Shanti Devi vs State of Haryana 2025 INSC 987 - Benefit Of Acquittal To Non-Appealing Accused
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Code of Criminal Procedure 1973 - When the entire case of the prosecution is being discarded, the benefit of this acquittal judgment deserves to be extended to the non-appealing accused. (Para 38)
Indian Evidence Act 1872 - Section 25-27 - confessional statement of an accused recorded in presence of a police officer cannot be admitted in evidence, except to the extent as provided under Section 27 of the Evidence Act and that too, when such disclosure leads to the discovery of incriminating fact/s. (Para 21) Extrajudicial confession has very weak evidentiary value and should be accepted with great care and caution. (Para 29) In cases based purely on circumstantial evidence, the onus lies upon the prosecution to prove the chain of incriminating circumstances beyond all manner of doubt- Referred to five golden principle Sharad Birdhichand Sarda v. State of Maharashtra. (Para 11)
Case Info
The case is
Case Name and Neutral Citation
- Case Name: Shanti Devi v. State of Haryana
- Neutral Citation: 2025 INSC 987
Coram (Judges)
- Coram: Manoj Misra, J. and Sandeep Mehta, J.
Judgment Date
- Date of Judgment: August 6, 2025
Caselaws and Citations Referred
- Sharad Birdhichand Sarda v. State of Maharashtra
- Citation: (1984) 4 SCC 116
- Principle: Five golden principles for cases based on circumstantial evidence.
- Shivaji Sahabrao Bobade v. State of Maharashtra
- Citation: (1973) 2 SCC 793
- Principle: Distinction between “may be proved” and “must be or should be proved”.
- Sahadevan v. State of Tamil Nadu
- Citation: (2012) 6 SCC 403
- Principle: Guiding principles for evidentiary value of extra-judicial confessions.
Statutes / Laws Referred
- Indian Penal Code, 1860 (IPC)
- Section 302 read with Section 34
- Section 201 read with Section 34
- Code of Criminal Procedure, 1973 (CrPC)
- Section 173(2)
- Indian Evidence Act, 1872
- Sections 25, 26, and 27 (regarding admissibility of confessions)
- Forensic Science Laboratory (FSL) Reports
- Reference to FSL, Madhuban and serological analysis
