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Supreme Court of India 2020-10-29

TOFAN SINGH vs STATE OF TAMIL NADU

Bench: 2 — R. F. Nariman, Navin Sinha

In Brief

In this major judgment on narcotic drug trafficking investigations, the Supreme Court examined whether officers designated under Section 53 of the NDPS Act qualify as "police officers" under Section 25 of the Indian Evidence Act, thus rendering confessions made to them inadmissible. By a 2:1 majority, the Court held that such designated officers are indeed "police officers" for purposes of Section 25, so any confessional statement made to them is barred from evidence. The Court also clarified that statements recorded under Section 67 of the NDPS Act cannot be used as substantive confessional evidence to convict an accused. The decision overruled Raj Kumar Karwal and Kanhaiyalal, reaffirming constitutional protections against self-incrimination in the NDPS framework.

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NDPS Act Narcotic Drugs Confessional Statements Police Officers Evidence Article 20(3) Self-Incrimination Investigation Fundamental Rights Criminal Procedure Constitutional Law Admissibility of Evidence Interrogation Safeguards Drug Trafficking

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