Sadashiv Dhondiram Patil vs. State of Maharashtra, Criminal Appeal, Supreme Court of India, Judgment dated January 9, 2025, [2025 INSC 93].

The Supreme Court of India, in Sadashiv Dhondiram Patil vs. State of Maharashtra [2025 INSC 93, decided January 9, 2025], quashed the conviction of the appellant for the murder of his wife, emphasizing the careful scrutiny required for extra-judicial confessions and the importance of credible evidence in criminal trials.

Facts and Background
Sadashiv Dhondiram Patil was charged with murdering his wife by strangulation using an iron rod and subsequently disposing of her body. The prosecution’s case largely rested on an extra-judicial confession allegedly made by the appellant before the Village Police Patil, discovery of the iron rod, and motive arising from marital discord. The Trial Court acquitted the appellant, but the Bombay High Court reversed the acquittal and sentenced him to life imprisonment.

Legal Issues
Whether an extra-judicial confession made before a Village Police Patil is admissible under the Indian Evidence Act.

The reliability and weight to be accorded to such a confession in the absence of corroborative evidence.

The evidentiary value of the discovery of the alleged murder weapon and the role of hostile witnesses.

The role of motive in establishing guilt in serious offenses like murder.

Supreme Court’s Findings
The Court clarified that a Village Police Patil is not a “police officer” under Section 25 of the Evidence Act; thus, confessions made before him are admissible as extra-judicial confessions. However, such confessions are inherently weak and require corroboration and careful evaluation for credibility.

Upon examining the evidence, the Court found the alleged confession vague and ambiguous, lacking the necessary trustworthiness to convict. The discovery of the iron rod was not satisfactorily proved since the Investigating Officer failed to establish the contents of the seizure panchnama properly, and the panch witnesses turned hostile.

The Court underscored that motive alone cannot be the sole basis for conviction, especially in grave offenses like murder. It must be considered alongside other reliable incriminating evidence. The prosecution failed to prove the case beyond reasonable doubt.

Conclusion
The Supreme Court allowed the appeal, reinstating the Trial Court’s acquittal. The judgment highlights:

Extra-judicial confessions require corroboration and must be credible to sustain conviction.

Village Police Patil is not a police officer under the Evidence Act, but confessions to him are weak evidence.

Discovery evidence must be properly established with credible witnesses.

Motive is a supplementary factor, not a standalone ground for conviction.

The prosecution bears the burden of proving guilt beyond reasonable doubt.