 3 SCC 43 Supreme Court of India Principles for circumstantial evidence The court emphasized that the prosecution must prove all circumstances connecting an unbroken chain of links leading to the conclusion that the accused committed the crime.
Nika Ram Vs. State of Himachal Pradesh (1972) 2 SCC 80 Supreme Court of India Inference of guilt from failure to explain circumstances The court noted that the accused’s failure to offer a cogent explanation about the circumstances of his wife’s death pointed towards his guilt.
Trimukh Moroti Kirkan Vs. State of Maharashtra (2006) 10 SCC 681 Supreme Court of India Burden of proof in cases of domestic violence The court explained that in cases of offenses within a house, the burden of proof on the prosecution is lighter, and the accused must provide a cogent explanation.
Stirland v. Director of Public Prosecution 1994 AC 315 House of Lords Duty of a Judge Cited to emphasize that a judge must ensure both that the innocent are not punished and the guilty do not escape.
State of Punjab v. Karnail Singh (2003) 11 SCC 271 Supreme Court of India Duty of a Judge Cited to emphasize that a judge must ensure both that the innocent are not punished and the guilty do not escape.
State of Tamil Nadu v. Rajendran (1999) 8 SCC 679 Supreme Court of India Significance of false explanations The court held that a false explanation by the accused adds to the chain of circumstances.
State of U.P. v. Dr. Ravindra Prakash Mittal (1992) 3 SCC 300 Supreme Court of India Significance of false explanations The court held that a false explanation by the accused adds to the chain of circumstances.
State of Maharashtra v. Suresh (2000) 1 SCC 471 Supreme Court of India Significance of false explanations The court held that a false explanation by the accused adds to the chain of circumstances.
Ganesh Lal v. State of Rajasthan (2002) 1 SCC 731 Supreme Court of India Significance of false explanations The court held that a false explanation by the accused adds to the chain of circumstances.
Gulab Chand v. State of M.P. (1995) 3 SCC 574 Supreme Court of India Significance of false explanations The court held that a false explanation by the accused adds to the chain of circumstances.
Vasanta Sampat Dupare v. State of Maharashtra (2015) 1 SCC 253 Supreme Court of India Interpretation of Section 27 of the Evidence Act The court clarified that the “fact discovered” under Section 27 includes the place from which an object is produced and the knowledge of the accused about its existence.
Pulukuri Kotayya v. King Emperor AIR 1947 PC 67 Privy Council Interpretation of Section 27 of the Evidence Act The court clarified that the “fact discovered” under Section 27 includes the place from which an object is produced and the knowledge of the accused about its existence.
Mohd. Inayatullah v. State of Maharashtra (1976) 1 SCC 828 Supreme Court of India Scope of Section 27 of the Evidence Act The court discussed the conditions for admissibility of information under Section 27, emphasizing that only the information directly linked to the discovery is admissible.
Sukhan v. Emperor AIR 1929 Lah 344 Lahore High Court Interpretation of “fact discovered” The court held that the expression ‘fact discovered’ in the section is restricted to a physical or material fact which can be perceived by the senses, and that it does not include a mental fact.
Ganu Chandra Kashid v. Emperor AIR 1932 Bom 286 Bombay High Court Interpretation of “fact discovered” The court held that the expression ‘fact discovered’ in the section is restricted to a physical or material fact which can be perceived by the senses, and that it does not include a mental fact.
Udai Bhan v. State of U.P. AIR 1962 SC 1116 Supreme Court of India Interpretation of “fact discovered” The court held that the expression ‘fact discovered’ includes not only the physical object produced, but also the place from which it is produced and the knowledge of the accused as to this.
Aftab Ahmad Anasari v. State of Uttaranchal (2010) 2 SCC 583 Supreme Court of India Admissibility of disclosure statements The court held that the part of a disclosure statement that relates to the discovery of a fact is admissible under Section 27 of the Evidence Act.
State of Maharashtra v. Damu (2000) 6 SCC 269 Supreme Court of India Interpretation of Section 27 of the Evidence Act The court held that recovery of an object is not discovery of a fact as envisaged in Section 27 of the Evidence Act.
State of Punjab v. Gurnam Kaur (2009) 11 SCC 225 Supreme Court of India Interpretation of Section 27 of the Evidence Act The court held that recovery of an object is not discovery of a fact as envisaged in Section 27 of the Evidence Act.
Bhagwan Dass v. State (NCT of Delhi) (2011) 6 SCC 396 Supreme Court of India Interpretation of Section 27 of the Evidence Act The court held that recovery of an object is not discovery of a fact as envisaged in Section 27 of the Evidence Act.
Manu Sharma v. State (NCT of Delhi) (2010) 6 SCC 1 Supreme Court of India Interpretation of Section 27 of the Evidence Act The court held that recovery of an object is not discovery of a fact as envisaged in Section 27 of the Evidence Act.
Rumi Bora Dutta v. State of Assam (2013) 7 SCC 417 Supreme Court of India Interpretation of Section 27 of the Evidence Act The court held that recovery of an object is not discovery of a fact as envisaged in Section 27 of the Evidence Act.
Prakash Chand v. State (Delhi Admn.) (1979) 3 SCC 90 Supreme Court of India Admissibility of conduct as evidence The court held that the conduct of an accused, such as leading the police to a place, is admissible under Section 8 of the Evidence Act.
H.P. Admn. v. Om Prakash (1972) 1 SCC 249 Supreme Court of India Admissibility of conduct as evidence The court held that the conduct of an accused, such as leading the police to a place, is admissible under Section 8 of the Evidence Act.
A.N. Venkatesh v. State of Karnataka (2005) 7 SCC 714 Supreme Court of India Admissibility of conduct as evidence The court held that the conduct of an accused, such as leading the police to a place, is admissible under Section 8 of the Evidence Act.
Kashmira Singh v. State of Madhya Pradesh 1952 SCR 526 Supreme Court of India Use of a co-accused’s confession The court clarified that a confession of a co-accused can only be used to lend assurance to other evidence against the co-accused.
Bhuboni Sahu v. R. (1948-49) 76 IA 147 Privy Council Use of a co-accused’s confession The court clarified that a confession of a co-accused can only be used to lend assurance to other evidence against the co-accused.
Periaswami Moopan, In re ILR (1931) 54 Mad 75 Madras High Court Use of a co-accused’s confession The court clarified that a confession of a co-accused can only be used to lend assurance to other evidence against the co-accused.
Emperor v. Lalit Mohan Chuckerbutty ILR (1911) 38 Cal 559 Calcutta High Court Use of a co-accused’s confession The court clarified that a confession of a co-accused can only be used to lend assurance to other evidence against the co-accused.
Haricharan Kurmi v. State of Bihar (1964) 6 SCR 623 Supreme Court of India Use of a co-accused’s confession The court reiterated that a confession of a co-accused cannot be treated as substantive evidence against a co-accused.
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Judgment

