The Supreme Court of India has acquitted Narayan Yadav in a murder case, holding that his conviction was based on inadmissible evidence. The case involved the killing of Ram Babu Sharma in 2019, with the High Court of Chhattisgarh earlier altering the charge from murder (Section 302 IPC) to culpable homicide not amounting to murder (Section 304 Part I IPC). However, the apex court ruled that there was no admissible legal evidence to justify even this reduced charge.
Background of the Case
On September 27, 2019, Narayan Yadav lodged an FIR at Korba Police Station, confessing that he killed Ram Babu Sharma during a quarrel after consuming alcohol. He alleged that the deceased made an obscene remark about his girlfriend, leading to a heated argument and violent retaliation. He admitted to using a knife and log of wood to inflict fatal injuries, and then fled the scene.
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This confession became the crux of the prosecution's case. The trial court convicted him under Section 302 IPC, sentencing him to life imprisonment. The High Court, while partially allowing his appeal, downgraded the conviction to Section 304 Part I IPC, citing Exception 4 to Section 300 IPC (sudden provocation).
The Supreme Court, in its judgment delivered by Justice J.B. Pardiwala and Justice R. Mahadevan, held that:
"A confessional FIR made by an accused before a police officer is hit by Section 25 of the Indian Evidence Act, 1872, and is inadmissible in law."
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The Court emphasized that a confession made by an accused cannot be used as evidence unless it leads to the discovery of facts under Section 27 of the Evidence Act. In this case, the FIR, being entirely confessional in nature, could not be relied upon.
Furthermore, the prosecution failed to establish the discovery of any incriminating material under Section 27. Several panch witnesses turned hostile, and the police did not properly prove panchnamas or link the recovery to any admissible disclosure.
The medical officer, Dr. R.K. Divya, stated that the cause of death was hemorrhagic shock due to stab wounds. However, the Supreme Court reiterated:
"Medical expert evidence is advisory in nature and cannot be the sole basis for conviction unless corroborated by other admissible evidence."
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The Court clarified that medical opinion, while supporting the nature of injuries, does not independently prove the identity of the assailant.
The Supreme Court also noted that the High Court wrongly applied Exception 4 to Section 300 IPC, which deals with sudden fights without premeditation. The evidence showed no mutual combat or provocation from the deceased that would qualify under this Exception.
"The assault was one-sided and brutal. The deceased was unarmed and the injuries inflicted were excessive and indiscriminate."
The Court remarked that, even if any exception were to apply, Exception 1 (grave and sudden provocation) might have been more relevant, though ultimately not applicable due to lack of supporting evidence.
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The Supreme Court set aside the conviction entirely, stating:
"There is no legal evidence to support the conviction. The accused is entitled to acquittal."
Narayan Yadav was acquitted of all charges and ordered to be released immediately, unless detained in any other case.
Case Title: Narayan Yadav vs State of Chhattisgarh
Case No.: Criminal Appeal No. 3343 of 2025