Confessional FIRs & Evidentiary Boundaries:
Narayan Yadav v. State of Chhattisgarh (2025 INSC 927)

1. Introduction

The judgment delivered on 5 August 2025 by the Supreme Court of India in Narayan Yadav v. State of Chhattisgarh sets a critical precedent on the evidentiary value of First Information Reports (FIRs) that contain confessions by an accused, the limited probative force of expert testimony in criminal trials, and the proper application of Exception 4 to Section 300 of the Indian Penal Code (IPC).

Narayan Yadav, a milk supplier, was initially convicted of murder under Section 302 IPC by the Sessions Court for killing Ram Babu Sharma. The Chhattisgarh High Court later altered the conviction to culpable homicide not amounting to murder (Section 304 Part I IPC) by invoking Exception 4 to Section 300. Dissatisfied, the accused appealed.

The Supreme Court, speaking through Pardiwala J. (Mahadevan J. concurring), acquitted the appellant entirely, chastising the High Court for relying on (i) a confessional FIR, (ii) un-corroborated medical evidence, and (iii) an incorrect understanding of the statutory exceptions to murder.

2. Summary of the Judgment

1. Confessional FIR Inadmissible: An FIR lodged by an accused that also contains a confession is hit by Section 25 of the Evidence Act and cannot be read as substantive evidence. Only those parts leading to discovery (Section 27) or evidencing conduct (Sec. 8) survive.
2. Expert Testimony Is Advisory: Medical opinions, though relevant, cannot by themselves prove the commission of an offence; they merely guide the court’s assessment of other substantive evidence.
3. No Independent Evidence: With the FIR excluded and panch witnesses hostile, there remained no legally admissible link between the accused and the homicide.
4. Misuse of Exception 4: Even if the prosecution had otherwise proved the assault, the High Court erred in invoking Exception 4 without evaluating whether the accused took “undue advantage” or acted “in a cruel or unusual manner.”
5. Acquittal: In the absence of admissible incriminating evidence, the Court allowed the appeal and acquitted Narayan Yadav.

3. Detailed Analysis

3.1 Precedents Cited & Their Influence

• Nisar Ali v. State of U.P. (1957): Reaffirmed that an FIR is not substantive evidence and cannot be used against its maker if he becomes an accused.
• Faddi v. State Of M.P. (1964): Clarified that a non-confessional statement in an FIR may be admissible as an admission, but a confessional FIR is barred.
• Aghnoo Nagesia v. State of Bihar (1965): Laid down that if a statement is partly confessional and partly exculpatory, and the two cannot be severed, the whole statement is inadmissible.
• Murli v. State of Rajasthan (2009): Emphasised that contents of a panchnama are not substantive evidence; only testimony of panchas is.
• A.N. Venkatesh v. State of Karnataka (2005): Accused’s conduct may be relevant under Section 8 but cannot by itself sustain conviction.
• Classic murder–culpable‐homicide divide cases: Rayavarapu Punnayya (1976), Kikar Singh (1993), Budhi Singh (2012), and Surain Singh (2017), employed to expose the High Court’s misapplication of Exception 4.

3.2 Court’s Legal Reasoning

1. Exclusion of Confessional FIR (Paras 16-26):
   • Section 25 Evidence Act renders any confession to a police officer inadmissible.
   • Since the FIR was a self-inculpatory statement, its substantive use was barred.
   • The High Court erred by directly corroborating medical evidence with this inadmissible confession.
2. Weakness of Medical/Expert Evidence (Paras 27-29):
   • Post-mortem merely established homicidal nature of death but not authorship.
   • Expert opinion, being advisory, cannot on its own connect the accused to the act.
3. Failure of Section 27 & Section 8 Bridges (Paras 30-36):
   • No witness reproduced the exact discovery statement as mandated by Section 27.
   • Conduct of pointing out the body or producing clothes, without proved discovery or blood-group match, was insufficient.
4. Exception 4 to Section 300 Misconceived (Paras 37-50):
   • Four cumulative conditions for Exception 4 were not satisfied.
   • Even on prosecution’s version, the accused employed a knife on an unarmed victim—“undue advantage” and “cruel manner” exclusions applied.
5. Result: Without any admissible substantive evidence, the presumption of innocence remained unrebutted; acquittal followed.

3.3 Impact of the Decision

• Investigative Practices: Police must secure independent evidence—eyewitnesses, forensic links, proper discovery memos—rather than rely on an accused’s FIR.
• Prosecution Strategy: Greater emphasis must be placed on proving discovery under Section 27 with verbatim statements and competent witnesses.
• Judicial Approach: Courts are reminded to scrutinise the admissibility of every piece of evidence before considering its corroborative value.
• Forensic Evidence: Medical or scientific opinion remains valuable but cannot substitute for proof of the accused’s participation.
• Doctrinal Clarity: The judgment offers a structured three-stage test (para 43) for distinguishing murder from culpable homicide and sharpens the contours of Exception 4.

4. Complex Concepts Simplified

4.1 Confessional FIR

An FIR that admits or implies guilt is “confessional.” Under Section 25 Evidence Act, any confession to a police officer is inadmissible in court. It may still (i) prove the fact that an accused reached the station (conduct), or (ii) be admissible in part if it directly leads to discovery (Sec. 27). Otherwise, courts must ignore its contents.

4.2 Section 27 Discovery Rule

Only “so much of the information” that distinctly relates to a fact discovered in consequence of the accused’s statement is admissible. The exact words must be proved through testimony. Absence of that verbatim statement or lack of a genuine discovery renders Section 27 inapplicable.

4.3 Expert Evidence

Doctors, forensic analysts, handwriting experts, etc., provide opinions to help the court. Their testimony is advisory; the judge must independently evaluate whether the remaining evidence establishes the offence.

4.4 Exception 4 to Section 300 IPC

A homicide is not murder if it is committed (a) without premeditation, (b) in a sudden fight, (c) in the heat of passion, (d) without the offender taking undue advantage or acting cruelly. All four conditions must co-exist.

4.5 Murder vs. Culpable Homicide Not Amounting to Murder

• Murder (Section 300): Intent to kill or cause injury “sufficient in the ordinary course of nature to cause death,” or knowledge that the act is so imminently dangerous that it must, in all probability, cause death.
• Culpable Homicide (Section 299): Causing death with intention or knowledge but falling short of the special characteristics of murder. Punishment is then under Section 304 (Part I for intention, Part II for knowledge alone).

5. Conclusion

The Supreme Court’s decision in Narayan Yadav v. State of Chhattisgarh fortifies three doctrinal pillars of Indian criminal jurisprudence:

1. Confessional FIRs are inadmissible against their maker, save for limited exceptions under Sections 8 and 27 of the Evidence Act.
2. Expert evidence, though significant, cannot single-handedly secure a conviction.
3. Exception 4 to Section 300 demands strict compliance with all its conjunctive requirements, and courts must beware of granting its shelter casually.

By acquitting the appellant, the Court underscored that procedural safeguards on admissibility are not mere technicalities but bulwarks of a fair trial. Investigators and lower courts are now on explicit notice: a conviction cannot be built on inadmissible confessions and un-corroborated expert opinion.