HAMDARD INSTITUTE OF LEGAL STUDIES AND RESEARCH,

SCHOOL OF LAW, JAMIA HAMDARD

“Admission and Confession: A Comparative Study under the Indian Evidence

Act”

SUBMITTED TO-
ADVOCATE R.H.A SIKANDAR
GUEST FACULTY (LAW)

SUBMITTED BY-
Name- Muzakkir
Sec- B
Enrollment No. - 2020-342-074
8 Semester, B.A.LL.B
th

EVIDENCE LAW-I
ASSIGNMENT SUBMISSION
 Contents

1. Table of cases……………....…………3

2. Abstract…...............................................4

3. Introduction...........................................4

4. Meaning of Confession...............……...8

5. Meaning of Admission…………............9

6. Difference between Confession and Admission…..11

7. Types of Confession………………...12

8. When Confession is Irrelevant.............................14

9. Conclusion……………...………….16

10. Reference………………..…………17
 Table of cases

● Satrucharla Vijaya Rama Raju v. Nimmaka Jaya Raju (2006) 1 SCC 212

● Bharat Singh v. Bhagirath AIR 1966 SC 405

● State of Punjab v. Bhagwan Singh 1952 AIR 214

● Balwinder Singh v. State 1996 AIR 607

● Pyare Lal v. State of Rajasthan 1963 AIR 1094

● Pakala Narayan Swamy Vs. The King (1939) 66IA 66

● Palvinder Kaur V. Province of Punjab AIR 1952 SC 354

● Nishi Kant Jha v Territory of Bihar AIR 1969 SC 422

● Rakesh Waddhawan Vs. Jagadamba Industrial Corporation AIR 2002 SC 2004

● Pakala Narayana Swami Vs. King Emperor (1939) 66IA 66

● Modi Ganga Vs. State AIR 1981 SC 1165

● Pyare Lal Vs. State of Rajasthan AIR 1963 SC 1094

● Jagta v State of Haryana AIR 1974 SC 1545

● Union of India Vs. J.S. Brar AIR 1978 SC 1248

● Shankara Vs. State AIR 1993 SC 773

● Abdul Ghani Vs. State AIR 1973 SC 264

● Pancho v. Province of Haryana AIR (2011) 10 SC 165

● Md. Inatulla Vs. The state AIR 1976 SC 83

● Ramesh Chandra Vs. Babulal 2014 AIR 509 F.B

● Muthu Kumar Swami Vs. R 1935 M 397, 456

Abstract

The Indian Evidence Act does not define the word Confession, but Confession is a statement
made by an accused person who is associated with a crime, which infers that they committed
a crime. The Act does not differentiate between the Admission and the Confession, but there
is a fragile line difference between Admission and Confession. Confessions are upgrades of
Admission, making them unique. Admission can be judicial or extrajudicial, with judicial
Admission admitted at the time of the judicial trial and extrajudicial Admission of facts
made during normal day-to-day activities. Judicial admissions or extra judicial admissions
are entirely admissible by the court of law under Section 58 and have much higher probative
value into substantive any fused against or go against the confessor of the statements, with
exceptions to Section 21 of the Indian Evidence Act.

Confessions can be of different types depending on the nature of the case. Judicial
confessions are made on or before a magistrate or court of law during criminal proceedings,
while extrajudicial confessions are made at any place other than the court. The court must
examine the confessions efficiently and ensure they are valid and supported by other
evidence. Retracted confessions can be used against the person confessing if supported by
independent and corroborative evidence. The Indian Evidence Act of 1872 deals with only
the conditions when a confession can be irrelevant. Section 24 states that a confession made
by a person accused of some offence is irrelevant if it comes out of inducement, threat, or
promise and has occurred from a person in authority, such as a magistrate or court. Section
26 prohibits judicial bodies from proving the guilt of the accused by their Confession.
Section 27 lifts the ban on admitting confessions made to police officers in police custody,
aiming to help in further discovery of facts and prove other relevant facts.

1. Introduction
The Indian Evidence Act defines "confession" as any statement made by an accused person
charged with a crime, suggesting or suggesting the inference that they committed a crime.
The term "confession" is not defined or expressed in the Indian Evidence Act, but the
inference explained under the definition of Admission in Section 17 applies to Confession in
the same manner. Confessions are statements made by the person charged with criminal
offences, suggesting a conclusion to any fact in issue or relevant facts. They may infer any
reasoning for concluding or suggesting that the accused is guilty of a crime. The Indian
Evidence Act also has a thin line difference between Admission and Confession, as
Admission only ends up in Admission of guilt by the accused. Confessions are upgrades of
Admission, making them memorable. The court should begin ascertaining the case facts with
all other evidence related to the case before turning to the approach of Confession by the
accused to administer complete justice to the conclusion of guilt.

