Aghnoo Nagesia vs. State of Bihar is a landmark case on the evidentiary value of confessional FIR under section 25 and section 27 of the Indian Evidence Act 1872.
FACTS:
- Aghnoo Nagesia (appellant) murdered his aunt (Mrs. Ratni), her daughter (Ms. Chamni), her son-in-law (Somra), and the son of Somra (Dilu).
- After that, the appellant himself went to the police station and lodged the FIR. FIR included all the confessions of appellants that how he murdered them, where he hid their bodies, and with which weapon he murdered them.
- The Trial Court convicted under Section 302 of the Indian Penal Code the appellant based on his confessional statements.
- High Court also upheld the conviction. By special leave, he appealed to the Supreme Court.
LEGAL ISSUE:
Can the accused be convicted for the charge of murder on the grounds of the aforesaid evidence, i.e. considering only confessional statements for conviction?
CONTENTION:
Section 25 protects only those parts of the statement which disclose the killing by the appellant and Section 25 of the Indian Evidence Act does not protect the rest of the statement.
DECISION:
- Supreme Court held that the confession given in the FIR report by the accused to a police officer is barred by Section 25 of the Indian Evidence Act and cannot be admitted as evidence.
- Confession comprises several parts and may reveal not only the commission of the crime but also the incriminating factors like motive, preparation, opportunity, provocation, the weapon used, intention, concealment of the weapon, and subsequent conduct of the accused.
- Court also mentioned Section 27 of the Indian Evidence Act which talks about how much information received by the accused may be proved (DISCOVERY STATEMENTS–This is an exception to the general rule as Discovery Statements can be admissible in evidence taken only from confessional statements).
- Court held that accused cannot be convicted based on a confessional statement given before the Police and it cannot be admissible in evidence alone as the only thing proved is that the accused knew where the dead bodies and weapons were. Thus, he may be innocent or guilty.
- The confessional statement, therefore, must be corroborated by other relevant evidence.
- When two views of the evidence are possible, the view that favors the accused should be taken. Thus, the accused was held not guilty of murder.
CONCLUSION:
Section 25 serves as important protection granted to the accused, considering the power imbalance between the State and the accused person. In the absence of such protection, it might lead to an innocent person getting convicted for an offense that he has not committed.
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