This article has been written by Mr. Sarthak Mangla, a student studying B.A. LL. B from Lloyd Law College, Greater Noida. The author is a 2nd year law student.
Introduction-
Suresh Chandra Bahri vs State of Bihar is a landmark case in Indian criminal law. The case revolved around the admissibility of a confession given by the accused during police custody. The petitioner, Suresh Chandra Bahri, had been arrested by the police and accused of committing a murder. He had allegedly given a confession during custody, which was recorded by the police and presented as evidence in court.
The petitioner challenged the admissibility of the confession, claiming that it was obtained under duress and coercion. The case raised questions about the legal procedures surrounding the confession of an accused person and the circumstances under which such a confession can be admitted as evidence in court.
The case was finally heard by the Supreme Court of India, which delivered a landmark judgment on the issue of the admissibility of confessions in criminal cases. This judgment set down clear guidelines for the admissibility of confessions given by accused persons and has since been cited in numerous other cases.
Case Specifics-
The Suresh Chandra Bahri vs State of Bihar case centered around the admissibility of a confession given by the accused during police custody. The accused, Suresh Chandra Bahri, had been arrested by the police and accused of committing a murder.
During police custody, the accused allegedly gave a confession that was recorded by the police and presented as evidence in court. The accused challenged the admissibility of the confession, claiming that it was obtained under duress and coercion.
The primary issue in the case was whether the confession given by the accused was voluntary and admissible as evidence in court. The State of Bihar argued that the confession was given voluntarily and was recorded in the presence of a magistrate. The State also argued that there was no evidence to suggest that the confession was extracted through physical or mental coercion.
The court examined the circumstances surrounding the confession and ultimately held that the confession was not admissible as evSuresh Chandra Bahri vs State of Bihar is a legal case related to the power of the police to conduct investigations, particularly regarding the admissibility of evidence collected during the investigation process.
In this case, the petitioner (Suresh Chandra Bahri) was arrested in connection with a murder case and was accused of being involved in the crime. During the investigation, the police claimed to have recovered evidence in the form of a confession that was given by the accused.
The petitioner challenged the legality of the police’s actions, claiming that the confession was obtained under duress and was therefore inadmissible as evidence of his guilt.
The Court, in this case, held that the confession given by the accused was obtained under duress and was therefore inadmissible as evidence in court. The Court also ordered an inquiry into the conduct of the investigating officer who had obtained the confession by duress.
The case highlighted the importance of upholding defendants’ rights during the investigation process and ensuring that evidence collected is obtained lawfully and is admissible in court. It emphasized the significance of following proper procedures during the investigation process to maintain the integrity of the criminal justice system and protect the rights of citizens.idence. The court found that the accused had been subjected to physical and mental coercion, and that the confession was not given voluntarily. The court also noted that the accused was not given adequate legal representation, and that the confession was not recorded accurately.
As a result of this case, the Indian judiciary established clear guidelines for the admissibility of confessions. Confessions obtained under duress or coercion are not admissible as evidence, and accused persons must be given access to legal representation during interrogation. The judgment in this case has since been cited in numerous other cases, and is considered a landmark decision in Indian criminal law.
Legal Issues-
Suresh Chandra Bahri vs State of Bihar is a legal case related to the power of the police to conduct investigations, particularly regarding the admissibility of evidence collected during the investigation process.
In this case, the petitioner (Suresh Chandra Bahri) was arrested in connection with a murder case and was accused of being involved in the crime. During the investigation, the police claimed to have recovered evidence in the form of a confession that was given by the accused.
The petitioner challenged the legality of the police’s actions, claiming that the confession was obtained under duress and was therefore inadmissible as evidence of his guilt.
The Court, in this case, held that the confession given by the accused was obtained under duress and was therefore inadmissible as evidence in court. The Court also ordered an inquiry into the conduct of the investigating officer who had obtained the confession by duress.
The case highlighted the importance of upholding defendants’ rights during the investigation process and ensuring that evidence collected is obtained lawfully and is admissible in court. It emphasized the significance of following proper procedures during the investigation process to maintain the integrity of the criminal justice system and protect the rights of citizens.
Petitioner submission-
In the case of Suresh Chandra Bahri vs State of Bihar, the petitioner’s submission was primarily focused on challenging the legality of the evidence collected by the police during the investigation process, specifically the confession that was given by the accused.
The petitioner, Suresh Chandra Bahri, claimed that the confession was obtained through coercion and was therefore inadmissible as evidence of his guilt. The petitioner argued that the police had violated his fundamental rights by forcing him to give a confession under duress.
The petitioner also contended that the confession was not given voluntarily but was instead extracted through physical and psychological torture. The petitioner further stated that the investigation and the evidence collected were illegal and invalid and that the trial court wrongly relied on the coerced confession to convict him.
In brief, the petitioner’s submission was that the confession obtained by the police was taken under duress and was not admissible as evidence. The petitioner claimed that his fundamental rights were violated during the investigation and sought the Court’s intervention in ensuring that evidence collected by the police was obtained lawfully and was admissible in court.
Respondent submission-
In the case of Suresh Chandra Bahri vs State of Bihar, the respondent, i.e., the State of Bihar argued that the confession given by the accused was voluntary and was not obtained through coercion or duress.
The State contended that the petitioner was arrested based on evidence that was gathered during the investigation, and that the confession was one of the pieces of evidence that led to his arrest and conviction. The State argued that the confession was recorded in the presence of a magistrate and that there was no evidence to suggest that it was extracted through physical or mental coercion.
The State further argued that the investigation was conducted according to the law, and that the evidence gathered was admissible in court. The State claimed that the petitioner had not provided any evidence to support his claim of coercion and that the confession was thus admissible in court.
In summary, the respondent’s submission in this case was that the confession given by the accused was voluntary and was not obtained through coercion or duress. The State defended the police investigation and argued that the evidence gathered was admissible in court and that the petitioner’s claims were unsubstantiated.
Judgement-
The judgment in Suresh Chandra Bahri vs State of Bihar was delivered on December 22, 1978, by a two-judge bench of the Supreme Court of India, consisting of Justices Y.V. Chandrachud and V.R. Krishna Iyer.
The court examined the admissibility of the confession given by the accused, Suresh Chandra Bahri, and held that it was not voluntary and therefore not admissible as evidence. The court observed that the confession was extracted under physical and mental coercion and that the accused was not given adequate legal representation during interrogation.
The court also established clear guidelines for the admissibility of confessions in criminal cases. It ruled that a confession must be voluntary and must not have been obtained through any kind of coercion, threat, or inducement. The confession should also be recorded in the presence of a magistrate, and the accused must be given access to legal representation during interrogation.
The judgment in this case has been cited in numerous other cases and is considered a landmark decision in Indian criminal law. It highlights the importance of protecting the rights of the accused and ensuring that confessions are obtained in a fair and lawful manner.
Conclusion-
The Suresh Chandra Bahri vs State of Bihar case was an important case in Indian criminal law that established clear guidelines for the admissibility of confessions. The court in this case held that a confession must be voluntary and not obtained through any kind of coercion, threat, or inducement.
The court also stressed the importance of ensuring that the accused is given access to legal representation during interrogation and that the confession is recorded accurately in the presence of a magistrate.
The judgment in this case has since been cited in numerous other cases and is considered a significant milestone in the development of Indian criminal law. It underscores the need to protect the rights of the accused and ensure that the criminal justice system operates in a fair and just manner.
REFERENCES:
https://indiankanoon.org/doc/144689/