Latest JudgementIndian Evidence Act, 1872

Anand Jakkappa Pujari @ Gaddadar v. State of Karnataka, 2026

It emphasized that admissibility requires that the information must lead to distinct and specific discoveries attributable to each accused.

Supreme Court of India·27 April 2026

Court

Supreme Court of India

Date of Decision

27 April 2026

Judges

Justice J.B. Pardiwala and Justice K.V. Viswanathan

Citation

Acts / Provisions

Section 27, Indian Evidence Act, 1872

Facts of the Case

The case concerned the disappearance and murder of a woman in Karnataka (March 2013).
The victim went missing on 23.03.2013, and her charred skeletal remains were recovered four days later from a forest area.
The prosecution alleged that the accused, including her brother, conspired due to a financial dispute involving money and gold.
It was alleged that the accused abducted, murdered, and burnt the body to destroy evidence.
The Trial Court convicted all accused; the High Court affirmed the conviction.
Before the Supreme Court, only two accused challenged the conviction.
A key piece of evidence was joint disclosure statements allegedly leading to recovery of crime-related locations.

Whether joint or simultaneous disclosure statements by multiple accused are admissible under Section 27 of the Evidence Act?
Whether a fact already discovered can be re-discovered through subsequent accused statements?
Whether conviction can be sustained primarily on last seen evidence without strong corroboration?

The Supreme Court held that joint disclosure statements are not per se inadmissible, but strict safeguards under Section 27 must be satisfied.
It clarified that a fact can be discovered only once, and cannot be repeatedly used against multiple accused.
If the police already know the fact, any subsequent statement does not amount to a valid discovery under Section 27.
The Court held that there cannot be a “re-discovery” of the same fact.
It emphasized that admissibility requires that the information must lead to distinct and specific discoveries attributable to each accused.
The Court observed that in the present case, the panch witness did not specify individual statements of the accused, making the evidence unreliable under Section 27.
It held that the alleged discoveries were joint and indistinct, failing the legal test.
The Court further noted that last seen evidence alone is insufficient to sustain conviction without corroboration.
It found that the prosecution failed to establish a complete chain of circumstances.

Joint disclosure statements are admissible only if they lead to distinct and identifiable discoveries attributable to each accused.
A fact already discovered cannot be rediscovered under Section 27 Evidence Act.
Conviction cannot rest solely on last seen theory without corroboration.
The conviction of the appellants was set aside and they were acquitted.

The Court clarified the fine distinction between joint disclosures and distinct discoveries under Section 27.
It reinforced that Section 27 is an exception to the rule against self-incrimination and must be strictly construed.
The judgment strengthens safeguards against mechanical reliance on police-recorded confessions/disclosures.
It emphasizes that evidentiary value arises only when discovery is clearly linked to a specific accused and new fact.
The ruling limits misuse of joint confessional statements in multi-accused cases.
It also reiterates that last seen theory is a weak form of circumstantial evidence unless strongly corroborated.