The Supreme Court upheld the conviction of Asar Mohammad (appellant No. 1) under Section 302 of the IPC, finding that the circumstantial evidence and his confession were sufficient to establish his guilt. However, the court acquitted Asraf Mohammad and Akhtar Mohammad (appellants No. 2 and 3) of the murder charges due to lack of independent evidence. The court affirmed the conviction of all three appellants under Section 201 of the IPC, holding that their failure to report the crime and their knowledge of the murder constituted an attempt to screen the offender from legal punishment.

Submission Treatment by the Court
Appellants’ claim that the evidence was insufficient Partially rejected. The Court found the evidence sufficient for Asar Mohammad’s conviction under Section 302 IPC but insufficient for Asraf and Akhtar.
Appellants’ argument that the motive was not established Acknowledged, but did not impact the conviction of Asar Mohammad due to other evidence.
Appellants’ challenge to the identification of the deceased Rejected. The Court found that the identity of the deceased was not disputed by the accused.
Appellants’ claim that PW-7 was a police plant Rejected. The Court found that the fact of the missing persons was established, regardless of the informant’s status.
Appellants’ claim that the police reports were tailored Rejected. The Court found that the circumstances established were sufficient to prove the guilt.
Appellants’ argument that the statement to the police was inadmissible Partially accepted. The Court held that the confession of Asar Mohammad could not be used against the co-accused for Section 302 IPC, but the part of the confession that led to the discovery was admissible.
State’s argument that the concurrent findings of the lower courts were correct Partially accepted. The Court upheld the conviction of Asar Mohammad for murder and all appellants for concealing the crime.
State’s argument that the chain of circumstances was complete Partially accepted. The Court found the chain complete for Asar Mohammad’s murder conviction and for all appellants under Section 201 IPC.

How each authority was viewed by the Court?

