The Legal Issue
The Supreme Court in *Tejaram v. State of Rajasthan*, 2026 LiveLaw (SC) 1070, addressed a critical aspect of criminal jurisprudence concerning the evidentiary value of statements made by an accused under Section 313 of the Code of Criminal Procedure, 1973 (CrPC). This section, now Section 342 of the Bharatiya Nagarik Suraksha Sanhita, 2023 (BNSS), mandates that the court question the accused about the circumstances appearing in the evidence against them. The core legal question was whether a conviction could be based solely on an inculpatory statement made by the accused during such examination, or if it merely serves as an aid to evaluate the prosecution's case.
Court's Reasoning
The Supreme Court unequivocally held that a statement recorded under Section 313 CrPC (or Section 342 BNSS) cannot form the sole basis for a conviction. The Court reiterated that the purpose of this examination is to enable the accused to explain any incriminating circumstances and to put forth their defence. It is not a substitute for the prosecution's duty to prove its case beyond reasonable doubt. While an inculpatory statement made by the accused during this examination can be considered, it must be weighed against all other evidence on record. The Court emphasized that the prosecution cannot rely on such a statement to fill gaps or lacunae in its own evidence. Any inculpatory part of the statement, if relied upon, must be corroborated by independent evidence. This ruling reinforces the fundamental principle that the burden of proof rests entirely on the prosecution.
Why It Matters
This decision is significant for criminal trials across India. It clarifies the limited evidentiary value of an accused's statement under Section 313 CrPC (or Section 342 BNSS), preventing its misuse as a primary tool for conviction. For the prosecution, it underscores the necessity of building a strong, independent case without relying on potential admissions from the accused during examination. For the defence, it provides a robust argument against convictions based solely on such statements, ensuring that the prosecution meets its high standard of proof. This judgment safeguards the rights of the accused and reinforces the principles of fair trial and due process in the Indian criminal justice system. Counsel should confirm whether CrPC or BNSS applies based on the date of the proceeding as per BNSS s.531(2)(a).