Latest JudgementIndian Penal Code, 1860Indian Evidence Act, 1872

Rajendra Singh & Others v. State of Uttaranchal, 2025

The judgment protects the rights of the accused from wrongful conviction based on partially inadmissible evidence.

Supreme Court of India·8 October 2025

Court

Supreme Court of India

Date of Decision

8 October 2025

Judges

Justice Pankaj Mithal and Justice Prasanna B. Varale

Citation

Acts / Provisions

Section 302 IPC Section 25, 26 & Section 27 of the Indian Evidence Act, 1872

Facts of the Case

The appellants were convicted under Section 302 IPC (murder).
The only incriminating evidence against them was their disclosure statements under Section 27 of the Evidence Act, where they allegedly led police to recover weapons.
The prosecution claimed that the weapons were the murder weapons based on these statements.
However, the weapons were not forensically linked to the deceased (no FSL report was produced).
The Trial Court acquitted the accused.
The High Court reversed the acquittal and convicted them.
This led to the appeal before the Supreme Court.

Is the entire disclosure statement under Section 27 admissible against the accused?
Can the recovered weapon be linked to the crime without forensic evidence?
Did the High Court err in reversing the trial court's acquittal based solely on recovery?

The Supreme Court acquitted all three accused, setting aside the conviction by the High Court.
The Court held “Only that part of the disclosure statement under Section 27 that leads to the recovery of a fact is admissible. The part stating that the weapon was used in the crime is inadmissible as it amounts to a confession barred under Sections 25 and 26.”
The Court reiterated the law laid down in Pulukuri Kottaya v. King Emperor, 1947 that Only discovery-related facts are admissible.

The High Court erred in interfering with the Trial Court's acquittal.
The weapon recovery, without forensic proof linking it to the deceased (e.g., no blood match or FSL report), could not prove guilt.
The disclosure statement was partly inadmissible, especially the part attributing the murder to the recovered weapons.
The Appellants acquitted by granting them the benefit of doubt.

The only incriminating evidence against them was their disclosure statements under Section 27 of the Evidence Act, where they allegedly led polic
This case reinforces settled law on the limited admissibility of confessional statements under Section 27.
The judgment protects the rights of the accused from wrongful conviction based on partially inadmissible evidence.
Mere recovery of weapons, without scientific or corroborative evidence linking them to the crime, is not sufficient for conviction.
The Court's stance also preserves the sanctity of trial court findings, cautioning appellate courts against casual reversal of acquittals.