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Supreme Court of India 2025-08-05 allowed

Narayan Yadav vs State of Chhattisgarh

Bench: 2 — J.B. Pardiwala, R. Mahadevan

In Brief

The appellant was convicted of murder (Section 302 IPC) by the trial court for killing a person following a quarrel at his residence. The High Court partly allowed the appeal, reducing the conviction to culpable homicide not amounting to murder (Section 304 Part I) invoking Exception 4 to Section 300 IPC. The Supreme Court reversed both judgments and acquitted the appellant. The Court held that: (1) the confessional FIR lodged by the appellant was inadmissible under Section 25 of the Indian Evidence Act; (2) expert medical evidence alone cannot sustain conviction in grave charges; (3) the appellant's conduct, while relevant, could not support conviction without corroborating evidence; and (4) Exception 4 could not apply as the deceased was unarmed and the assault was one-sided. Absent substantive evidence, the appellant was acquitted of all charges.

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Criminal Law Evidence Murder and Culpable Homicide Admissibility of Confessions Expert Evidence Exception 4 Section 300 IPC Section 27 Indian Evidence Act Circumstantial Evidence

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