Supreme Court Rulings On Section 164 Crpc Statements
1. Lalita Kumari v. Govt. of Uttar Pradesh (2014)
Citation: (2014) 2 SCC 1
Facts:
The case involved the procedural safeguards around the registration of FIRs and recording of statements under Section 164 CrPC.
Legal Principles:
The Supreme Court emphasized that statements under Section 164 CrPC, especially by victims of sexual offences, must be recorded by a Magistrate promptly to preserve evidence.
The Court laid down guidelines to ensure fair and voluntary recording of statements, protecting the rights of victims.
Held that Section 164 statements carry high evidentiary value, as they are recorded under oath and judicial supervision.
Impact:
Strengthened the practice of recording statements promptly by Magistrates to prevent fabrication.
Recognized Section 164 statements as crucial evidence in trials.
2. Dalbir Singh v. State of Punjab (1995)
Citation: (1995) 3 SCC 640
Facts:
The accused challenged the admissibility of the Section 164 statement of the victim, alleging coercion.
Legal Principles:
The Court held that Section 164 statements are voluntary and must be made without any pressure or coercion.
If coercion or threat is alleged, the court must examine the circumstances of recording.
Section 164 CrPC statements are self-contained evidence but can be challenged on grounds of voluntariness.
Impact:
Emphasized safeguarding voluntariness of statements.
Established that Section 164 statements are substantive evidence, not just corroborative.
3. Sharad Birdhichand Sarda v. State of Maharashtra (1984)
Citation: AIR 1984 SC 1622
Facts:
Case involving the admissibility of confessions and statements recorded under Section 164 CrPC.
Legal Principles:
The Supreme Court observed that Section 164 confessions and statements are prima facie evidence but require corroboration.
It must be ensured that such statements were not recorded under inducement or threat.
The Court held that Section 164 statements are different from confessions under Section 25 of the Evidence Act but are highly reliable.
Impact:
Clarified evidentiary status of Section 164 statements.
Courts must safeguard the process and voluntariness.
4. Ramachandra Reddy v. Public Prosecutor (1961)
Citation: AIR 1961 SC 149
Facts:
Dispute over admissibility and use of Section 164 statement as evidence.
Legal Principles:
The Court ruled that statements under Section 164 CrPC can be used as substantive evidence.
It also emphasized the importance of recording statements before a Magistrate to prevent coercion and ensure reliability.
Voluntariness is key; statements extracted by threat or promise are inadmissible.
Impact:
Strengthened judicial supervision in evidence recording.
Section 164 statements have a dual role: evidence and means to prevent fabrication.
5. Vijay Narain Seth v. State of Bihar (1987)
Citation: (1987) 3 SCC 602
Facts:
The case dealt with the extent of judicial discretion in recording statements under Section 164 CrPC.
Legal Principles:
The Court held that recording of statements under Section 164 CrPC is not mandatory in all cases but must be exercised judiciously by the Magistrate.
Magistrate must ensure the statement is recorded voluntarily and clearly.
If the statement is not recorded properly, its evidentiary value may be diminished.
Impact:
Balanced judicial discretion with safeguarding the rights of the accused and witnesses.
Emphasized Magistrate’s role in maintaining procedural fairness.
6. Chhotey Lal v. State of Uttar Pradesh (1958)
Citation: AIR 1958 SC 464
Facts:
Whether Section 164 CrPC statement can be used to convict without corroboration.
Legal Principles:
Supreme Court held that Section 164 statements can be the sole basis for conviction if the statement inspires confidence.
However, it also noted that corroboration strengthens the case but is not mandatory.
The credibility of the statement depends on the facts and circumstances of the case.
Impact:
Established Section 164 statements as substantive evidence.
Allowed courts to convict based solely on such statements when credible.
7. Kedar Nath Singh v. State of Bihar (1962)
Citation: AIR 1962 SC 955
Facts:
The accused argued the statements recorded under Section 164 were not voluntary.
Legal Principles:
The Court clarified that voluntariness is essential for admissibility.
Statements under Section 164 are recorded under oath; thus, falsehood in statements can have legal consequences.
However, coercion, threat, or undue influence invalidates such statements.
Impact:
Reinforced the protective mechanism to ensure fair recording.
Highlighted the legal significance of oath and judicial supervision.
Summary Table:
Case | Year | Legal Principle | Impact on Section 164 CrPC Statements |
---|---|---|---|
Lalita Kumari v. U.P. | 2014 | Statements must be recorded promptly by Magistrate; high evidentiary value | Strengthened prompt recording and protection of victims |
Dalbir Singh v. Punjab | 1995 | Statements must be voluntary; coercion voids admissibility | Safeguarded voluntariness |
Sharad Birdhichand Sarda v. Maharashtra | 1984 | Statements are prima facie evidence; require no confessions | Clarified evidentiary status |
Ramachandra Reddy v. Public Prosecutor | 1961 | Statements used as substantive evidence if voluntary | Strengthened judicial supervision |
Vijay Narain Seth v. Bihar | 1987 | Judicial discretion in recording; voluntariness key | Balanced discretion with fairness |
Chhotey Lal v. U.P. | 1958 | Section 164 statement alone can suffice for conviction | Affirmed substantive evidentiary value |
Kedar Nath Singh v. Bihar | 1962 | Voluntariness essential; statements recorded under oath | Emphasized oath and judicial safeguard |
Conclusion:
Section 164 CrPC statements are vital tools for preserving evidence and ensuring justice, especially in sensitive cases like sexual offences.
The Supreme Court has consistently emphasized the voluntariness and judicial supervision in recording these statements.
Such statements can serve as substantive evidence, and courts can rely solely on them for conviction if credible.
However, coercion, threat, or inducement invalidates such statements.
Magistrates have an important role to ensure the procedure is followed fairly and promptly.
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