  • Padala Veera Reddy vs. State of Andhra Pradesh [CITATION]: The court followed the principles laid down in this case for assessing circumstantial evidence, emphasizing that the circumstances must be cogently established, point unerringly to guilt, and form a complete chain.
  • Gambhir v. State of Maharashtra [CITATION]: The court cited this case as one of the authorities that laid down the tests for circumstantial evidence.
  • Rama Nand v. State of Himachal Pradesh [CITATION]: The court cited this case as one of the authorities that laid down the tests for circumstantial evidence.
  • Prem Thakur v. State of Punjab [CITATION]: The court cited this case as one of the authorities that laid down the tests for circumstantial evidence.
  • Earabhadrapa alias Krishnappa v. State of Karnataka [CITATION]: The court cited this case as one of the authorities that laid down the tests for circumstantial evidence.
  • Gian Singh v. State of Punjab [CITATION]: The court cited this case as one of the authorities that laid down the tests for circumstantial evidence.
  • Balwinder Singh v. State of Punjab [CITATION]: The court cited this case as one of the authorities that laid down the tests for circumstantial evidence.
  • Mulakh Raj & Ors. Vs. Satish Kumar & Ors. [CITATION]: The court applied the principles from this case, emphasizing that the prosecution must prove an unbroken chain of circumstances leading to the conclusion that the accused committed the crime.
  • Nika Ram Vs. State of Himachal Pradesh [CITATION]: The court used this case to support its inference of guilt based on the accused’s failure to explain the circumstances of the crime.
  • Trimukh Moroti Kirkan Vs. State of Maharashtra [CITATION]: The court applied the principle that in cases of domestic offenses, the prosecution’s burden is lighter, and the accused must provide a cogent explanation.
  • Stirland v. Director of Public Prosecution [CITATION]: The court cited this to emphasize the dual duty of a judge to protect the innocent and ensure that the guilty do not escape.
  • State of Punjab v. Karnail Singh [CITATION]: The court cited this to emphasize the dual duty of a judge to protect the innocent and ensure that the guilty do not escape.
  • State of Tamil Nadu v. Rajendran [CITATION]: The court used this case to support its view that a false explanation by the accused adds to the chain of circumstances.
  • State of U.P. v. Dr. Ravindra Prakash Mittal [CITATION]: The court used this case to support its view that a false explanation by the accused adds to the chain of circumstances.
  • State of Maharashtra v. Suresh [CITATION]: The court used this case to support its view that a false explanation by the accused adds to the chain of circumstances.
  • Ganesh Lal v. State of Rajasthan [CITATION]: The court used this case to support its view that a false explanation by the accused adds to the chain of circumstances.
  • Gulab Chand v. State of M.P. [CITATION]: The court used this case to support its view that a false explanation by the accused adds to the chain of circumstances.
  • Vasanta Sampat Dupare v. State of Maharashtra [CITATION]: The court applied the principles from this case to interpret Section 27 of the Evidence Act, clarifying that the “fact discovered” includes the place from which an object is produced and the accused’s knowledge of it.
  • Pulukuri Kotayya v. King Emperor [CITATION]: The court followed this case to interpret Section 27 of the Evidence Act, clarifying that the “fact discovered” includes the place from which an object is produced and the accused’s knowledge of it.
  • Mohd. Inayatullah v. State of Maharashtra [CITATION]: The court used this case to explain the scope of Section 27 of the Evidence Act, emphasizing that only the information directly linked to the discovery is admissible.
  • Sukhan v. Emperor [CITATION]: The court cited this case to show the earlier view that the expression ‘fact discovered’ in the section is restricted to a physical or material fact which can be perceived by the senses, and that it does not include a mental fact.
  • Ganu Chandra Kashid v. Emperor [CITATION]: The court cited this case to show the earlier view that the expression ‘fact discovered’ in the section is restricted to a physical or material fact which can be perceived by the senses, and that it does not include a mental fact.
  • Udai Bhan v. State of U.P. [CITATION]: The court cited this case to show that the expression ‘fact discovered’ includes not only the physical object produced, but also the place from which it is produced and the knowledge of the accused as to this.
  • Aftab Ahmad Anasari v. State of Uttaranchal [CITATION]: The court used this case to support the admissibility of disclosure statements under Section 27 of the Evidence Act.
  • State of Maharashtra v. Damu [CITATION]: The court used this case to support the interpretation of Section 27 of the Evidence Act that the recovery of an object is not the same as discovery of a fact.
  • State of Punjab v. Gurnam Kaur [CITATION]: The court used this case to support the interpretation of Section 27 of the Evidence Act that the recovery of an object is not the same as discovery of a fact.
  • Bhagwan Dass v. State (NCT of Delhi) [CITATION]: The court used this case to support the interpretation of Section 27 of the Evidence Act that the recovery of an object is not the same as discovery of a fact.
  • Manu Sharma v. State (NCT of Delhi) [CITATION]: The court used this case to support the interpretation of Section 27 of the Evidence Act that the recovery of an object is not the same as discovery of a fact.
  • Rumi Bora Dutta v. State of Assam [CITATION]: The court used this case to support the interpretation of Section 27 of the Evidence Act that the recovery of an object is not the same as discovery of a fact.
  • Prakash Chand v. State (Delhi Admn.) [CITATION]: The court used this case to support the admissibility of the accused’s conduct, such as leading the police to the bodies, as evidence under Section 8 of the Evidence Act.
  • H.P. Admn. v. Om Prakash [CITATION]: The court used this case to support the admissibility of the accused’s conduct, such as leading the police to the bodies, as evidence under Section 8 of the Evidence Act.
  • A.N. Venkatesh v. State of Karnataka [CITATION]: The court used this case to support the admissibility of the accused’s conduct, such as leading the police to the bodies, as evidence under Section 8 of the Evidence Act.
  • Kashmira Singh v. State of Madhya Pradesh [CITATION]: The court applied the principle from this case that a confession of a co-accused can only be used to lend assurance to other evidence against the co-accused.
  • Bhuboni Sahu v. R. [CITATION]: The court applied the principle from this case that a confession of a co-accused can only be used to lend assurance to other evidence against the co-accused.
  • Periaswami Moopan, In re [CITATION]: The court applied the principle from this case that a confession of a co-accused can only be used to lend assurance to other evidence against the co-accused.
  • Emperor v. Lalit Mohan Chuckerbutty [CITATION]: The court applied the principle from this case that a confession of a co-accused can only be used to lend assurance to other evidence against the co-accused.
  • Haricharan Kurmi v. State of Bihar [CITATION]: The court reiterated the principle from this case that a confession of a co-accused cannot be treated as substantive evidence against a co-accused.
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Ratio Decidendi