An admission is a statement which suggests some inference as to the existence of a fact in

issue or a relevant fact. An admission is a voluntary acknowledgement about the existence of
certain facts. It is a statement of fact which waives or dispenses with the production of
evidence by conceding that the fact asserted by the opponent is true. Admission plays a vital
part in judicial proceedings; if either party proves that the other party has admitted the fact in
issue or relevant facts, it becomes easy for the court to administer justice effectively. Section
17 to 23 of the Indian Evidence Act deals explicitly with the portions related to Admission."
Admission can be judicial or extrajudicial, with judicial Admission made at the time of the
judicial proceeding and extrajudicial Admission made during normal day-to-day activities.
Judicial Admission or judicial admissions are completely admissible by the court of law
under Section 58 of the same Act and have much higher probative value in substantiating any
fact".

The Indian Evidence Act has lifted the concept of Admission and Confession, explaining that
discretionary and undeviating cognizance of guilt is Confession, and the Confession made by
the accused may be used as a piece of damaging evidence against him. However, admissions
acknowledged by the person who admitted the fact may not be considered conclusive proof
of facts admitted, and the admitted matter or facts can only be considered as substantive or
probative evidence of Admission. Confession is a statement made by a person charged with
criminal offences, which can infer any reason for concluding or suggesting guilt of a crime. It
is made by the person who is charged with the crime and may infer any reason for concluding
or suggesting that he is guilty of a crime. The concept of Confession usually deals with
criminal proceedings, with no specific section defining it.

"Confessions can be used or go against the confessor of the statements, with exceptions to
ection 21 lays down the principle as to proof of admissions. This Section is based upon the
principle that an admission is evidence against the party who had made the admission and
therefore, it can be proved against him. He himself cannot prove his own statements
otherwise, if he were in a difficulty, he might make declarations to suit his own case and then
lodge them in proof of his case.

The general rule is that the statements of a living person cannot be received unless they are
against his interests. No man should be at liberty to make evidence for himself through his
own statements. Granted this facility, every litigant would construct a favorable case by his
own statements. Thus, self-favoring admissions are not permissible. The Evidence Act does
not require that an admission should be a self-harming statement; the definition under Section
17 also includes self-serving statements, though a party can prove self-serving statements
only under the exceptions laid down in Section 21.

Satrucharla Vijaya Rama Raju v. Nimmaka Jaya Raju1 When a person's self-serving
statement subsequently becomes adverse to his interest, it may be proved against him as an
admission.
Though in a prior statement, an assertion in one's own interest may not be evidence, a prior
statement adverse to one's interest would be evidence. Indeed, it would be the best evidence.

Bharat Singh v. Bhagirath2 Admissions are substantive evidence of the fact admitted though
they are not conclusive proof of the matters admitted. Admissions duly proved are admissible
evidence irrespective of whether the party making them appears in the witness box or not and
whether that party when appearing as a witness was confronted with those statements in case
he made a statement contrary to his admissions.

Judicial confessions are made before a magistrate or court during criminal proceedings, while
extrajudicial confessions are made at any place other than the court. The court must take care
to check if the Confession made by the accused is voluntary and authentic so that no innocent
person can be charged for wrongful acts of others, as provided in Article 20(3) of the Indian
Constitution. Extrajudicial confessions, also known as extrajudicial confessions, are made at
any place other than the court and can be made in the form of prayer or in a private room or
self-conversation. Both judicial and extrajudicial confessions can be accepted in the court but
have different evidentiary values or probative values to establish any fact. A conviction will

1
(2006) 1 SCC 212
2
AIR 1966 SC 405
not solely be based on the Confession, but the court will test the extrajudicial Confession to
make any person guilty of any offence committed by them.

In "State of Punjab v. Bhagwan Singh, The Supreme Court held that an extrajudicial
confession's value only increases when it is clearly consistent and convincing to the
conclusion of the case; otherwise, the accused cannot be held liable for the conviction solely
on the basis of the confession made by them"3. In "Balwinder Singh v. State, the Supreme
Court emphasised the importance of credibility in determining the credibility of a confession.
The court must examine the confessions efficiently and ensure that they are true and
supported by other evidence. Retracted confessions, which are voluntarily made by the
confessor but later revoked or retracted, can be used against the person confessing if they are
supported by independent and corroborative evidence"4.

