The Supreme Court judgment Tejinder Singh v. State of

Solution

Tejinder Singh v. State of Punjab established that extra-judicial confessions (made to persons other than official authority) are admissible when they meet the reliability threshold established by Section 22 of BSA and the principles derived from judicial precedent. Critically, the Court held that recovery of articles or facts disclosed in the confession, which were not previously known to investigating authorities, corroborates the confession and makes it admissible. This principle finds expression in the "recovery doctrine"—wherein the disclosure of unknown facts through confession followed by successful recovery establishes the confession's truthfulness. While such confessions require corroboration to be the sole basis of conviction, they are not categorically inadmissible. This aligns with BSA principles that admissibility does not equate to conclusiveness—confessions, extra-judicial or otherwise, require evaluation against the "proved" standard under Section 2(j) of BSA.