Prof.Dr.Mukund Sarda, Dr.Bhagyashree Deshpande


Extra-judicial confessions are those which are made to a person in authority or to police by an accused in custody. The major problem with such confessions is that its relevancy and admissibility. The said confessions are regarded as weak evidence due to simple reason of its genuineness. Sections 24 and 27 of Indian Evidence Act deal with admissibility of extra-judicial confessions. This law has been developed through precedents, in the case of PulukuriKottya Supreme Court laid down essentials of section 27 of the Indian Evidence Act. Furthermore, in the cases of Narayan Singh, Mulk Raj and Sahadevan v. State of Tamil Nadu, the Supreme Court has laid down conditions for admissibility of such confessions some mutual of them are that it must be voluntary, need to be verified and proved like an alleged fact. The paper aims to discuss this concept in detail and tries to resolve the issue admissibility of extra judicial confessions by suggesting certain guidelines.


extra judicial confession, Indian Evidence Act, admissibility, relevance

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Police Officer, so much of such information whether it amounts to a confession or not, as relates distinctly to the fact thereby discovered, may be proved”.

PulukuriKotayya v. Emperor, AIR 1947 PC P.67.

AIR 1985 SC P.1678.

Balwinder Singh v. State of Punjab, AIR 1996 SC P.607.

Pakkirisamy v. State of TN. AIR 1998 SC P.107.

State of Rajasthan v. Raja Ram, AIR 2003 SC P.360.

AlokeNath Dutta v. State of WB, (2007) 12 SCC P.230.

Sansar Chand v. State of Rajasthan, AIR 2011 SC (Cri) P.99.

See alsoThimma Raju v. State of Mysore, AIR 1971 SC P.1871; Mulk Raj v. State of U.P., AIR 1959 SC P.902; Shiva Karan PayaswamiTewari v. State of Maharashtra,AIR 2009 SC P.1692’ Mohd Azad v.. State of WB, AIR 2009 SC P.1307.

Ramesh ChandrabhaiRathod v. State of Gujarath (2009) AIR SCW P.3391.

S.K. Yusuf v. State of WB, AIR 2011 SC P 2283.See alsoPancho v. State of Haryana AIR 2012 SC P.523.

RanjeethdasMunidasTalwa and another v. State of Gujarat, 2016 Cr LJ P.278 (Gujarat HC).


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