Introduction:

The Supreme Court recently delivered a significant judgment in the case of Randeep Singh @ Rana & Anr. Versus State of Haryana & Ors., addressing the admissibility of evidence under Section 27 of the Indian Evidence Act, 1872. The Court, while allowing an appeal against the conviction of the accused in a murder case, underscored the limited scope of Section 27, ruling that only the portion of an accused’s statement directly leading to the discovery of evidence is admissible. The judgment, rendered by a bench comprising Justices Abhay S. Oka, Ahsanuddin Amanullah, and A.G. Masih, critically evaluated the inclusion of inadmissible confessional statements by the prosecution in the examination-in-chief of a witness and highlighted procedural lapses at the trial court level. The accused were charged with abduction and murder. Still, the Court found that the circumstantial evidence presented did not establish their guilt beyond a reasonable doubt, ultimately leading to their acquittal.

Prosecution’s Arguments:

The prosecution contended that the accused had made statements during police custody that directly led to the discovery of the location where the victim’s body was disposed of. They further argued that the accused had voluntarily disclosed crucial information about the abduction and murder, substantiated by the investigating officer’s testimony. The prosecution relied heavily on the alleged confessions and the subsequent recovery of the body, asserting that the confessional statements should be admissible as per Section 27 of the Evidence Act.

Defense’s Arguments:

The defense vehemently opposed the admissibility of the accused’s confessional statements, asserting that they were recorded in violation of Sections 25 and 26 of the Evidence Act, which bar confessions made to police officers from being admitted as evidence. They argued that only the specific portion of the statement leading to the recovery of the body could be considered under Section 27, and any attempt to admit the broader confession was a grave procedural error. The defense also emphasized that the prosecution’s case was entirely circumstantial, with no direct evidence linking the accused to the alleged crime. They contended that the chain of events was incomplete and riddled with inconsistencies, making the conviction unsustainable.

Court’s Judgment:

• Clarification on Section 27 of the Evidence Act

The Supreme Court provided a detailed interpretation of Section 27 of the Evidence Act, reiterating that only the portion of an accused’s statement that “distinctly relates” to the discovery of evidence is admissible in court. The bench expressed concern over the trial court’s reliance on inadmissible portions of the accused’s confessional statements, stating that such practices could prejudice the judiciary and compromise the fairness of the trial. Justice Oka criticized the inclusion of broad confessions in the deposition, emphasizing that Sections 25 and 26 of the Evidence Act categorically prohibit confessions made to police officers from being used as evidence, barring the limited exception provided under Section 27.

• Examination of Evidence:

The Court scrutinized the prosecution’s evidence and found that the circumstantial evidence did not establish a conclusive link between the accused and the crime. The investigating officer’s testimony (PW-27) was found to have improperly included inadmissible confessional statements, which, the Court noted, should not have been allowed by the trial judge. The alleged discovery of the locations where the abduction, murder, and disposal occurred was not corroborated by sufficient independent evidence. The Court observed that the prosecution had failed to prove the chain of events beyond a reasonable doubt, a requirement in cases based solely on circumstantial evidence.

• Acquittal of the Accused:

Based on the above findings, the Supreme Court held that the conviction of the accused could not be sustained. The Court emphasized that admissible evidence must form the basis of a conviction, and procedural safeguards must be strictly followed to prevent miscarriages of justice. The bench also highlighted the need for trial courts to exercise caution and refrain from being influenced by inadmissible material. Accordingly, the appeal was allowed, and the accused were acquitted of all charges under the Indian Penal Code.