Sahoo vs State of UP - Case Analysis

Introduction of Sahoo vs State of UP

The Supreme Court in Sahoo vs State of UP upheld the conviction of Sahoo stating that a confession need not be communicated to another person to be admissible under Section 17 of the Indian Evidence Act, 1872. Sahoo's muttering, which admitted guilt, was considered a confession. The Court also concluded that the circumstantial evidence, along with the extra-judicial confession, established a complete chain of events proving Sahoo's guilt. The decision clarified the admissibility of self-directed confessions and their role in supporting circumstantial evidence in criminal cases.

Historical Context and Facts of Sahoo vs State of UP

The case at hand, Sahoo, the appellant, resided in Pachperwa, Gonda District, and had two sons namely, Badri and Kirpa Shanker. The eldest son i.e., Badri was married to Sunderpatti and worked in Lucknow while his wife stayed with Sahoo. It was alleged that Sahoo and Sunderpatti had an illicit relationship though they frequently quarreled. 

The Incident

One day during one of their arguments Sunderpatti fled to the home of a neighbor, Mohammed Abdullah. Sahoo brought her back and after a heated exchange, they went to sleep in the only room of the house. The only other person present was Sahoo’s second son, KirpaShanker. 

Discovery and Testimony of the Witness

The next morning Kirpa Shanker found Sunderpatti seriously injured in the room where she had been sleeping but Sahoo was missing. Meanwhile the prosecution witness reported hearing Sahoo muttering “Finished Sunderpatti, finished the daily quarrels.” 

Admission to the Hospital

Sunderpatti was admitted to Sadar Hospital in Gonda that day and succumbed to her injuries after a few days. 

Legal Proceeding

Sahoo was subsequently charged with murder under Section 302 of the Indian Penal Code and put on trial in the Court of Sessions, Gonda.

Decision of the Trial Court

The Trial Court convicted Sahoo under Section 302 of the Indian Penal Code and sentenced him to death.

Decision of the High Court

The accused approached the High Court against the decision of the Trial Court. However, the High Court upheld the decision of the Trial Court.

Appeal in the Supreme Court

Aggrieved by the decision of the High Court, the Appellant approached the Supreme Court.

Issue addressed in Sahoo vs State of UP

The main questions which was addressed in this case were-

• Whether muttering by the accused amounts to confession under the Indian Evidence Act, 1872 and if so, is it admissible evidence under Section 17 of the Evidence Act?
• Is communication with another person necessary for an extra-judicial confession under Sections 24 to 30 of the Indian Evidence Act, 1872?

Legal Provisions involved in Sahoo vs State of UP

Section 17 of the Indian Evidence Act, 1872

Section 17 of the Act states that an admission is a statement, oral or documentary or contained in electronic form, which suggests any inference as to any fact in issue or relevant fact, and which is made by any of the persons, and under the circumstances, hereinafter mentioned.

Section 24 of the Indian Evidence Act, 1872

Section 24 of the Act provides that a confession made by an accused person is irrelevant in a criminal proceeding, if the making of the confession appears to the Court to have been caused by any inducement, threat or promise having reference to the charge against the accused person, proceeding from a person in authority and sufficient, in the opinion of the Court, to give the accused person grounds which would appear to him reasonable for supposing that by making it he would gain any advantage or avoid any evil of a temporal nature in reference to the proceedings against him.

Section 25 of the Indian Evidence Act, 1872

According to Section 25 of the Act no confession made to a police-officer shall be proved as against a person accused of any offence.

Section 26 of the Indian Evidence Act, 1872

Section 26 of the Act provides that no confession made by any person whilst he is in the custody of a police officer, unless it be made in the immediate presence of a Magistrate, shall be proved as against such person.

Section 27 of the Indian Evidence Act, 1872

Section 27 states that when any fact has been discovered in consequence of the information from a person accused of any offence, in the custody of a police officer, whether that information amounts to the confession or not, as relates directly to the facts thereby discovered, may be proved.

Section 28 of the Indian Evidence Act, 1872

Section 28 of the Act addresses the admissibility of confessions made after the removal of inducement, with the admissibility of the confession made after removing inducement, threat, or promise.

Section 29 of the Indian Evidence Act, 1872

Section 29 provides that any confession that is otherwise relevant does not become irrelevant because of the promise of secrecy, etc.

Section 30 of the Indian Evidence Act, 1872

Section 30 provides that When more persons than one are being tried jointly for the same offence, and a confession made by one of such persons affecting himself and some other of such persons is proved, the Court may take into consideration such confession as against such other person as well as against the person who makes such confession.

Section 302 of the Indian Penal Code, 1860

According to Section 302 of IPC whoever commits murder shall be punished with death or imprisonment for life and shall also be liable to fine.

Judgment and Impact of Sahoo vs State of UP

The Supreme Court upheld the conviction and sentence of Sahoo for the murder of Sunderpatti, based on circumstantial evidence and an extra-judicial confession. The oral statement of the Appellant where he was heard muttering about having “finished Sunderpatti” was admitted under Section 17 of the Indian Evidence Act, 1872. The Court ruled that a confession does not require communication to another person, mere muttering is sufficient. The Court illustrated that a statement, even if not communicated to others (e.g., written in a diary) can still be a confession if it admits guilt. Similarly, oral confessions like Sahoo’s muttering were admissible as evidence, provided they were proven through clear witness testimony.

The Supreme Court identified the following key circumstantial evidence:

• The illicit relationship between Sahoo and Sunderpatti.
• Their quarrel the night before her death.
• Sunderpatti being last seen with Sahoo.
• Sahoo’s second son, Kirpa Shanker, witnesses Sahoo leave the house after hearing a gurgling sound.
• Witnesses hear Sahoo muttering about finishing Sunderpatti.

The Court concluded that the chain of circumstantial evidence was complete leading to the conviction.

Conclusion

The Supreme Court upheld Sahoo’s conviction and sentence, emphasising that a confession need not be communicated to another person to be admissible as evidence. The Court ruled that mere muttering, if it sufficiently admits guilt, can constitute a valid confession under Section 17 of the Indian Evidence Act, 1872. The circumstantial evidence, combined with the extra-judicial confession, created a complete chain of events that led to the conclusion of Sahoo’s guilt. This decision clarified the legal standing of self-directed confessions and their role in corroborating circumstantial evidence in criminal trials.