CONVICTION CANNOT BE SUSTAINED SOLELY ON AN UNCORROBORATED CONFESSION

INTRODUCTION
In its Judgment dated 27 January 2026, rendered in Bernard Lyngdoh Phawa v. State of Meghalaya (Criminal Appeal No. 3738 of 2023), the Supreme Court of India reaffirmed a foundational principle of criminal jurisprudence: a conviction cannot be sustained solely on the basis of an uncorroborated confession.
The criminal justice system demands that courts adjudicate disputes by examining the totality of circumstances, including documentary evidence, oral testimony, motive, burden of proof and other relevant material. Among these, a confession occupies a delicate position. While it may amount to an admission of culpability, the law has consistently cautioned against treating a confession as conclusive proof of guilt in the absence of supporting evidence.
Confessions are susceptible to coercion, inducement, misunderstanding or fabrication. Consequently, courts are required to scrutinise such statements with utmost care. This leads to two pertinent legal questions: whether a confession, by itself, can form the sole basis for conviction and whether a court can rely upon a confession without independent corroboration.
The present Judgment provides a decisive answer by holding that a confession, unless voluntary, truthful and corroborated by independent and reliable evidence, cannot be the sole foundation for conviction. The ruling assumes significance as it corrects the approach adopted by the Meghalaya High Court, which had reversed an acquittal and recorded a conviction primarily on the basis of confessional statements.

FACTS OF THE CASE
The case originates from the alleged homicide of Biplab Das, a 21-year-old student of St. Anthony’s College, Shillong, who went missing in 2006. Despite sustained efforts by his family, his whereabouts remained unknown until his body was later exhumed from a grave at Mawlai-Mawroh in Meghalaya. The post-mortem examination revealed that the cause of death was strangulation.
During the course of investigation, suspicion arose against two acquaintances of the deceased, including Bernard Lyngdoh Phawa. The matter was tried before the Trial Court, which acquitted the Accused on the ground that the prosecution had failed to establish guilt beyond reasonable doubt. The Trial Court noted the absence of direct evidence as well as significant gaps in the chain of circumstantial evidence.
Aggrieved by the acquittal, the State preferred an Appeal before the Meghalaya High Court. The High Court reversed the Trial Court’s findings and convicted the Accused under Section 302 of the Indian Penal Code (now corresponding to Section 103 of the Bharatiya Nyaya Sanhita, 2023) for the offence of murder and under Section 201 IPC (now Section 238 of the Bharatiya Nyaya Sanhita) for causing disappearance of evidence. The High Court’s decision was primarily based on the confessional statements attributed to the Accused.
The Accused, challenging the reversal of acquittal, approached the Supreme Court.

COURT’S ANALYSIS AND DECISION
The Supreme Court examined the reasoning adopted by the High Court and found it to be legally unsustainable. It reiterated that an appellate court must exercise extreme caution while interfering with an order of acquittal, particularly where the prosecution case rests on circumstantial evidence and alleged confessions.
The High Court had placed reliance on the Judgment in Sharad Birdhichand Sarda v. State of Maharashtra ((1984) 4 SCC 116), wherein the Supreme Court laid down five cardinal principles governing cases based on circumstantial evidence. These principles require that the circumstances relied upon must be fully established, must point unerringly towards the guilt of the accused, must form a complete chain and must exclude every hypothesis consistent with innocence.
Applying these principles to the facts of the present case, the Supreme Court found that the prosecution had failed to establish a complete and coherent chain of circumstances. The alleged confession was neither adequately proved nor corroborated by independent evidence. Material doubts persisted and the circumstances did not conclusively establish the guilt of the Accused.
The Court further relied upon Manoharan v. State by Inspector of Police ((2019) 7 SCC 716), wherein it was held that a confession can be acted upon only if it is voluntary, truthful and corroborated by other reliable evidence. The Court emphasised that a confession, even if admissible, cannot be elevated to the status of substantive proof in the absence of corroboration.
Consequently, the Supreme Court set aside the Judgment of the High Court and restored the acquittal recorded by the Trial Court.

CONCLUSION
The Judgment in Bernard Lyngdoh Phawa v. State of Meghalaya reinforces a vital safeguard against wrongful convictions. It underscores that criminal courts must not rely mechanically on confessional statements without subjecting them to rigorous scrutiny and corroboration.
By reaffirming that an uncorroborated confession cannot be the sole basis for conviction, the Supreme Court has strengthened the principles of fairness, due process and proof beyond reasonable doubt. The decision serves as a timely reminder that in criminal trials, suspicion, however strong, cannot substitute proof and confessions, unless independently supported, cannot determine guilt.

ALLUR RAJA RAJESHWARI SOUJANYA
Legal Associate
The Indian Lawyer & Allied Services

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