What if a person is convicted in court on the basis of the statement he/she made while in police custody? Confessions made in police custody can be true or extorted by force and torture. To find a difference between the two is really onerous. That’s why the confession statements given to the police are inadmissible as evidence in the court under Section 25 of the Evidence Act, to protect the accused from various forms of torture and to ensure the undertaking of a genuine investigation.
But still, in the \”Munikrishna versus the State\” case, the accused were convicted by the trial court under section 302 IPC and later their appeals were dismissed by the Karnataka High Court on the basis of the voluntary statements and their videography statements made in police custody. When the convicts approached the Supreme Court of India, the Bench of CJI UU Lalit and Justices S Ravindra Bhat and Sudhanshu Dhulia ruled that under Article 20(3) of the Constitution, an accused cannot be obliged to be a witness against himself, and that a confessional statement given to the police is inadmissible on the court as evidence, under Section 25 of the Evidence Act. Thus, protecting the constitutional rights of the accused.
Source: https://lawtrend.in/can-conviction-be-recorded-based-on-video-of-confession-made-before-police-supreme-court-saya-no/