Judicial Interpretation Of Section 164 Crpc Statements
1. State of Uttar Pradesh v. Rajesh Gautam (2003)
Background:
In this case, a statement was recorded under Section 164 CrPC, which the accused later claimed was coerced and not voluntary.
Issue:
Whether a statement under Section 164 CrPC can be admitted if the accused alleges coercion.
Judgment:
The Supreme Court held that statements under Section 164 must be voluntary. If the accused claims coercion, the trial court must carefully examine the circumstances before admitting it as evidence. The Magistrate must ensure no pressure or inducement.
Significance:
Affirmed voluntariness as an essential requirement for Section 164 statements.
Stressed the Magistrate’s duty to ensure free will.
Such statements can be used as evidence but require judicial scrutiny for voluntariness.
2. M.S. Verma v. State of Rajasthan (1991)
Background:
The accused argued that the Magistrate failed to properly caution them during recording of statement under Section 164.
Issue:
Whether failure of Magistrate to caution the accused affects the admissibility of the statement.
Judgment:
The Supreme Court ruled that the Magistrate must caution the accused that the statement may be used against them. Failure to do so may render the statement inadmissible because the accused must be aware of the consequences.
Significance:
Established the Magistrate’s duty to caution the accused.
Ensured accused understands rights before statement.
Protects accused from self-incrimination without awareness.
3. Nandlal Wasudeo Badwaik v. Lata Nandlal Badwaik (1992)
Background:
This case involved a statement under Section 164 made by a woman regarding allegations against the accused.
Issue:
Whether statements under Section 164 can be treated as substantive evidence in civil and criminal matters.
Judgment:
The court clarified that Section 164 statements are prima facie evidence, meaning they carry weight but are not conclusive. Such statements can be used both in criminal trials and related civil matters like matrimonial disputes.
Significance:
Clarified evidentiary value of Section 164 statements.
Can be used in both criminal and civil proceedings.
Not conclusive proof but important evidence.
4. State of Punjab v. Gurmit Singh (1996)
Background:
The accused challenged the admissibility of a Section 164 statement, claiming it was made without proper legal safeguards.
Issue:
What procedural safeguards must be followed during recording under Section 164?
Judgment:
The Supreme Court ruled that the Magistrate must record the statement without any pressure, ensure the accused understands the language, and that the statement is not recorded in the presence of the police or other influencing parties.
Significance:
Emphasized the importance of procedural safeguards.
Safeguards protect the statement from being declared involuntary.
Statements recorded under improper conditions can be excluded.
5. Nandini Satpathy v. P.L. Dani (1978)
Background:
Although mainly about custodial interrogation, this case also discussed voluntariness in recording confessions and statements.
Issue:
Whether custodial statements recorded under pressure are admissible.
Judgment:
The Supreme Court held that any statement made under custodial pressure or coercion is inadmissible. The principles apply equally to Section 164 statements, requiring voluntariness.
Significance:
Reinforced the principle that no coercion is allowed.
Expanded protection of accused rights in Section 164 contexts.
Quick Summary:
Section 164 statements must be voluntary and free from coercion.
Magistrates have a duty to caution the accused and ensure understanding.
Statements are prima facie evidence, not conclusive proof.
Proper procedural safeguards (language, no police presence) are mandatory.
Coerced or improperly recorded statements are inadmissible.
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