FIR Lodged by Accused Containing Confession Cannot Be Used as Evidence: Supreme Court

The Supreme Court has clarified that when a first information report (FIR) is lodged by an accused individual and contains a confession, it cannot be admissible as evidence against that person during trial. The Court delivered this ruling while adjudicating an appeal filed by one Narayan Yadav, who had been convicted under Section 302 of the Indian Penal Code (IPC) by a trial court, and subsequently under Section 304 Part I by the Chhattisgarh High Court. The conviction was principally based on the contents of an FIR submitted by Yadav himself and the medical evidence from the post-mortem report.

The apex bench, led by Justices JB Pardiwala and R. Mahadevan, held that the FIR in question was confessional in nature and thus rendered inadmissible under Section 25 of the Evidence Act, which bars the use of confessions made to a police officer. The Court took issue with the earlier courts for relying on Yadav’s FIR, noting that such reliance was fundamentally flawed. It emphasized that the contents of such FIRs—when they include self-incriminating confessions—must be excluded, except to the narrow extent that they establish the time and maker of the statement as conduct evidence under Section 8 of the Evidence Act.

Moreover, the Court expressly disapproved of the Chhattisgarh High Court’s approach of corroborating medical evidence with the confessional part of the FIR. The Supreme Court underscored that medical testimony, while relevant, holds only advisory value and cannot serve as the sole basis for convicting an accused. Reliance on forensic findings must be supported by other admissible, credible evidence.

The judgment further explained that, beyond Section 8 conduct, only discrete factual discoveries revealed by the accused may be admissible under Section 27 of the Evidence Act—specifically, if they directly lead to the discovery of a material nature unknown to the investigating authorities. This narrow exception does not permit using the broader confessional content of an FIR as proof of guilt.

The Court held that dismissing the FIR’s inadmissible portions leaves the trial case lacking in independent foundation, particularly where convictions rest heavily on uncorroborated confession. In Yadav's case, the remaining medical evidence was insufficient to sustain the conviction in the absence of admissible supportive facts. This prompted the Court to overturn the conviction and direct reconsideration of the matter in light of the correct evidentiary framework.

This ruling reinforces the statutory prohibition on using police-recorded confessions and safeguards the principle that criminal convictions must be based on reliable, corroborated evidence. The decision makes clear that FIRs filed by accused individuals containing self-incriminating statements cannot serve as substantive proof of guilt. Only isolated conduct or fact disclosures meeting legal criteria may survive scrutiny, and convictions cannot be sustained solely on medical reports or inadmissible confession material.

The Supreme Court’s determination stands as a stern reminder of evidentiary limits and due process requirements in criminal trials, reaffirming that fundamental rights protect against coerced or self-recorded admissions made without judicial safeguards.