Supreme Court Reaffirms Inadmissibility of Confessional FIRs or Solely on Medical Evidence

The Supreme Court of India acquitted the accused of a murder case, overturning a Chhattisgarh High Court decision. The Apex Court held that there was a complete absence of admissible legal evidence required for the conviction and It also highlighted the key errors in the lower court’s interpretation of criminal law, specially the admissibility of confessional FIRs and the application of Exception 4 to Section 300 of the Indian Penal Code.

Background: The case stemmed from an incident from the year 2019, where appellant/accused (Narayan Yadav), lodged an FIR confessing to the killing of Ram Babu Sharma, alleged to get into a quarrel over an offensive remark made about his girlfriend. Based on which the police started the investigation and recovered the body and the alleged weapon. The Trial Court convicted Yadav of murder under Section 302 IPC and sentenced him to life imprisonment.

In an appeal before the High Court, It modified the conviction from Murder to Culpable Homicide not amounting to murder under Section 304 Part I IPC, thereby extending the benefit of Exception 4 to Section 300., aggrieved by which the appellant/accused filed the present appeal before the Supreme Court.

Supreme Court's Key Observations:

The Supreme Court categorically held that the FIR lodged by the appellant—containing a confession—was inadmissible in evidence against him. Citing Section 25 of the Indian Evidence Act and precedents like Faddi v. State of M.P., 1964 and Aghnoo Nagesia v. State of Bihar, 1965, need to be referred to for the following points:

A confessional FIR cannot be used to prove guilt;
Any corroboration drawn from such a confession is impermissible;
Unless clearly separable, a confessional FIR must be excluded in its entirety;
Such statements may only be used to show the accused’s conduct (Section 8) or if they lead to discovery of facts (Section 27).

On the "Expert Medical Opinion" the Apex Court held that the expert medical opinion is only advisory and not conclusive, and It criticized the High Court’s reliance on the medical expert’s opinion (PW-10, Dr. R.K. Divya), holding that, in the absence of other admissible proof, medical evidence alone cannot establish the guilt.

On the "Limits of Discovery and Conduct Evidence" the Court observed that while actions like pointing out the body or lodging an FIR may be relevant under Section 8, however, no legally-valid discovery under Section 27 was established, as prosecution witnesses failed to testify about the accused’s specific statements; Since mere panchnamas are not substantive evidence and that cannot form the sole basis for a conviction in serious offences like murder.

The Apex Court held that the High Court misapplied the Exception 4 to Section 300 IPC as which applies only where a sudden fight occurs without premeditation and without the accused taking undue advantage. since there was no evidence of a mutual exchange of blows, which is essential to claim a "sudden fight."

If any exception applied, the Court observed, it might have been Exception 1 (grave and sudden provocation), though that too was not conclusively established.

In view of these findings, since the confessional FIR excluded and no other admissible evidence supported the conviction, the Supreme Court acquitted Narayan Yadav and ordered his immediate release. It also directed that the judgment be circulated to all High Courts, reaffirming critical principles of criminal jurisprudence and evidentiary law.

Bench: Justice J.B. Pardiwala and Justice R. Mahadevan