17 January 2026 Legal Updates

Disclosure Statements Under Section 27 Evidence Act Alone Insufficient For Conviction Without Complete Chain Of Circumstantial Evidence: Supreme Court

(a) Case Title:

• Tulasareddi @ Mudakappa & Anr. v. State of Karnataka & Ors.

(b) Court:

• Supreme Court of India

(c) Date of Decision:

• January 16, 2026

(d) Bench:

• Justice Sanjay Karol & Justice Vipul M. Pancholi

Facts of the Case

The case related to an alleged murder where the prosecution’s case rested entirely on circumstantial evidence. The primary basis for implicating the accused was their disclosure statements under Section 27 of the Indian Evidence Act, leading to the alleged recovery of the dead body, along with surrounding circumstances such as motive, last seen evidence, and conspiracy.

The Trial Court acquitted the accused, holding that the chain of circumstances was incomplete, the disclosure statements were weak, the recovery was doubtful, and the sole “last seen” witness (PW-5) was unreliable. The medical evidence also did not fully support the prosecution’s timeline.

However, the Karnataka High Court reversed the acquittal, relying heavily on the Section 27 disclosures and recovery of the body, treating them as sufficient to connect the accused with the offence.

Aggrieved, the accused approached the Supreme Court.

Issues Raised

• Whether conviction can be sustained solely on disclosure statements under Section 27 of the Evidence Act?
• Whether the High Court was justified in reversing an acquittal without a complete chain of circumstantial evidence?
• Whether alleged recovery pursuant to disclosure, when not duly proved, can form the basis of conviction?

Contentions of the Appellants (Accused)

• Section 27 disclosures are not confessional evidence and have limited evidentiary value.
• The chain of circumstantial evidence was incomplete, failing the settled tests laid down by the Supreme Court.
• Recovery of the dead body was not conclusively proved.
• The sole eyewitness (PW-5) was unreliable and inconsistent.
• The High Court exceeded its appellate jurisdiction by reversing a possible and reasonable acquittal.

Contentions of the Respondent (State)

• Disclosure statements under Section 27 led to the recovery of the dead body.
• Circumstances such as motive, last seen evidence and recovery cumulatively established guilt.
• The High Court was justified in re-appreciating evidence and reversing the acquittal.

Court’s Reasoning & Key Findings

1. Limited Scope of Section 27 Evidence:

• The Court held that disclosure statements to police are not confessions.
• Only the portion leading to discovery of a fact is admissible, and even that cannot stand alone.

2. Incomplete Chain of Circumstantial Evidence:

• Conviction based on circumstantial evidence requires:
  - Each circumstance to be proved
  - All circumstances to form a complete chain
  - The chain to point only towards guilt
• This standard was not met in the present case.

3. Appellate Court’s Limits in Acquittal Appeals:

• If two reasonable views are possible, the appellate court must not disturb acquittal.
• The High Court erred in substituting its own view when the Trial Court’s view was plausible.

4. Unreliable Witness & Doubtful Recovery:

• PW-5 (sole eyewitness) was unreliable.
• The discovery of the dead body itself was not duly proved, weakening the prosecution case.

Final Verdict

• Appeals Allowed
• Conviction set aside
• Trial Court’s acquittal restored

Legal Principles Established

1. Section 27 Evidence Act – Limited Evidentiary Value:

• Disclosure statements alone cannot form the basis of conviction.
• Discovery must be clearly proved and supported by other evidence.

2. Circumstantial Evidence Doctrine:

• Conviction requires a complete and unbroken chain of circumstances.
• Any missing link → benefit of doubt to accused.

3. Appellate Restraint in Acquittal Cases:

• If the Trial Court’s view is reasonable, it cannot be overturned merely because another view is possible.

4. Criminal Jurisprudence Principle:

• Suspicion, however strong, cannot replace proof beyond reasonable doubt.