Nagamma @ Nagarathna v. State of Karnataka 2025 INSC 1135 - Ss.25-27 Evidence Act - Motive
Indian Evidence Act 1872 - Section 27- A joint or simultaneous disclosure would per se be not inadmissible under Section 27 -But it is very difficult to place reliance on such an utterance in chorus; There would be practical difficulty in placing reliance on such evidence, It is for the Courts to decide, on a proper evaluation of evidence, whether and to what extent such a simultaneous disclosure. (Para 27)
Indian Evidence Act 1872 - Section 25,26 -The confession made to the SHO, overheard by the Sentry of the police station, has to be completely eschewed under Section 25. The confession made to the wife of the deceased and police constable; who arrived at the police station in the status of the neighbour of the deceased, also has to be eschewed under Section 26. (Para 25)
Circumstantial Evidence - Motive - Absence of motive is not an imperative circumstance to arrive at a conviction, in a case where there is ocular evidence. The role of motive is not very significant even when circumstances otherwise form an unbreakable chain. Motive only provides another link, and the absence of motive is a factor that weighs in favour of the accused. (Para 14)
Case Info
Case Name and Neutral Citation
- Case Name: Nagamma @ Nagarathna & Ors. v. State of Karnataka
- Neutral Citation: 2025 INSC 1135
Coram
- Coram:
- Justice K. Vinod Chandran
- Justice K. V. Viswanathan
Judgment Date
- Date of Judgment: September 22, 2025
Caselaws and Citations Referred
- State of West Bengal v. Vindu Lachmandas Sakhrani alias Deru
- Citation: AIR 1994 SC 772
- Suraj Pal v. State of Uttar Pradesh
- Citation: AIR 1995 SC 419
- Babu v. State of Kerala
- Citation: (2010) 9 SCC 189
- Santosh v. State (NCT of Delhi)
- Citation: (2023) 19 SCC 321
- Shivaji Chintappa Patil v. State of Maharashtra
- Citation: (2021) 5 SCC 626
- State of U.P. v. Deoman Upadhyaya
- Citation: 1960 SCC OnLine SC 8
- State (NCT of Delhi) v. Navjot Sandhu @ Afsan Guru
- Citation: (2005) 11 SCC 600
- Kishore Bhadke v. State of Maharashtra
- Citation: (2017) 3 SCC 760
- Mohd. Inayatullah v. State of Maharashtra
- Citation: (1976) 1 SCC 828
- Manoj Kumar Soni v. State of M.P.
- Citation: 2023 SCC OnLine SC 984
Statutes/Laws Referred
- Indian Penal Code (IPC):
- Section 302 (Murder)
- Section 34 (Acts done by several persons in furtherance of common intention)
- Section 109 (Abetment)
- Section 147, 323, 307, 149 (Referenced in caselaw context)
- Code of Criminal Procedure (CrPC):
- Section 161 (Examination of witnesses by police)
- Section 313 (Power to examine the accused)
- Indian Evidence Act, 1872:
- Section 25 (Confession to police officer not to be proved)
- Section 26 (Confession by accused while in custody of police not to be proved)
- Section 27 (How much of information received from accused may be proved)
- Section 106 (Burden of proving fact especially within knowledge)
#SupremeCourt on admissibility of joint or simultaneous disclosures under Section 27 Evidence Act. https://t.co/zwysmpvjIo pic.twitter.com/PlRfK8KrFC
— CiteCase 🇮🇳 (@CiteCase) September 22, 2025
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