In this case, the accused, Aghnoo Nagesia, was charged with murdering four of his family members his aunt Ratni, her daughter Chamni, Chamni’s husband Somra, and their son Dilu. After committing the crime, he himself went to the police station and filed an FIR. In that FIR, he gave a detailed confession, stating how he killed them, which weapon he used, and where he had hidden their bodies.
The Trial Court relied on this confession and convicted him under Section 302 of the Indian Penal Code (IPC) for murder. The High Court later confirmed this decision. Aghnoo Nagesia then approached the Supreme Court by way of a special leave petition.
Issue before the court
The main issue before the court was whether the confession made by the accused (Aghnoo Nagesia) in the First Information Report (FIR) to the police could be used as evidence to convict him for murder under Section 302 of the Indian Penal Code.
Contention before the Court
The petitioner contends that Section 25 of the Indian Evidence Act only bars the use of that part of the statement which clearly shows that the appellant committed the murder. It does not protect or exclude the remaining parts of the statement which do not relate directly to the act of killing. So, only the portion of the confession that talks about the actual crime is inadmissible, but the rest of the statement can still be used as evidence.
Analysis of the Court
In this case, the Supreme Court ruled that any confession made by an accused person to a police officer and recorded in an FIR cannot be used as evidence in court because it is barred under Section 25 of the Indian Evidence Act. The Court explained that a confession often includes many elements such as the motive behind the crime, how it was planned, what weapon was used, and how the weapon was hidden, along with the accused's behavior after the crime.
The Court also referred to Section 27 of the Indian Evidence Act, which is an exception to the general rule. This section allows certain parts of a confession to be used in evidence, but only if it leads to the discovery of a fact, like finding the murder weapon or the dead body (called a "discovery statement").
However, the Court clarified that a person cannot be convicted solely on the basis of such a confessional statement made before the police. Just because the accused knew where the weapon or bodies were found does not automatically prove that he committed the crime. That confession must be supported by other strong and reliable evidence. As a result, the accused in this case was found not guilty of murder.
Concluding Remark
In conclusion, the Aghnoo Nagesia v. State of Bihar case played an important role in clarifying the law on confessional statements made to the police. The Supreme Court clearly held that any confessional FIR given to a police officer cannot be used as evidence under Section 25 of the Indian Evidence Act. It also limited the use of Section 27, stating that it applies only when the accused is in police custody and some specific fact is discovered as a direct result of the confession. This judgement is significant as it upholds the rights of the accused and prevents the misuse of confessions obtained under pressure, thus strengthening the safeguards against wrongful conviction.
