Introduction
In a landmark judgment, the Supreme Court of India has reiterated that an accused cannot confer the status of a confession to an eked-out First Information Report (FIR) against himself/herself or co-accused persons. The judgment in Narayan Yadav v State of Chhattisgarh has resolved overhanging debates on how statements made in FIRs ought to be treated, when the maker is also an accused but has attempted to cross the divide by styling it a confession, and it provide an important topical guidance as to the efficacy standards in criminal trials.
Background
The case arose when Narayan Yadav—the appellant—lodged an FIR at the Korba Kotwali Police Station, on 27 September 2019, confessing that he had murdered Ram Babu Sharma. The FIR detailed the events leading up to the murder, the quarrel, and eventually, what Narayan did ever after, including how he later made arrangements to dispose of the body and ran away. The FIR was registered, so it is no surprise that the investigation took its due course, and the trial was held using forensic, medical, and circumstantial evidence. Almost all of the panch witnesses (some hostile) yielded the same results, and the trial court found Narayan Yadav guilty of murder under Section 302 of the IPC. On appeal, the High Court modified the conviction to Section 304 Part I with exception 4 of Section 300 IPC.
Key Points
Admissibility of First Information Report (FIR) as evidence: The Supreme Court reiterated that a confessional FIR made by an accused cannot be used as evidence against the maker if it is inculpatory or against a co-accused. The Court made heavy reference to decisions such as Nisar Ali v. State of U.P., Faddi v. State of M.P., Aghnoo Nagesia v. State of Bihar, and reiterated only facts which were non-confessional admissions could be admissible as per Section 21 of the Indian Evidence Act, 1872.
Section 25 of the Evidence Act: The court explained that Section 25 bars confessions to a police officer; thus, if the accused claims any status at the time of making the confession, those statements are inadmissible. The only facts that can be admissible as per Section 27 of the Act are facts that were discovered through such statements, and all documents need to be presented.
Significance of Expert and Situational Evidence: The Court also recognized that expert witness testimony, including medical evidence, is corroborative and cannot on its own ground a conviction for murder under any of its forms. The Court also noted that the antagonism of the panch witnesses further doused the charges and would certainly have weakened the prosecution’s case even more, in the discovery of objects or facts stage.
Conduct in Relation to Section 8: Conduct of the accused is also relevant to Section 8 of the Evidence Act, but the Supreme Court pointed out that conduct as a reason cannot ground a conviction without other corroborative evidence of the prosecution’s case.
Recent Developments
The Supreme Court on August 5, 2025, reiterated its ruling to overturn the conviction that found that neither the confessional statement in the FIR nor subsequent conduct of the appellant standing alone, established guilt beyond reasonable doubt. The Court criticized the trial and appellate courts for treating the confessional aspects of the FIR and such inadequate medical and circumstantial evidence as a sufficient basis for conviction. The court highlighted its message that conviction cannot be based only on expert evidence or evidence that is inadmissible by statute.
Moreover, the Supreme Court noted with criticism the High Court’s application of Exception 4 to Section 300 IPC, emphasizing that all component parts must be clearly established, as a matter of law, including, inter alia, mutual provocation and a genuine “sudden fight,” for either of those exceptions to reduce culpability from murder to culpable homicide.
Conclusion
The ultimate decision of the Supreme Court in Narayan Yadav v State of Chhattisgarh is an essential reminder that the fundamental protections of evidence, in criminal law, are not a technicality but a protection against wrongful convictions. By affirming that confessional FIRs cannot be used against the maker, as well as any other co-accused, and holding the burden higher for admissibility of expert and circumstantial evidence, the Supreme Court relied upon statutory obligations and its own constitutional duties to ensure a fair trial. This decision will have an impact on future lower court judges and trial lawyers dealing with the interaction of confessions, FIR, and the rights of an accused.
Information Report (FIR) against himself/herself or co-accsued persons. The judgment in Narayan Yadav v State of Chhattisgarh has resolved overhanging debates on how statements made in FIRs ought to be treated, when the maker is also an accused but has attempted to cross the divide by styling it a a confession, and it provide an important topical guidance as to the efficacy standards in criminal trials.
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WRITTEN BY __ Kondala Phani Priya
