This case sets a precedent for the admissibility of confessions in First Information Reports (FIRs). The Indian Evidence Act, 1872 (IEA) discrepancy between Sections 25, 26, and 27 is resolved by this case of aghnoo nagesia v the state of bihar.
aghnoo nagesia v the state of bihar Case Facts
- Aghnoo Nagesia, the appellant, was accused in 1963 of killing four people in violation of section 302 of the indian penal code, 1860 (IPC).
- These offenses were reported to the police by the appellant himself.
- The officer in charge of that Police Station, a Sub-Inspector, reduced the information about the offense to writing.
- After confirming with his left thumbprint, the appellant was taken into custody.
- During a joint inspection to the deceased victim’s home and other sites by the appellant and the Sub-Inspector, the bodies of the victims and the murder weapon were found.
- Furthermore, a chadar (a piece of fabric) soiled with human blood was found in the appellant’s home.
- According to medical evidence, all four victims had been brutally murdered since their incised wounds were consistent with having been caused by a sharp instrument, most likely a tangi.
- Notably, the confessional FIR that the appellant himself filed served as the main source of evidence, there were no eyewitnesses to the murders.
- After taking into account all of the relevant facts and circumstances, the Chotanagpur Judicial Commissioner found the appellant guilty of murder and gave him the death penalty.
- The appellant’s appeal was dismissed by the Patna High Court, which also accepted the death reference and upheld the conviction.
- The appellant invoked article 136 of the indian constitution of 1950 to petition the Supreme Court for Special Leave.
aghnoo nagesia v the state of bihar Issues
- Is it possible to convict an accused person of murder based solely on confessional remarks and the aforementioned evidence?
Contentions by the Parties
- Only the portions of the statement that reveal the appellant’s killing are protected by section 25 of the indian evidence act; the remaining portion of the statement is not.
aghnoo nagesia v the state of bihar: Important Laws Involved
- Section 302 of Indian Penal Code provides with the punishment for murder. Anyone found guilty of murder faces a life sentence in prison or the death penalty in addition to a fine. Since this is a cognizable offense, a police officer does not need a warrant to make an arrest. The Court of Sessions may hear the case, and it is an offense for which there is no bail.
- The Indian Evidence Act’s Section 24 addresses confessions obtained through coercion or inducement. In a criminal trial, any confession gained under duress or through promise is not admissible. The court will have the last say on whether or not the person in charge induced the accused to confess in any way. This would offer the accused an opportunity to avoid the severe penalty he might face if the case goes forward.
- Confessions made to a police officer are covered under Section 25 of the Indian Evidence Act. A confession given to a police officer cannot be used as proof of the accused’s criminal activity. The possibility that the confession so obtained was the product of coercion, as already mentioned in the previous section, leads to this part.
- The Criminal Procedure Code’s Section 162 addresses the use of remarks made to a police officer as evidence. It is not necessary for any statement made during the investigation by the accused or anybody else to be signed. This encompasses any documents generated throughout the course of an inquiry or legal proceeding and documented wherever, including the police journal. But the prosecution may record any remark made by someone who is called as a witness or for trial with a court’s authority.
- Confession recording is covered in Section 164 of the Criminal Procedure Code. Whether or whether the confession or statement is made within the magistrate’s jurisdiction, it should still be made in front of the magistrate. It is also mentioned that any such confession needs to be captured on audio and video while the defense attorney is present. It is required to inform the individual making the confession that it could be used against them in court.
aghnoo nagesia v the state of bihar Judgment
- The Supreme Court ruled that the accused’s confession to a police officer included in the FIR report is prohibited under Section 25 of the Indian Evidence Act and cannot be accepted into evidence.
- Confession is divided into various sections and can disclose not only the actual crime committed but also elements that could be used against the accused in the future, such as motive, provocation, opportunity, preparation, weapon used, intention, and concealment of the weapon.
- Additionally, the court brought up Section 27 of the Indian Evidence Act, which addresses the amount of information that the accused may prove (DISCOVERY STATEMENTS: This is an exception to the rule as only confessional statements can be introduced as evidence in court).
- The accused cannot be found guilty solely on the basis of a confessional statement made to the police, the court said, nor can it be accepted as evidence on its own because all that is established is the accused’s knowledge of the locations of the weapons and dead bodies. He could therefore be guilty or innocent.
- Therefore, additional pertinent evidence must support the confessional statement.
- The side that supports the accused should be considered when there are two plausible interpretations of the evidence. As a result, the accused was found not guilty of murder.
Moral Background of the Case
- Given that the main piece of evidence in the case under discussion was Mr. Aghnoo Nagesia’s confession to a police officer, the Honorable Supreme Court decided to acquit him despite the strong likelihood that he was the murderer. It may seem unfair to say this. But when you look at it more broadly, there are two possible outcomes.
- First of all, laws are enshrined in the legal system in multiple views. Even though the current laws have undergone numerous revisions, their continued prevalence can be attributed to their ability to uphold justice, even in seemingly insignificant ways. The prohibition against using such admissions as proof stems from the desire to shield innocent parties from any unnatural danger.
- The Court also believes that police personnel may use coercion to expedite the investigation process by threatening or offering something to the person who is being charged. For this reason, there is a clear prohibition.
- Second, what if the accused’s sibling had actually killed the victims and the older brother had confessed to the crime to keep the younger brother out of jail? There is a long shot for this.
- For this reason, every crime is thoroughly examined, and before a decision and judgment are made, lengthy arguments are heard. In the confusion matrix, this example may be a false positive, but one or two false positives must be accepted in order to avoid numerous false negatives.
The decision in Aghnoo Nagesia v. State of Bihar guarantees that the integrity of the legal system is not jeopardized by confessions made under duress or by unethical tactics. The Supreme Court’s ruling reinforced the concepts of justice and due process by highlighting how crucial it is to abide by the laws that guard against forced confessions and the abuse of authority by authorities. The ruling supports a more stringent and equitable legal system by highlighting the fact that confessions made while under police custody cannot serve as the only foundation for conviction if they are not thoroughly investigated.
Although the details of Aghnoo Nagesia v. State of Bihar offer some finality, the ideas it discusses are still relevant today. They serve as a reminder of the constant necessity to closely examine judicial processes and make sure that the pursuit of justice does not violate people’s rights. This foundation will unavoidably be built upon in subsequent cases as new facets of procedural justice and legal interpretation are explored.
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