AUTHOR NAME- Snehil Singh, B.A. L.L.B., Fifth Year.
NAME OF INSTITUTION: Babu Banarasi Das University, Lucknow
Citation: [2025] 2 S.C.R. 388 | Case Type: Criminal Appeal / 608/ 2013 |
Date of Judgement: 04 February 2025 | Judgement by: Hon’ble Mr. Justice Ujjal Bhuyan |
Petitioner: Rama Appa Mahapatar | Respondent: The State Of Maharashtra |
Disposal: Appeal Allowed | Order/ Judgement: Judgement |
FACTS:
In this case it was observed that Ramu Appa Mahapatar (the accused) and Manda (the victim) were living together in a rented room which was owned by Ravindra Gopal Jadhav. One day in morning of March 21, 2003, Ramu has informed Jadhav that Manda had died and he was going to Dipchale village to inform her family about her death. Ramu, along with his son, traveled to Dipchale and has met Manda’s brother, Bhagwan. In the presence of other witnesses—Chandabai, Pandhari, and Shankar. Ramu has reportedly admitted that he had made an argument with Manda, it has become such a big argument due to which he assaulted her, resulting in her death. Before Ramu could return with Manda’s family, Jadhav has entered the house, which was locked from the outside. Inside which he discovered the Manda’s body with some multiple injuries. The room was in disarranged, with some broken jewelry and scattered household items, which has basically suggested that a struggle had taken place.
ISSUE RAISED:
The question was raised that whether the confession made by the appellant was sufficient in order to convict him for the murder under section 302 of the Indian Penal Code[i].
RULE OF LAW:
In this case it is considered that such a type of extra judicial confession is always considered as weak evidence and a proper scrutiny has to be done in such a type of case. If it is required to make such confession to be the reason of the conviction, it has to be voluntary, truthful and must be accompanied by other evidences.
REASONING:
The Supreme Court has basically observed that when the prosecution has filled their case it has totally relied on the extra judicial confession which was made by the appellant before several witness earlier. But there was no other piece of evidences which could basically support the confession made by the appellant, some of the witnesses have mentioned that the appellant was totally in the confused state of mind and also some of the key details were omitted from the confession of the appellant which has basically made the confession unreliable.
HELD:
In this case the Supreme Court has basically set aside the appellant’s conviction and sentence and has ordered his release immediately unless some new connection is found in this case or any other. The court has mentioned that the principle of the extra judicial confession is inherently weak and it must have to be accompanied by any other type of reliable piece of evidence in order to sustain the conviction. Also, in this case the court has reinforced some cautious approach of the court that they must adopt when they are relying on the extra judicial confessions and also the court has highlighted the necessary evidences which must be present in order to establish the guilt beyond reasonable doubt.
BIBLIOGRAPHY:
Case name- Ramu Appa Mahapatar v. The State of Maharashtra (Criminal Appeal No. 608 of 2013).[ii]
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[i] The Indian Penal Code 1860, 302, No. 45 of 1860, Acts of Parliament (India).
[ii] [2025] 2 S.C.R. 388