Supreme Court quashes murder conviction where extra‑judicial confessions lacked credibility

A bench of Justices Ujjal Bhuyan and Abhay S. Oka heard an appeal against the conviction under Section 302 IPC affirmed by the Bombay High Court, challenging a trial court’s reliance on extra‑judicial confessions to convict the accused for the death of his live‑in partner.

The Court allowed the appeal, held that the conviction could not be sustained on the basis of the uncorroborated extra‑judicial statements, and set aside the life sentence. The Bench emphasised that "extra‑judicial confession is a weak piece of evidence" and that suspicion alone could not substitute for proof. The Court, in its reasoning, observed: "As we know, circumstantial evidence is not direct to the point in issue but consists of evidence of various other facts which are so closely associated with the fact in issue that taken together, they form a chain of circumstances from which the existence of the principal fact can be legally inferred or presumed. The chain must be complete and each fact forming part of the chain must be proved. It has been consistently laid down by this Court that where a case rests squarely on circumstantial evidence, inference of guilt can be justified only when all the incriminating facts and circumstances are found to be incompatible with the innocence of the accused or the guilt of any other person." The Court concluded that the extra‑judicial confessions did not inspire confidence and that "suspicion howsoever strong cannot take the place of hard evidence."

Background The prosecution case was that the accused lived with the deceased Manda in a chawl and that, on the morning of March 21, 2003, he informed the landlord and relatives that his partner had died after he had assaulted her. The landlord (PW‑1) and relatives (including PW‑3, PW‑4 and PW‑6) testified that the accused admitted having assaulted Manda with a grinding stone and a stick. The landlord lodged an FIR and police investigation followed; no blood‑stained clothes, no recovery of the alleged grinding stone, and no forensic matching of blood were placed on record. The trial court convicted the appellant for murder and sentenced him to rigorous imprisonment for life; the High Court dismissed an appeal and affirmed conviction.

On special leave, the Supreme Court reviewed authorities on extra‑judicial confessions (including State of Rajasthan v. Raja Ram, Sansar Chand, and Sahadevan v. State of Tamil Nadu) and reiterated that extra‑judicial confession, being part of circumstantial evidence, required careful scrutiny: it must be voluntary, true, and inspire confidence, and ordinarily should be corroborated. The Bench found multiple infirmities: witnesses recorded that the accused appeared "in a confused state of mind" when the statements were made; material omissions existed between statements recorded under Section 161 CrPC and trial testimony; there was no corroborative recovery or forensic evidence; and the conduct of PW‑3 on hearing an alleged admission by his sister’s killer was inconsistent with what would be expected. The Court held these defects struck at the root of the prosecution case. Finding that the evidence failed the required tests, the Court held that the appellant was entitled to benefit of doubt, set aside the conviction and sentence, and ordered that the appellant be released if not required in any other case.

Case Details: Case No.: Criminal Appeal No. 608 of 2013 (2025 INSC 147) Case Title: Ramu Appa Mahapatar v. The State of Maharashtra Appearances: For the Petitioner(s): [Counsel not indicated in the judgment text] For the Respondent(s): [Counsel not indicated in the judgment text]