Confession As A Confession

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The Indian Evidence Act does not define the term “confession”. In his book The Digest, Lord Stephen defined confession as- An admission by an accused from which an inference can be drawn that he has committed the crime. The Indian court relied on this definition for a long period of time which was later on modified by the Privy Council holding that only direct acknowledgment of guilt can be regarded as a confession.
In the case of Pakala Narayan Swami v. Emperor the question before the court was whether statements from which the guilt of an accused can be inferred amounts to a confession or not. It was observed by Lord Atkin that:
“A confession must either admit in terms the offence, or at any rate substantially all the facts which constitute …show more content…

The provisions relating confession in the Evidence Act, 1872 merely provide when a confession can be used as a piece of evidence in a court of law and presumption of genuineness of judicial confession but whether a confession can be the sole basis of conviction that is not stated in any statutory law, which are hereafter called rules of law, and therefore one has to rely on case laws. The sagacity and judiciousness of the judges determine, depending on facts of cases before them, when a confession, admitted in evidence, can be the basis of conviction. Further section 164 of Code of Criminal Procedure empowers any Metropolitan or Judicial Magistrate whether or not he has jurisdiction in the case to record any confession or statement of a person made in the course of investigation by the police, or (when the investigation has been concluded) at any time afterwards but before the commencement of the inquiry or trial. It applies only to the statements recorded in the …show more content…

When it is made to the court itself then it will be called judicial confession and when it is made to anybody outside the court, in that case it will be called extra-judicial confession. It may even consist of conversation to oneself, which may be produced in evidence if overheard by another. For example, in Sahoo v. State of U.P. the accused who was charged with the murder of his daughter-in-law with whom he was always quarreling was seen on the day of the murder going out of the house, saying words to the effect : “I have finished her and with her the daily quarrels.” The statement was held to be a confession relevant in evidence, for it is not necessary for the relevancy of a confession that it should be communicated to some other

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