The Supreme Court has ruled that a disclosure statement under Section 27 of the Indian Evidence Act, without supporting evidence, cannot be the sole basis for conviction. The verdict underscores that such statements, while relevant, are weak forms of evidence and must be corroborated by additional proof to establish guilt beyond a reasonable doubt.
A bench comprising Justice Abhay S. Oka and Justice Ujjal Bhuyan overturned the murder conviction of an accused under Section 302 of the Indian Penal Code. The ruling emphasized that aside from the accused’s disclosure statement leading to the recovery of a weapon, the prosecution failed to present substantive evidence to confirm his involvement in the crime.
The case revolved around an incident from December 31, 2010, in which the accused allegedly stabbed a man named Ramakrishnan, leading to his death. The prosecution contended that the act was driven by prior enmity, as the deceased was implicated in the murder of the accused’s elder brother.
Challenging his conviction, the appellant pointed out discrepancies in witness testimonies, highlighting omissions in their statements, such as the exact number of stab wounds and the distance from which they claimed to have seen the crime. He also argued that key eyewitnesses were not examined and that those who testified failed to report the incident immediately, raising doubts about their credibility.
The State defended the conviction, asserting that minor inconsistencies in the witnesses’ statements did not affect their reliability. It further argued that the accused’s disclosure statement, which led to the recovery of the weapon, strengthened the prosecution’s case.
However, the Supreme Court found the testimonies unreliable, noting significant gaps in the statements, including contradictions regarding the number of wounds and the witnesses’ proximity to the crime scene. Additionally, the Court questioned why the witnesses neither reported the incident to the police right away nor attempted to take the victim to the hospital.
The key legal issue before the Court was whether a disclosure statement leading to the recovery of a weapon, without any corroborating evidence, could be sufficient for conviction. Relying on a precedent set in Manoj Kumar Soni v. State of M.P (2023), the Court reiterated that a disclosure statement alone lacks the evidentiary strength to establish guilt beyond a reasonable doubt.
“A doubt looms: can disclosure statements per se, unaccompanied by any supporting evidence, be deemed adequate to secure a conviction? We find it implausible,” the Court observed, emphasizing that while such statements can aid investigations, they are insufficient on their own to prove charges conclusively.
Based on these findings, the Supreme Court allowed the appeal and acquitted the accused.