This statement forms an essential part of the jurisprudence surrounding the
law of evidence. It emphasizes the relationship and distinction between
"admissions" and "confessions," which are crucial concepts under the Indian
Evidence Act, 1872 (Sections 17–31 for admissions and Sections 24–30 for
confessions).
Definition of Admission (Section 17, Indian Evidence Act):
An admission is a statement, oral or written, made by a party to a legal
proceeding or by someone connected to the party, which suggests any inference as
to any fact in issue or relevant fact.
Definition of Confession:
A confession is a specific type of admission, where the person acknowledges
guilt for committing an offense. While not explicitly defined in the Evidence
Act, judicial interpretations clarify that confessions are admissions of guilt.
Explanation:
- Confession is a Subset of Admission:
All confessions are admissions because they acknowledge facts relevant to an offense. However, an admission does not necessarily involve acknowledgment of guilt; it can relate to other facts that indirectly implicate or support evidence of liability.
Example:
Confession: "I killed X intentionally with a knife."
Admission: "I was at the scene where X was stabbed."
- Nature of Admission:
Admissions cover a broader spectrum, including statements made in civil cases (e.g., ownership of property, acknowledgment of debt) and criminal cases. They are not confined to acknowledging guilt but may include statements about collateral or circumstantial facts.
Example in Civil Cases: "I borrowed ₹10,000 from the plaintiff."
- Nature of Confession:
A confession directly relates to the acknowledgment of guilt in a criminal case. Courts require confessions to be clear, unequivocal, and voluntary to be admissible.
Confession in criminal law directly implicates the person in the crime, leaving no room for ambiguity.
- Voluntariness and Admissibility:
Under Section 24 of the Indian Evidence Act, a confession is inadmissible if it appears to have been obtained through inducement, threat, or promise. Admissions do not have this strict requirement, though their relevance and credibility are evaluated.
Example: A coerced statement like "I killed X because the police threatened me" is inadmissible as a confession.
- Judicial Use and Interpretation:
Admissions serve as evidence to corroborate other facts, and they may not be conclusive proof.
Confessions, if voluntary and truthful, can serve as direct evidence of guilt.
Case Law:
Pakala Narayana Swami v. Emperor (1939): Defined confession as an acknowledgment of guilt and nothing short of that.
State of UP v. MK Anthony (1985): Emphasized voluntariness and truthfulness for admissibility of confessions.
- Legal Consequences:
Confession: Directly impacts the outcome of criminal proceedings and is often treated as the best evidence when admissible.
Admission: May strengthen a case but requires additional corroborative evidence.
Conclusion:
The statement underlines the narrower scope of confession within the broader
category of admissions. While confessions are highly specific and critical in
criminal law, admissions serve as evidence in both civil and criminal cases
without necessarily indicating guilt. The distinction is vital for understanding
their use and admissibility in legal proceedings.
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