In the landmark case Dilip Mitra
v. State of West Bengal (2011), the Supreme Court addressed the recording of confessions by Magistrates and the safeguards required to ensure voluntariness. The Court established that: Which principle regarding confessional statements was established in Dilip Mitra
v. State of West Bengal?

In Dilip Mitra v. State of West Bengal (2011), the Supreme Court reiterated that Magistrates must ensure confessions are voluntary by scrutinizing whether the accused appears to have been subjected to duress, coercion, or inducement. The Magistrate must question the accused before and after recording to satisfy themselves of voluntariness. This landmark decision emphasizes the Magistrate's role as a guardian of constitutional rights and requires substantive judicial examination, not merely mechanical recording. These principles are reflected in BNSS Section 183, which requires the Magistrate to explain the person's rights and satisfy themselves of voluntariness before recording any confession.