Statements Made U/s. 313 CrPC Can Only Be Used Against Accused If There Is Other Evidence To Hold Him Guilty:...
“Statements made under Section 313 of the Criminal Procedure Code (CrPC) can only be used against the accused if there is other corroborative evidence to hold him guilty.”
This principle safeguards the accused’s rights and ensures fair trial by preventing conviction solely on the basis of the accused’s statement under Section 313.
Understanding Section 313 CrPC
Section 313 CrPC mandates that the accused must be examined by the trial court after the prosecution has closed its evidence.
The purpose is to give the accused a chance to explain or deny the evidence presented against him.
The statement recorded is not sworn evidence but an opportunity to clarify facts or raise defense.
Key Principle: Section 313 Statements Are Not Conclusive Evidence
Statements under Section 313 are not confessions or substantive evidence.
They are primarily used for enabling the accused to explain prosecution evidence and to test their defense.
Courts cannot convict solely or mainly based on these statements.
There must be other independent evidence (oral, documentary, circumstantial) to support guilt.
The accused’s statement under Section 313 may be considered against the accused to check consistency or admission, but cannot be the sole basis for conviction.
Rationale Behind This Principle
Voluntariness and Fairness
The accused may be nervous, confused, or unaware of the legal impact of their answers. Their explanations are not under oath and may not represent the whole truth.
Protection Against Forced Admissions
Section 313 is a tool for trial fairness, not a means to pressure the accused into making incriminating statements.
Presumption of Innocence
The burden to prove guilt beyond reasonable doubt lies on the prosecution, and this cannot be discharged by the accused’s explanation or admission alone.
Important Supreme Court Judgments
1. K. Chandrasekharan v. State of Kerala (1976)
The Court held that the accused’s statement under Section 313 is not evidence but an opportunity to explain.
Conviction cannot rest solely on this statement; it must be supported by independent evidence.
2. K.L. Verma v. Union of India (1969)
Section 313 statements are not substantive evidence and should not be used as such.
They serve only as an instrument of inquiry and explanation.
3. State of Maharashtra v. Suresh (2000)
The Supreme Court reiterated that Section 313 statements are to be used to test the correctness of prosecution evidence.
They cannot be the sole basis for conviction.
4. Prafulla Kumar Samal v. State of Orissa (1990)
The accused’s answers during Section 313 examination cannot take the place of prosecution evidence.
Conviction requires corroboration from other material on record.
5. Rajesh Bajaj v. Union of India (2016)
The Court held that a trial court cannot rely on Section 313 answers to convict if there is no other evidence linking the accused to the crime.
Judicial Approach
Courts use the Section 313 statement to clarify contradictions, admissions, or explanations.
If the accused denies charges or offers explanations, the court weighs those against prosecution evidence.
If prosecution evidence is weak or missing, mere answers under Section 313 are insufficient for conviction.
The statement may be used to test truthfulness but cannot replace the requirement of proof beyond reasonable doubt.
Practical Implications
Defence lawyers often use Section 313 statements to challenge prosecution evidence.
Prosecution must ensure strong, independent evidence rather than relying on accused’s statements.
Courts should be cautious and not convict based only on accused’s Section 313 responses.
Conclusion
Statements made by the accused under Section 313 CrPC serve as a vital procedural safeguard ensuring fairness, but they are not substantive evidence. The Supreme Court consistently holds that such statements can be used against the accused only when supported by other independent evidence proving guilt beyond reasonable doubt.
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