In which case it was held that every confession is an

Solution

In Subbiah Mudaliar vs Gopala Mudaliar it was held that for a statement in a former suit to be admissible under Section 32(5) of Evidence Act that the person who made the statement must have special means of knowledge must be shown by independent evidence, otherwise it would be arguing in a circle to hold the document itself proves the relation therefore shows special means of knowledge In State(NCT of Delhi) vs. Navjot Sandhu alias Afsan Guru it was held that though every confession is an admission, every admission need not be a confession. An admission made before the police cannot be proved against the accused and cannot be considered a confession. In Kottaya vs Emperor the Court was of the opinion that the extent to which information is admissible depends upon the exact nature of the fact discovered to which such information is required to relate. (Admissibility of information under Section 27 of Evidence Act) In Gulzar Khan vs State it was held that the scope of Section 73 of Evidence Act extends to the court of Magistrate as well.