The utility of an extra judicial confession as evidence in a murder trial is weak if there is no corroboration.

Criminal Appeal No. 2230 of 2010 in the Supreme Court of India involved the conviction of an accused for murder based on an extra-judicial confession.

The evidentiary value of such a confession is generally weak, but it can sustain a conviction if it is voluntary and truthful. The reliability of the confession is also important, and it is expected to be made to someone in whom the confessor has implicit faith.

“The prosecution’s case about extra­judicial confession does not inspire confidence at all. Moreover, there are no other circumstances brought on record which could support or corroborate the prosecution case. Therefore, in our considered view, the evidence in form of the extra­judicial confession of the appellant deserves to be discarded. Admittedly, there is no other evidence against the appellant. Therefore, the conviction of the appellant cannot be sustained.”

Pawan Kumar Chourasia …..Appellant
State of Bihar …..Respondent
decided by the Supreme Court on 14.03.2023


Sanjiv Narang Adv. is an Advocate on Record in the Supreme Court of India. His qualifications include an LLB from University of Delhi and a Masters degree in Personnel Management from Panjab University,Chandigarh.In his more than 3 decades of experience, he has practiced law at the District, High Court and Supreme Court levels.He also has more than a decade of experience in the field of Management. He is the author of two books namely Laws for Women in India and Innovation, Why What and How.