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Munikrishna @ Krishna Etc. vs State by Ulsoor PS

Criminal Appeal · 2022 INSC 1322Decided 30 Sept 2022
Criminal Appeal Nos. 1597-1600 of 2022
S. Ravindra Bhat · Sudhanshu Dhulia

Background

In October 2000, a 72-year-old man was found murdered in his Bengaluru home, with his purse and some valuables missing. Five accused, including the appellants, were tried and convicted by the Sessions Court under Section 302 read with Section 34 IPC and sentenced to life imprisonment; the Karnataka High Court upheld the conviction in 2010. The appellants challenged this before the Supreme Court, arguing that the courts below had relied heavily on inadmissible "voluntary statements" and videographed confessions made by the accused to the police.

Decision Breakdown

The Supreme Court found that both the Trial Court and the High Court had wrongly relied on confessional statements made by the accused to the police (recorded on DVD and even broadcast on a TV channel), which are barred under Article 20(3) of the Constitution and Section 25 of the Indian Evidence Act. The Court also found the recovery of the alleged murder weapon and stolen gold to be unreliable: the knife's recovery was delayed by over four months without explanation and its witness turned hostile, while the recovered gold was not identified by the complainant as belonging to the deceased. The Court noted it had reached an identical conclusion in a related, earlier connected case involving some of the same accused (decided April 2022), criticizing the police practice of extracting and relying on confession-like statements. Applying the principle that suspicion, however strong, cannot substitute for legal proof, the Court set aside the convictions of the Sessions Court and High Court, allowed the appeals, and ordered the appellants' release unless wanted in another case.

Lesson Learnt

Confessions made by an accused to the police cannot be used as evidence against them. Courts must exclude such statements even where a crime is heinous, since suspicion or an "ugly" fact pattern can never replace legally admissible proof. Broadcasting an accused's police statements on television before trial is itself an interference with the administration of justice.

Official source (sci.gov.in)View Judgment (PDF)

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