In "Pyare Lal v. State of Rajasthan, the Supreme Court lifted the requirement that a retracted
confession has enough value to form any other legal grounds to establish a conviction only if
the court satisfies that it was true and was on someone's own will. In Pancho v. State of
Haryana, the court held that confessions made by co-accused do not have much evidentiary
value and can only be used to corroborate the conclusion drawn out by other probative
evidence"5.

The "Indian Evidence Act 1872 deals with the conditions when a confession can be
irrelevant. Section 24 of the Act states that a confession made by a person accused of some
offence is irrelevant if it comes out of inducement, threat, or promise and has occurred from a
person in authority, such as a magistrate or court. The Confession must be out of inducement,
threat, or promise, relate to the charge in question, and have the benefit of temporal nature or
disadvantage"6.

"Confessions made to police officers are not admissible as evidence in a court of law against
the accused to prove their guilt. Section 26 prohibits judicial bodies from proving the guilt of
the accused by their Confession. Section 27 of the Indian Evidence Act lifts the ban on
admitting confessions made to police officers in police custody. The Act allows for the

3
1952 AIR 214
4
1996 AIR 607
5
1963 AIR 1094
6
Indian Evidence Act 1872
Admission of statements made by an accused, even to police officers, aiming to help in
further discovery of facts and prove other relevant facts. This provision allows for the
Admission of confessions made to police officers in police custody, even if recorded in the
immediate presence of a magistrate. The Supreme Court explained that this Confession may
help in further discovery of facts and help the court prove other relevant facts"7.

Meaning of Confession
As per Sir James Stephen, "As an admission made at the time by a person charged with the
crime stating or suggesting the inference that he committed a crime"8.
However, Confession is not defined in the Indian Evidence Act, but it is defined and
explained by the various jurists and the author. "Section 17 defines the term admission. An
admission is a statement oral or documentary or contained in electronic form which suggests
an inference to any fact in issue or relevant fact, which is made by any of the persons and
under the circumstances hereinafter mentioned".

Presently, in the wake of understanding the revelation of both the terms (Admission and
Confession), it is clear that both include the facts of the case. Admission includes the relevant
facts, which is permissible by the court, but the Confession. It is not necessary that every fact
is admissible in the case in which facts are admitted in the case when the facts themselves
are admitted by the accused or the offender who is directly or indirectly involved in the case
that admitted facts is known as Confession. Subsequently, the Confession is facts which are
made by an individual who is accused of any criminal offences and such proclamations
presented by him will recommend an end regarding any reality in issue or as to essential
realities. The assertions might induce any thinking for closing or recommending that he is at
legitimate fault for wrongdoing. We may likewise characterize the Confession all in all as the
admitted facts by the accused in the criminal procedures.

Case laws
In Pakala Narayan Swamy Vs. The King Emperor Lord Atkin said, "A Confession must
either admit in terms the offence or at any rate substantially all the facts which constitute the

7
Indian Evidence Act 1872
8
legalserviceindia.com-article-138-admissions-and-confessions-under-indian-evidence-act-1872 8 Indian
Evidence Act 1872
offence. An admission of a gravely incriminating fact, even a conclusively incriminating fact,
is not of itself a confession"9.

In "Palvinder Kaur V. Province of Punjab, the Supreme Court of India uplifted the decision
taken by the privy council in the Pakala Narayan Swami case on the basis of two reasons.
Firstly, the statement made by the person confirming that he is guilty of any offence or
Admission made by him indicating all the facts which constitute the offence is considered a
confession. Secondly, when the statement made by any person is sufficient for acquittal of the
person from his statement, then these statements cannot come under the ambit of the
confession"10.

In "Nishi Kant Jha v Territory of Bihar, the Supreme Court focuses on relying on the
statement confessed by the accused before or during the trial or neglects some parts of the
admitted facts or denies the statement which is made by himself, then the court will focus on
the inculpatory part of the statement, i.e. confession"11.

