In a recent ruling, the Supreme Court of India has elucidated crucial principles regarding the admissibility and weight of evidence obtained under Section 27 of the Evidence Act. This section pertains to the discovery of facts made in consequence of information received from accused persons in police custody. The apex court, in its judgment delivered by a bench comprising Justices BR Gavai and Sandeep Mehta, underscored the necessity for the prosecution to demonstrate that the discovery resulting from the accused's statement was not previously known to anyone.
The case under consideration involved the conviction of the accused by a trial court for various offenses under the Indian Penal Code. The prosecution had asserted that crucial evidence, namely the discovery of a deceased body, was made based on statements provided by the accused under Section 27 while in police custody. This conviction was subsequently upheld by the High Court.
However, in their appeal before the Supreme Court, the accused contended that the conviction could not be sustained as the prosecution had failed to establish that the discovery of the evidence was solely based on the accused's statements under Section 27. They argued that there was prior knowledge of the existence of the deceased's body at the location where it was found.
In its judgment, the Supreme Court concurred with the accused's contentions, emphasizing the prosecution's burden to prove beyond reasonable doubt that the discovery was indeed unknown prior to the accused's disclosure. The court highlighted discrepancies in the evidence, noting that witnesses and the police were already aware of the deceased's death and the location of the body before the accused's statements were recorded under Section 27.
As a result, the Supreme Court acquitted the accused, overturning the previous conviction. The ruling underscores the importance of meticulous scrutiny of evidence, particularly concerning discoveries made in consequence of accused persons' statements. It reaffirms the principle that such evidence must not only be admissible but also incontrovertibly linked to facts previously unknown to ensure a fair and just trial.
This landmark judgment serves as a significant legal precedent, providing clarity on the interpretation and application of Section 27 of the Evidence Act. It underscores the court's commitment to upholding the principles of justice, fairness, and the rule of law in criminal proceedings.
