Case Title: Harkirat Singh v. State of Punjab (1997)

Quick Summary

The Supreme Court ruled that notes made during an inquest cannot be used as substantive evidence at trial because Section 162 CrPC blocks such use. The High Court had treated an inquest statement and FIR contents as if they were proof by themselves. Since the informant had died and key witnesses were unreliable, the conviction could not stand. The Court set aside the conviction and discharged the appellant.

Issues

• Was the High Court right in upholding the conviction based on an inquest statement and FIR contents?

Rules

• Section 162 CrPC: Statements to police during investigation cannot be used as substantive evidence; only for contradiction as per law.
• FIR Use: FIR is not evidence by itself. It is mainly for setting the law in motion and may corroborate/contradict the informant when he or she testifies.

Arguments

Judgment

The Supreme Court held that the High Court had wrongly treated the inquest statement as substantive evidence, which Section 162 CrPC does not permit. The Court also noted that the FIR, whose author had died before trial, could not by itself prove the prosecution story. With only two remaining eyewitnesses who were not fully reliable, the evidence fell short. The conviction and sentence were set aside, and the appellant was discharged from his bail bonds.

Ratio Decidendi

1. Statements recorded during investigation, including inquest notes, are not independent proof at trial due to Section 162 CrPC.
2. FIR contents cannot become evidence if the informant is not examined; they serve only to corroborate or contradict the informant’s testimony.
3. Where crucial witnesses are unreliable, conviction cannot rest on weak support material like inquest notes or FIR contents.

Why It Matters

This case cleanly separates investigation from proof. Police notes help investigate, but courts need admissible evidence tested in open court. For students, it is a go-to authority on how Section 162 CrPC limits the use of inquest notes and FIR contents.

Key Takeaways

• Inquest statement ≠ substantive evidence.
• FIR is not a substitute for testimony.
• Section 162 CrPC acts as a gatekeeper for police-recorded statements.
• Unreliable eyewitnesses + barred statements = conviction cannot stand.

Mnemonic + 3-Step Hook

1. Spot: If a judgment leans on inquest notes or FIR contents, raise Section 162.
2. Sort: Separate what aids investigation (statements) from what proves facts (testimony & admissible evidence).
3. State: FIR only corroborates/contradicts the informant; it does not stand alone.

IRAC Outline

Glossary

Inquest

Preliminary inquiry into causes of death; not a substitute for trial evidence.

Substantive Evidence

Evidence that, by itself, proves a fact in issue.

FIR

First Information Report; sets criminal law in motion, not proof on its own.

FAQs

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