Kiran Raj

The Supreme Court of India Division Bench of Justice J.B. Pardiwala and Justice R. Mahadevan held that the impugned judgment convicting an accused under Section 304 Part I of the Indian Penal Code was unsustainable in law. The Court determined that the conviction rested on inadmissible evidence and misapplication of legal principles, ultimately concluding that no legal evidence remained to support the charge. The Court directed that the accused be acquitted of all charges and released forthwith if not required in any other case. The bail bonds were ordered to stand discharged, and the Registry was directed to circulate a copy of the judgment to all High Courts.

On 27 September 2019, an FIR was lodged at Korba Kotwali Police Station, District Korba, by the accused himself. The FIR, registered for offences under Sections 302 and 380 IPC, contained a detailed account of events. The accused stated that he was living with a relative, working as a milk supplier, and had been invited by the deceased to drink alcohol at his residence. During the evening, the accused showed the deceased a photograph of his girlfriend, upon which the deceased allegedly made a remark suggesting she be brought to his house for one night. The FIR recorded that an altercation ensued, leading the accused to pick up a knife kept in the house and inflict blows on the deceased’s neck and stomach, followed by hitting him with a wooden log. The accused claimed he covered the body, ransacked the room, took a purse containing Rs. 7,000 and the keys of a Bolero car, and left in the vehicle. He met with an accident, was taken to hospital, and later informed relatives and police, eventually pointing out the location of the body.

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The investigation included recovery of a knife from the scene, collection of clothes allegedly worn during the offence, and preparation of panchnamas. The post-mortem report documented multiple incised wounds on the forehead, parietal bones, abdomen, and chest. The cause of death was recorded as shock due to haemothorax from laceration of the right lung.

The trial court, relying on oral and documentary evidence, convicted the accused under Section 302 IPC and sentenced him to life imprisonment. On appeal, the High Court altered the conviction to Section 304 Part I IPC, granting the benefit of Exception 4 to Section 300 IPC. The accused then appealed to the Supreme Court.

The Supreme Court examined the evidentiary basis for the conviction. It stated: "The FIR lodged by the appellant amounts to a confession, and any confession made by an accused before the police is hit by Section 25 of the Act of 1872." The Court found that the High Court’s reliance on the contents of the FIR to corroborate medical evidence was impermissible: "There was no question at all for the High Court to seek corroboration of the medical evidence on record with the confessional part of the FIR lodged by the appellant."

The Court elaborated on legal precedent, referring to decisions in Nisar Ali v. State of U.P., Faddi v. State of M.P., and Aghnoo Nagesia v. State of Bihar, which restrict the admissibility of confessional FIRs. It recorded that such FIRs can only be used as admissions under Section 21 of the Evidence Act if non-inculpatory.

On the reliance placed on expert medical opinion, the Court stated: "An accused cannot be held guilty of the offence of murder solely on the basis of medical evidence on record." It noted that most panch witnesses had turned hostile and the investigating officer did not prove the contents of the panchnamas in accordance with law.

Regarding Section 27 of the Evidence Act, the Court found no witness testimony specifying the exact statement by the accused leading to the discovery of any fact. On Section 8, it recorded: "While the conduct of an accused may be a relevant fact under Section 8... it cannot, by itself, serve as the sole basis for conviction, especially in a grave charge such as murder."

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Addressing Exception 4 to Section 300 IPC, the Court stated: "The deceased was unarmed... the appellant inflicted injuries all over his body indiscriminately. Exception 4 is not attracted." It added that even if an exception were considered, Exception 1 relating to grave and sudden provocation could have been more relevant, but the absence of admissible evidence rendered such analysis unnecessary.

The Court allowed the appeal and set aside the High Court’s judgment. It ordered: "The appellant is acquitted of all the charges, and he be set free forthwith if not required in any other case. The bail bonds stand discharged, if any." It further directed: "The Registry shall circulate one copy each of this judgment to all the High Courts."

Advocates Representing the Parties:

For the Petitioners: Ms. Manjeet Chawla, AOR

For the Respondents: Ms. Sugandha Jain, Standing Counsel for State of Chhattisgarh, Adv., Mr. Prabodh Kumar, AOR

Case Title: Narayan Yadav v. State of Chhattisgarh

Neutral Citation: 2025 INSC 927

Case Number: Criminal Appeal No. 3343 of 2025

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