Supreme Court Acquits Murder Convict: A Masterclass on Evidence Law


In a significant judgment, the Supreme Court of India recently overturned the conviction of Narayan Yadav, who had been sentenced for murder, and set him free. The decision in Narayan Yadav v. State of Chhattisgarh is not just a verdict on facts it’s a lesson in how criminal trials must respect the rules of evidence.

Case in Brief

Narayan Yadav was accused of killing his acquaintance, Ram Babu Sharma, after a drunken altercation allegedly triggered by an obscene remark about Yadav’s girlfriend. Yadav himself went to the police station and lodged the FIR, narrating in detail how the incident unfolded.

The trial court convicted him under Section 302 IPC (murder) and sentenced him to life imprisonment. The High Court reduced the conviction to Section 304 Part I IPC (culpable homicide not amounting to murder) by applying Exception 4 to Section 300 IPC. Yadav appealed to the Supreme Court.

The Supreme Court’s Key Findings

The apex court found several flaws in the High Court’s approach:

1. Confessional FIRs Are Inadmissible

The FIR Yadav lodged was essentially a confession. Under Section 25 of the Indian Evidence Act, 1872, any confession made to a police officer is inadmissible in evidence. The High Court erred by using the contents of the FIR to corroborate medical evidence.
Only limited parts of such a statement — like the fact that the accused made a report (Section 8) or information leading to a discovery (Section 27) — can be admitted.

2. Expert Evidence is Advisory, Not Conclusive

The court reminded that a doctor’s post-mortem opinion is advisory in nature. Conviction cannot rest solely on medical evidence without reliable corroborating material.

3. Section 27 & 8: Conduct and Discovery

For recovery evidence to be admissible under Section 27, the exact statement of the accused leading to the discovery must be proved. In this case, the prosecution failed to establish any valid discovery. Conduct under Section 8 can be relevant, but cannot be the sole basis for conviction.

4. Wrong Use of Exception 4 to Section 300

The High Court applied Exception 4 (sudden fight) without satisfying all its conditions. The Supreme Court clarified that:

  • There must be mutual combat.

  • The offender must not have taken undue advantage.

  • The manner of attack must not be cruel or unusual.
    Here, the deceased was unarmed, and the accused inflicted multiple indiscriminate injuries — negating the applicability of Exception 4.

The Outcome

Finding that there was no legally admissible evidence linking Yadav to the crime, the Supreme Court acquitted him entirely.

This ruling reinforces core principles:

  • Procedural safeguards are non-negotiable. Even a seemingly guilty person cannot be convicted on inadmissible evidence.

  • Courts must rigorously apply the Evidence Act.

  • Exceptions to murder require all conditions to be satisfied.

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