Meaning of Admission
Definition of Admission: - Famous Scholars Stephen, Wills, etc., have defined the term
admission in their own way. However, these definitions are insignificant in the context of
courts in India because the Indian Evidence Act expressly defined the term admission in
section 17. Therefore, in India, the term admission is governed by the definition given in
Section 17 and not by the definition of the various Scholars.
According to "Section 17 of the Indian Evidence Act, the definition of admission is: - An
Admission is a statement, oral or documentary or contained in electronic form which suggests
any inference as to any fact in issue or relevant fact, and which is made by any of the persons,
and under the circumstances hereinafter mentioned"12. In other words, an admission is a
statement that is made by the victim or accused in the form of oral, documentary and
electronic form. Which inference regarding facts-in-issue or relevant fact and the statement
has been made by any of the persons given in sections 18, 19 and 20 and made in the
circumstances given in sections 21 to 23.

9
9 (1939) 66IA 66
10
AIR 1952 SC 354
11
11 AIR 1969 SC 422
12
Indian Evidence Act 1872
In Rakesh Waddhawan Vs. Jagadamba Industrial Corporation, "Admission is only a piece of
evidence and can be explained. It does not conclusively bind a party unless it amounts to an
estoppel. The value of an admission has to be determined by keeping in view the
circumstances in which it was made and to whom. A mere failure to object cannot be placed
on a footing higher than an admission"13.

Persons Whose Admissions Are Relevant

● A party to the suit or proceeding (Section 18)
● An agent authorised by such party (Section 18)
● A party suing or sued in a representative character making admissions while holding
such character (e g trustees, executors, etc ) (Section 18)
● A person who has a proprietary/pecuniary interest in the subject matter of suit during
the continuance of such interest. (Section 18)
● A person from whom the parties to suit have derived their interest in the subject
matter of suit during the continuance of such interest (Section 18)
● A person whose position it is necessary to prove in a suit, if such statement would be
relevant in a suit brought by or against himself (Section 19)
● A person to whom a party to suit has expressly referred for information in reference to
a matter in dispute (Section 20)

Evidentiary Value Of Admissions

An admission does not constitute a conclusive proof of the facts admitted (Section 31). It is
only a prima facie proof. Thus, evidence can be given to disprove it. The admissions thus,
may constitute a weak kind of evidence. The person against whom an admission is proved is
at liberty to show that it was mistaken or untrue. But until such evidence is given, an
admission can safely be presumed to be true and can be received as substantive evidence.
Admissions constitute an exception to the hearsay rule. Admissions may operate as estoppels
under Section 31.

13
13 AIR 2002 SC 2004
Silence as admission:
Silence may amount to admission as if there is no reply or denial. A party may admit the truth
of the matter.
Example:
In Bessela v Stern the girl said to the boy “you always promised to marry me and you did not
keep your words.” The boy did not deny the allegation, but he offered her some money. The
boy’s silence as to promise was held to be admission.

Difference between Confession and Admission

Admission and Confession are correlated to each other, but both are different in two senses.
Admission is defined in the I.E. Act, but Confession is used only on the basis of the
interpretation of the courts in the cases.

1. A confession is a statement made by an accused person that is sought to be proved

against him in criminal proceedings to establish the commission of an offence by him,
whereas Admission is a statement of a person that suggests the inference regarding any
fact-in-issue or relevant facts in both civil and criminal cases.
2. Confession always goes against the person making it, while Admission may be used
on behalf of the person making it under the exceptions provided in section 21.
3. "Confession has been defined nowhere in the Indian Evidence Act. It was defined by
the privy council in the case of Pakala Narayana Swami Vs. King Emperor, whereas
Admission has been defined in section 17"14.
4. "Confession, if deliberately and voluntarily made, may be accepted as conclusive of
the matters confessed. Admission is not conclusive as to the matters admitted; it may operate
as an estoppel (Section 31)"15.
5. Confession is Admission in criminal cases only, but Admission is admissible in both
criminal as well as in civil cases.

In CBI v V .C. Shukla the Supreme Court has pointed out the difference between an
admission and a confession. “Only voluntary and direct acknowledgement of guilt is a
confession, but, if it falls short of actual admission of guilt, it may be used as evidence
against the person who made it or his authorized agent, as an admission under section 21.”
Admissions so made may not be taken as conclusive proof of matter admitted but are to be
accepted as substantive evidence of fact admitted.

