Shaik Shabuddin v. State of Telangana; 2025 INSC 1449 - S.27 Evidence Act -SC-ST Act
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Indian Evidence Act 1872 - Section 27 - On an arrest, when the material objects could have been seized from the body of the accused on a mere search by the police, the attempt to convert it as a recovery under Section 27 cannot at all accepted- The disclosure relied upon can only relate to the concealment and the recovery of material objects on such disclosure made, which recovery has to be made in the persons of witnesses.
Criminal Trial - Rape and Murder -The medical evidence regarding the homicidal death and the rape committed on the victim, the time of death as stated in the postmortem report, the accused having been found in the same vicinity as the victim and the failure of the accused to establish the alibi as spoken of under Section 313 questioning, would provide a complete chain of circumstances to convict the accused under Sections 302 & 376D read with Section 34 of the IPC. (Para 12)
Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 - Section 3(2)(v) , 3(1)(w)(i) - The knowledge of the caste status of the victim; which is an essential ingredient under both the provisions under the SC/ST Act.
Case Info
- Case name: Shaik Shabuddin v. State of Telangana.
- Neutral citation: 2025 INSC 1449.
- Coram: Ahsanuddin Amanullah, J. and K. Vinod Chandran, J.
- Judgment date: December 17, 2025 (New Delhi).
- Caselaws and citations: None expressly cited by name in the judgment text provided; the Court discusses evidentiary principles (e.g., “last seen” theory, Section 106 Evidence Act, inadmissibility of custodial confessions, limits of Section 27 recoveries) without referencing specific precedents.
- Statutes/laws referred:
- Indian Penal Code, 1860: Sections 302, 376D, 34, 404.
- Indian Evidence Act, 1872: Sections 27, 106.
- Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989: Sections 3(2)(v), 3(1)(w)(i).
- Criminal Appellate Jurisdiction; Special Leave Petition (Criminal) No. 6850 of 2024 (procedural posture).
#SupremeCourt holds that the disclosure relied upon Section 27 Evidence Act can only relate to the concealment ! https://t.co/z1mPjcvLRx pic.twitter.com/Qn2oMgPYkn
— CiteCase 🇮🇳 (@CiteCase) December 17, 2025