Anand Jakkappa Pujari @ Gaddadar v. State of Karnataka, 2026
It emphasized that admissibility requires that the information must lead to distinct and specific discoveries attributable to each accused.
Judgement Details
Court
Supreme Court of India
Date of Decision
27 April 2026
Judges
Justice J.B. Pardiwala and Justice K.V. Viswanathan
Citation
Acts / Provisions
Section 13(1)(ia), Hindu Marriage Act, 1955
Section 25, Hindu Marriage Act, 1955
Facts of the Case
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The case concerned the disappearance and murder of a woman in Karnataka (March 2013).
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The victim went missing on 23.03.2013, and her charred skeletal remains were recovered four days later from a forest area.
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The prosecution alleged that the accused, including her brother, conspired due to a financial dispute involving money and gold.
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It was alleged that the accused abducted, murdered, and burnt the body to destroy evidence.
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The Trial Court convicted all accused; the High Court affirmed the conviction.
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Before the Supreme Court, only two accused challenged the conviction.
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A key piece of evidence was joint disclosure statements allegedly leading to recovery of crime-related locations.
Issues
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Whether joint or simultaneous disclosure statements by multiple accused are admissible under Section 27 of the Evidence Act?
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Whether a fact already discovered can be re-discovered through subsequent accused statements?
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Whether conviction can be sustained primarily on last seen evidence without strong corroboration?
Held
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Joint disclosure statements are admissible only if they lead to distinct and identifiable discoveries attributable to each accused.
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A fact already discovered cannot be rediscovered under Section 27 Evidence Act.
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Conviction cannot rest solely on last seen theory without corroboration.
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The conviction of the appellants was set aside and they were acquitted.
Analysis
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The Court clarified the fine distinction between joint disclosures and distinct discoveries under Section 27.
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It reinforced that Section 27 is an exception to the rule against self-incrimination and must be strictly construed.
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The judgment strengthens safeguards against mechanical reliance on police-recorded confessions/disclosures.
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It emphasizes that evidentiary value arises only when discovery is clearly linked to a specific accused and new fact.
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The ruling limits misuse of joint confessional statements in multi-accused cases.
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It also reiterates that last seen theory is a weak form of circumstantial evidence unless strongly corroborated.