The Supreme Court highlighted the principles of law related to confession of the accused and that the accused needs to be treated as innocent until proven guilty.The rights of the accused cannot be compromised during the criminal procedure.Though this principle is an important principle of law, it has been frequently compromised during the legal and judicial procedure.
The highlighting of this principle by the Supreme Court would add credence and weight to the aforementioned principles.
Case: Sudarshan Singh Wazir vs. State (Delhi)
Issues Involved:
- Whether the confession made by the accused was voluntarily given and hence admissible in evidence.
- Whether the statement of the accused could be considered a valid piece of evidence, given the circumstances under which it was made.
- Whether the evidence provided by the prosecution was sufficient to establish the guilt of the accused beyond a reasonable doubt.
Background:
In this case, Sudarshan Singh Wazir was charged under the Indian Penal Code (IPC), in relation to an incident that occurred in Delhi. The prosecution relied on a confession made by the accused during police custody, which became a point of contention. The defence argued that the confession was not voluntary and was made under duress or coercion, thus challenging its admissibility.
Legal Issues and Provisions:
- Confessions under Indian Evidence Act: The admissibility of confessions made by an accused person is governed by Section 24 of the Indian Evidence Act, 1872, which prohibits confessions made under coercion or duress.
- Principle of Voluntariness: The confession must be voluntary, and it must be given without any external influence, threat, or inducement, as per the principles of criminal jurisprudence in India.
Court’s Findings:
- On the Confession:
The Supreme Court found that the confession made by Sudarshan Singh Wazir was not voluntary and hence, could not be treated as valid evidence. The Court referred to the safeguards under Section 24 of the Indian Evidence Act, which requires that a confession must be free from any form of compulsion. The Court noted that any confession made under duress would violate the right to a fair trial and would be inadmissible. - On the Admissibility of Evidence:
The Court emphasized that the prosecution’s evidence should be carefully scrutinized, especially when the confession is a primary piece of evidence. In this case, since the confession was deemed inadmissible, the Court found that the remaining evidence did not sufficiently establish the guilt of the accused beyond a reasonable doubt. - On the Burden of Proof:
The Court reiterated that the burden of proof in criminal cases lies with the prosecution. The accused is presumed innocent until proven guilty. In the absence of reliable evidence, the Court held that it could not convict the accused.
Key Legal Principles Laid Down:
- Voluntariness of Confessions: The judgment reasserted that confessions must be voluntary to be admissible in court. If the confession is obtained under threat, coercion, or inducement, it cannot be used as evidence.
- Burden of Proof: The prosecution must prove the guilt of the accused beyond a reasonable doubt, and mere suspicion is insufficient to secure a conviction.
- Due Process and Fair Trial: The Court emphasized that the principles of a fair trial and due process must be adhered to, especially when it comes to the rights of the accused.
Conclusion:
In the Sudarshan Singh Wazir vs. State (Delhi) case, the Supreme Court acquitted the accused due to the inadmissibility of the confession and the insufficient evidence to convict him. The Court upheld the rights of the accused to a fair trial and reiterated the importance of following due process in criminal investigations and trials.