Summary and Analysis of Narayan Yadav Vs State Of Chhattisgarh (Criminal Appeal No. 3343 Of 2025)

1. Heading of the Judgment

Narayan Yadav vs State of Chhattisgarh
(Supreme Court of India, Judgment dated 5th August 2025)

2. Relevant Laws and Sections Discussed

The judgment extensively interprets:

• Indian Evidence Act, 1872 (IEA):
  Section 25: Prohibits confessions made to police officers from being used as evidence.
  Section 27: Allows information leading to discovery of facts (e.g., weapons, stolen goods) to be admissible.
  Section 8: Conduct of the accused (e.g., surrendering, pointing out evidence) is relevant.
  Section 21: Admissions (non-confessional statements) are admissible against the maker.

• Indian Penal Code, 1860 (IPC):
  Section 300: Defines "murder" and Exception 4 (sudden fight without premeditation).
  Section 304: Punishment for culpable homicide not amounting to murder.
  Section 302: Punishment for murder.

3. Basic Details of the Case

• Parties:
  Appellant: Narayan Yadav (accused).
  Respondent: State of Chhattisgarh.

• Origin:
  Appellant lodged an FIR (27.09.2019) confessing to murdering Ram Babu Sharma after a drunken quarrel.
  Trial Court convicted him under Section 302 IPC (murder), sentencing him to life imprisonment.
  High Court altered conviction to Section 304 Part I IPC (culpable homicide not amounting to murder), granting benefit of Exception 4 to Section 300 IPC.

• Supreme Court’s Task:
  Decide whether the High Court erred in convicting the appellant under Section 304 Part I IPC.

4. Explanation of the Judgment

A. Key Errors Identified by the Supreme Court

The Supreme Court reversed the High Court’s decision and acquitted Narayan Yadav, citing three critical errors:

(i) Inadmissibility of Confessional FIR

• Issue: The High Court relied on the FIR (Exhibit P-14) lodged by the appellant, which contained a full confession of murder.

• Law Violated: Section 25 IEA bars confessions made to police officers from being used as evidence.

• Court’s Reasoning:
  A confessional FIR is wholly inadmissible against the accused. It can only be used for limited purposes:
  To prove the accused’s conduct (e.g., promptly reporting the incident) under Section 8 IEA.
  To admit information leading to discovery of facts (e.g., weapons, stolen goods) under Section 27 IEA.
  The High Court wrongly treated the FIR as "corroborative evidence" by matching it with medical reports.

• Precedents Cited:
  Faddi v. State of M.P. (1964): Non-confessional parts of an FIR may be admissible as admissions.
  Aghnoo Nagesia v. State of Bihar (1965): Entire confessional FIR must be excluded if it contains self-incriminating statements.

(ii) Over-reliance on Medical Evidence

• Issue: The High Court convicted the appellant primarily based on the post-mortem report (by Dr. R.K. Divya, PW-10).

• Court’s Reasoning:
  Medical evidence is advisory, not conclusive. An expert witness (e.g., a doctor) cannot prove who committed the crime; they only opine on cause of death.
  Conviction for murder requires direct/circumstantial evidence linking the accused to the crime, not just medical reports.

(iii) Misapplication of Exception 4 to Section 300 IPC

• Issue: The High Court applied Exception 4 (sudden fight without premeditation) to reduce the conviction.

• Court’s Reasoning:
  Exception 4 requires:
  A sudden mutual fight (both parties exchanging blows).
  No undue advantage (e.g., using a weapon against an unarmed victim).
  No cruel/unusual manner of attack.
  Here, the deceased was unarmed. The appellant used a knife and wooden log to inflict brutal injuries (6 stab wounds). This showed:
  Unfair advantage (armed vs. unarmed).
  Cruelty (multiple injuries to vital organs).
  Precedents Cited:
  Kikar Singh v. State of Rajasthan (1993): Exception 4 inapplicable if the accused uses a deadly weapon against an unarmed victim.
  Surain Singh v. State of Punjab (2017): "Sudden fight" implies mutual combat, not one-sided assault.

B. Lack of Corroborative Evidence

• Hostile Witnesses: All panch witnesses (PW-1 to PW-6) turned hostile.

• No Discovery of Facts: The police failed to prove recovery of evidence (e.g., bloodstained clothes) under Section 27 IEA.

• Conduct Alone Insufficient: The appellant’s act of surrendering or pointing out evidence (Section 8 IEA) could not substitute substantive proof of guilt.

C. Final Ruling

• The Supreme Court acquitted Narayan Yadav due to:
  "Total absence of legally admissible evidence connecting the appellant to the crime."

• The prosecution failed to prove guilt beyond reasonable doubt.

Conclusion

The Supreme Court’s judgment emphasizes:

1. Confessions to police are inadmissible (Section 25 IEA).

2. Medical reports cannot establish guilt without corroborative evidence.

3. Exception 4 to Section 300 IPC applies only in mutual fights without brutality or unfair advantage.

4. Conduct of the accused (Section 8 IEA) is relevant but insufficient for conviction in serious crimes like murder.

Result: Acquittal of Narayan Yadav.