Trial Court Cannot Convict Accused Based on Confession Statement: Telangana HC

Hyderabad: The Telangana High Court ruled that trial courts cannot convict an accused based solely on police submissions, including confession statements, which are inadmissible. Emphasizing the importance of adhering to the five principles outlined in the Sharad Birdhichand Sarda vs State of Maharashtra case, the High Court criticized the conviction of Wadde Raju, who was sentenced to life imprisonment by a lower court for murder. The conviction was based on circumstantial evidence, including a confession and recovered items. The High Court found significant flaws in the investigation and extended the benefit of the doubt to Raju, ultimately overturning the conviction.

Key Points:

  1. High Court’s Directive: The Telangana High Court ruled that trial courts must not convict an accused based solely on moral grounds or on confession statements recorded by police, which are deemed inadmissible as evidence.
  2. Legal Guidelines: The court emphasized adherence to the five golden principles (panchsheel) from the case Sharad Birdhichand Sarda vs State of Maharashtra for proving cases based on circumstantial evidence. These principles provide a framework to ensure reliable and fair judgments.
  3. Case Background: The trial court had sentenced Wadde Raju to life imprisonment for the murder of Shanthamma, based on his confession statement and circumstantial evidence related to the theft of her silver jewelry.
  4. Investigation Issues: The investigating team labeled Raju as a serial killer and prepared his confession in the presence of panches. The police claimed to have recovered Shanthamma’s anklets from Raju 45 days after the initial investigation.
  5. Flaws in Evidence:
  6. The trial court’s conviction was based on a postmortem report, the confession statement, and the recovery of anklets from Raju.

  1. The High Court found significant errors in the investigation, including discrepancies in witness testimonies and the timeline of evidence recovery.
  2. Witness Testimonies:
  3. Shanthamma’s son was reported to have identified his mother’s body and ornaments on April 29, 2014.
  4. However, during cross-examination, the son testified that he learned of his mother’s death on May 7, 2014, in Hyderabad.
  5. Shanthamma’s daughter identified the ornaments only on September 20, 2014.
  1. Court’s Finding: The High Court concluded that the seizure of evidence was incorrect and likely fabricated, undermining the reliability of the investigation.
  2. Verdict: Given these investigative flaws, the High Court extended the benefit of the doubt to Raju and overturned the life imprisonment conviction, highlighting the need for proper and truthful evidence in securing a conviction.

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