Extra-judicial confession lacks evidentiary value without relationship of confidence or independent corroboration.

The State appealed against the acquittal of the respondent, Jagdish Hirabhai Malam, who was charged under Section 302 of the IPC for the murder of his grandfather, Govabhai.

The prosecution alleged that on March 21, 1996, the accused strangulated and struck the deceased with a stone due to a property dispute regarding the non-allotment of a monetary share from sold land.

The case was primarily based on an extra-judicial confession allegedly made by the accused on November 23, 1996 (eight months after the death) to four witnesses during the funeral ceremony of the accused’s nephew.

The Trial Court acquitted the accused on January 1, 2000, finding the evidence insufficient.

1. Whether the findings of the Trial Court acquitting the accused were palpably wrong, manifestly erroneous, or demonstrably unsustainable.

2. Whether the extra-judicial confession allegedly made by the accused was voluntary, truthful, and inspired sufficient confidence to form the sole basis of conviction.

Section 378(1)(3) of the Cr.P.C. regarding appeals against acquittal, adhering to the principles in Rajesh Prasad v. State of Bihar and Chandrappa v. State of Karnataka, which mandate that an appellate court should not disturb an acquittal if two reasonable views are possible.

Section 302 of the IPC.

The evidentiary standards for extra-judicial confessions established in Sahadevan v. State of Tamil Nadu, which characterize such confessions as a "weak type of evidence" requiring independent corroboration and high credibility.

The High Court found that the prosecution's case rested entirely on circumstantial evidence and the alleged extra-judicial confession.

Upon reappreciating the testimony of PW3, PW4, and PW5, the Court observed that these witnesses had no relationship of intimacy or confidence with the accused, making it "inherently improbable" that he would confess three murders to them without reason.

The Court noted material omissions in the police statements and found the sequence of successive confessions at various locations to be "unnatural".

Furthermore, the medical evidence from PW1 was inconclusive, as the doctor admitted the cause of death could be unrelated to the alleged assault and noted an absence of typical signs of strangulation, such as lung congestion.

Consequently, the Court held that the Trial Court’s decision to discard the confession was a plausible and well-reasoned view.

The High Court upheld the Trial Court’s judgment, dismissed the State's appeal, and confirmed the acquittal of the respondent. The bail bond was cancelled and record proceedings were ordered to be returned.