The key legal principles established by the Supreme Court in this case are:

  • Circumstantial Evidence: In cases based on circumstantial evidence, the prosecution must prove a complete chain of circumstances that unerringly points towards the guilt of the accused. The circumstances must be cogently established and must rule out any reasonable possibility of the crime being committed by someone else.
  • Confession of a Co-Accused: The confession of a co-accused is not substantive evidence and cannot be the sole basis for conviction. It can only be used to lend assurance to other evidence against the co-accused.
  • Section 27 of the Evidence Act: The “fact discovered” under Section 27 includes not only the physical object produced but also the place from which it is produced and the knowledge of the accused about its existence. However, the recovery of an object is not the same as discovery of a fact.
  • Section 8 of the Evidence Act: The conduct of the accused, such as leading the police to the place where the bodies were hidden, is admissible as relevant evidence.
  • Section 201 of the IPC: Failing to report a crime with the intention of screening the offender is a punishable offense under Section 201 of the IPC.

Obiter Dicta

The Supreme Court made the following observations that were not essential to the decision but are significant:

  • Duty of a Judge: The court reiterated the duty of a judge to ensure that the innocent are not punished and that the guilty do not escape.
  • Significance of False Explanations: The court observed that a false explanation by the accused adds to the chain of circumstances against them.

Flowchart of the Case

Crime: Murder of Zahida Begum and Ishlam
↓
Police Investigation: Confession by Asar Mohammad, Recovery of Bodies
↓
Trial Court: Conviction and Death Sentence
↓
High Court: Commutation to Life Imprisonment
↓
Supreme Court: Upholds Conviction of Asar Mohammad for Murder, Conviction of All for Concealing Crime

Conclusion

The Supreme Court’s judgment in Asar Mohammad vs. State of U.P. provides a comprehensive analysis of the evidentiary standards required in cases based on circumstantial evidence. The court emphasized that while circumstantial evidence can be the basis for conviction, it must be complete and unerring. The judgment also clarified the limits on the use of a co-accused’s confession and the scope of Section 27 of the Evidence Act. The conviction of all three appellants under Section 201 of the IPC highlights the legal obligation of individuals to report criminal activity, particularly when they have knowledge of it. This case serves as a significant precedent for future cases involving circumstantial evidence and the concealment of crimes, underscoring the importance of a complete chain of circumstances and the legal implications of failing to report a crime.

Source: Asar Mohammad vs. State of U.P.