14
(1939) 66IA 66
15
Indian Evidence Act 1872
Types of Confession
A confession is not defined in the Indian Evidence Act 1872 but is interpreted by the
Supreme Court with the help of various court decisions in the Indian legal system. There are
different kinds of Confession, but the courts differentiate the different kinds of Confession on
the basis of the style of the recording of the accused statement in the court or outside of the
court. The statement which is recorded by the magistrate is called judicial Confession, and
statements recorded outside the court are called extra judicial Confession and so on.

Judicial Confession
Judicial Confession is a confession that is made before a magistrate or court during judicial
proceedings is known as judicial judicial Confession.
Evidentiary Value: -
A judicial confession is a substantive piece of evidence, and an accused may be convicted
only on such evidence if the court is convinced that the Confession is true and voluntary. For
Example- A confession made to a Magistrate made to a magistrate order Section-16416. In
"Modi Ganga Vs. State The supreme court held that the confessional statement, when
recorded in accordance with sections 164 and 364, Cr.P.Code, can be admitted in evidence
without the magistrate recording such statement being examined"17.

Extrajudicial Confession
A confession that is not judicial is known as extrajudicial Confession. For example-
Confessions made by father, teacher, friend etc.
Evidentiary value:-
"There is no legal bar to convict the accused only on the basis of extrajudicial Confession, but
a supreme court in Pyare Lal Vs. State of Rajasthan Held that the rule of court requires that
an accused should not be convicted on the basis of Extra Judicial confession unless it is
corroborated, especially in serious cases like murder and culpable homicide."18 That is why
"Supreme Court Jagta v State of Haryana held that extrajudicial confession is a fragile type of
evidence"19.

16
Criminal Procedure Code 1973
17
AIR 1981 SC 1165
18
AIR 1963 SC 1094
19
AIR 1974 SC 1545
Lord Macaulay also remarks "that a person should not be convicted on the basis of such
confession because generally such a type of confession is made verbally and even an honest
man may misunderstand the words altered to him.

The distinction between the Judicial Confession and Extra Confession

1. "A Judicial confession is made before a magistrate or court, whereas an Extra Judicial
confession is made to any person other than a magistrate or court.
2. A Judicial confession is made during judicial proceedings, but it is not so in the case
of Extra judicial Confession.
3. An Extra judicial confession is weaker evidence than a judicial confession, and it
requires corroboration in order to base a conviction on it".

Retracted Confession
The English importance of withdrawal is the activity of stepping back from something.
Confession is a sort of Confession that is intentionally made by the questioner; however,
subsequently, it is denied or retracted by a similar inquisitor. A retracted Confession can be
used against the individual who is admitting a few withdrawn explanations in the event that it
is validated by another free and demonstrative proof.

In "Abdul Ghani Vs. State The supreme court held that when the accused did not make a
confession which has been already made earlier, i.e. the accused back out his/her earlier
statement made by him/her, it amounts to retraction of Confession already made"20.
In "Shankara Vs. State The supreme court held that retracted Confession may form the basis
for conviction without corroboration if it is found to be perfectly voluntary and if so is further
found to be true and trustworthy"21.

In the "Union of India Vs. J.S. Brar In This case, the Supreme Court overruled the earlier
judgement"22. "Shankara Vs. State and held that the retracted Confession without independent
corroboration cannot sustain a conviction"23.

Confession by co-accused:

20
AIR 1973 SC 264
21
AIR 1978 SC 1248
22
AIR 1993 SC 773
23
AIR 1978 SC 1248
When the number of accused is more than one, and the nature of offences indicates that one
or more than one accused is involved in the crime, the statement made by one of them is
relevant to each other. So, the admitted facts by the co-accused by one of them are binding
for all accused in the same offence, not for the other offence.

The High Court, on account of "Pancho v. Province of Haryana, held that the Confessions
made by the co-accused do not have much evidentiary worth and cannot be considered a
meaningful piece of proof. In this way, the Confession made by the co-accused must be
utilized to substantiate the end excessively long by other probative proof".24

For example, assume three people, Rahul, Sami and Guddu, are accused together of similar
offences, and they are arraigned for the homicide of Cruel. Furthermore, during the legal
procedures, Rahul admitted that he, Sami and Guddu murdered, and on the off chance that his
explanations of the Rahul are perceived as obvious articulations, the court might utilize the
Confession of Rahul against all the accused and can be the ground of the conviction for all
three accused. The Confession made by Rahul is also used as the Confession made by Sami
and Guddu. Furthermore, it is the basis of the convictions.

When Confession is Irrelevant

Sections 24, 25, 26 and 27 of the Indian Evidence Act 1872 are irrelevant in the general
sense, but they may be relevant after the corroborating evidence is produced in the court.

