Aghnoo Nagendra v.

State of Bihar (1996) 1 SCR 1341

This case explores in detail, the body of law regarding confessions. It also illustrates how s.27
operates.

The accused was charged under s.302, IPC for the murder of four persons. His conviction and
death sentence was confirmed by the High Court of Patna and the case came up before the
Supreme Court by way of special leave. In this case, the FIR was lodged by the appellant
himself, whereupon the officer-in-charge took immediate cognizance and arrested the
appellant. Later, in the company of the appellant and another witness, the police officer went
to the scene of the crime and as per the appellants directions, recovered the bodies of the
murdered persons and other incriminating items. It was argued on behalf of the appellant that
the entire statement was a confession made to a police officer by the accused and therefore
attracted the bar of s.25.

The Supreme Court stated that a confessional statement includes not only the admission of the
offence but also other admissions of incriminating facts relevant to the offence such as motive,
preparation, absence of provocation, concealment of weapons, and subsequent conduct which
throw light on upon gravity of the offence and the intention and knowledge of the accused.