Narayan Yadav v. State of Chhattisgarh

Criminal Appeal · 2025 INSC 927Decided 5 Aug 2025
Crl.A. No.-003343-003343 - 2025 (arising out of SLP (Crl.) No. 10595 of 2025)
Justice J.B. Pardiwala · Justice R. Mahadevan

Background

The appellant himself walked into a police station and lodged an FIR confessing that he had killed a man named Ram Babu Sharma after a drunken quarrel, and had also taken money and a vehicle from the house. He was tried and convicted of murder under Section 302 IPC; the High Court of Chhattisgarh partly allowed his appeal, downgrading the offence to culpable homicide not amounting to murder (Section 304 Part I IPC) by applying "Exception 4" (a sudden fight without undue advantage). The appellant challenged even this reduced conviction before the Supreme Court.

Decision Breakdown

The Supreme Court held that the appellant's own FIR was a confession made to police and, by law, is not admissible in evidence against him: the entire conviction of both lower courts rested on this inadmissible confession plus circumstantial recoveries that, on their own, did not prove guilt beyond reasonable doubt. Because there was no other credible, legally admissible evidence connecting the appellant to the killing, the Court found this to be a case of "no legal evidence" and acquitted him of all charges. The Court also went on to explain, for future guidance, that the High Court's use of Exception 4 was wrong in any event, since the deceased was unarmed and the attack was one-sided and excessive: such facts cannot support a "sudden fight" defense, though this observation did not change the final acquittal since the prosecution had no separate appeal challenging it.

Lesson Learnt

A confession made by an accused to a police officer, even one an accused volunteers on his own, cannot by itself be used to convict him; courts must find other legally admissible evidence. Separately, claiming a "sudden fight" to reduce a murder charge only works if both sides were roughly equally armed and matched, attacking an unarmed person with a weapon typically rules out that defense.

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