Section 24: - "Section 24 of the Indian Evidence Act 1872 provides that when an accused
makes the confession as a result of the Inducement, threat or promise given by a person in
authority, such a confession would not be relevant in any criminal proceeding if the
inducement, threat or promise is of temporal nature and related to the allegation levelled
against the accused"25.

It is notable that the term person in authority used in "section 24 has not been defined by the
Indian Evidence Act. But in the famous case of Santokhi Beldar Vs. R The Patne High held
that a person in authority means some are engaged in the arrest, detention, examination or
prosecution of the accused or by someone acting in the presence and without the dissent of

24
AIR (2011) 10 SC 165
25
Indian Evidence Act 1872
such a person"26. Section 25: - "Section 25 of the Indian Evidence Act 1872 declares that "No
Confession made to a police officer shall be proved as against a person accused of any
offence".
In other words, it can be said that a confession made by an accused to a police officer is not
relevant as such not admissible in evidence against the accused"27.

Section 26:- "It is notable that section 26 is nothing but the extension of section 25
(Confession made to the police officer is irrelevant). Section 25 applies to all confessions
made to police officers, whereas section 26 applies to Confession to whosoever made (other
than police officers) by a person while in police custody Ramesh Chandra Vs. Babulal28 and
Muthu Kumar Swami Vs. R"29.

"Section 26 lays down that confession made to any person when the maker of confession is
in police custody cannot be proved against him unless it is made in the immediate presence of
a magistrate"30. It is notable that section 26 is in two parts; the first part of the section is
known as the general rule, whereas the second part of the section is known as the exception to
the general rule. The first part of the section makes all the confessions irrelevant if they are
made when the accused is in the custody of the police. However, according to the second part
of the section, such confessions are relevant if they are made in the immediate presence of the
magistrate, though the accused is in police custody.

Section 27: - "Section 27 Provides that when an accused gives some information during
police custody and as a result of such information, a fact is discovered that part of the
information which is directly related to the discovery of a fact is relevant, whether
information amounts to confession or not the facts discovered would be relevant even if the
information is in the nature of confession"31.

In fact, "section 27 is an exception to section 25 and section 26. That is why the Supreme
Court also in Delhi Administration Vs. Bal Krishna and in Md. Inatulla Vs. The state32 made

26
AIR 1933 Pat 149
27
Indian Evidence Act 1872
28
2014 AIR 509 F.B
29
1935 M 397, 456
30
Indian Evidence Act 1872
31
Indian Evidence Act 1872
32
AIR 1976 SC 83
the scope of section 27 clear and held that section 27 is by way of a proviso (the exception to
sections 25 and 26), and a statement even by way of Confession made in police custody
which distinctly relates to the fact discovered is admissible in evidence against the
accused"33.

Conditions for the application of "section 27, in order to apply section 27, the following
conditions must be satisfied: -
a. The person giving the information must be an accused.
b. The accused must be in the custody of the police.
c. The statement of the accused (Whether Confession or not) must be distinctly related
to the discovery of a fact"34.

Conclusion
There are several major differences between Confession And Admission, but a major point of
easy distinction is that confession is a direct statement that does not require evidence for it to
be backed up. It is the responsibility of the court to determine the validity of a confession in
light of the facts and circumstances of each case. On the other hand, an admission requires
evidence for it to support conviction of any kind, usually on the part of the opposite party. In
simpler words, where an accused makes a confession, the prosecution does not have any
further duty of proving the guilt of the accused, but where a person makes an admission, the
opposite party needs to provide evidence against the admission to prove it wrong. Even
though the law is pretty clear on confessions and admissions, overlaps are bound to happen
because of the variety of cases that come before the courts. This leaves it to the courts to
deliver judgments that can be used to further clarify the position, whether of confessions or
admissions.

References
Internet /Web Resources–
Live Law
SCC
YLCC
Law Trend

33
AIR 1976 SC 83
34
Indian Evidence Act 1872
Lawfaculty.in
Law Corner.in

Offline Material/Books Referred:

1. Indian Evidence Act, 1872 (Relevant Statutory Provisions)
2. Lecture Notes
3. Monir: Law of Evidence
4. Batuk Lal: Law of Evidence
5. Ratan Lal & Dhiraj Lal: Law of Evidence
6. Avtar Singh: Principles of Law of Evidence