admissibility and limitations of disclosure statements under section 27

A disclosure statement made by an accused while in police custody is admissible under Section 27 of the Indian Evidence Act, 1872, strictly to the extent that it leads directly to the discovery of a distinct fact previously unknown to the investigating agency. However, pure confessional statements or self-incriminating admissions contained within such disclosures remain wholly inadmissible in evidence against the accused. The discovery of a fact, such as the recovery of a dead body or an object, does not automatically translate into proof of guilt for murder unless connected to the accused through an unbroken chain of circumstantial evidence. Where the recovery process is plagued by serious procedural omissions—such as failing to examine crucial independent witnesses who recovered the object—the reliability of the discovery itself becomes highly doubtful. Conviction cannot be founded solely on the recovery of a body or article based on a disclosure statement when the underlying chain of circumstances remains incomplete and unsubstantiated. (Tulasareddi @ Mudakappa & Anr. v. The State of Karnataka & Ors. | 2026 INSC 67)