Dipakbhai Jagdishchandra Patel vs State of Gujarat - Supreme Court Important Judgment 2019

Dipakbhai Jagdishchandra Patel vs State of Gujarat - Supreme Court Important Judgment 2019 - 

On 24th April, 2019, in the case of Dipakbhai Jagdishchandra Patel versus State of Gujarat and Another [Criminal Appeal No.714 of 2019], the Supreme Court examined the evidentiary value of admission and also discussed how a statement which does not constitute confession, may still be used an admission.

It was held that an admission “may be admissible under the Evidence Act provided that it meets the requirements of admission as defined in Section 17 of the Evidence Act.” However, an admission, if it is made in the course of investigation under the Cr.PC to a Police Officer, then, it will not be admissible under Section 162 of the Cr.PC as it clearly prohibits the use of statement made to a Police Officer under Section 161 of the Cr.PC except for the purpose which is mentioned therein.” The Supreme Court held that “statement given under Section 161, even if relevant, as it contains an admission, would not be admissible, though an admission falling short of a confession which may be made otherwise, may become substantive evidence.