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Virsa Singh vs The State Of Punjab 1958

Case Summary


The case of Virsa Singh vs The State Of Punjab (1958) arose from a criminal trial concerning the offense of murder under the Indian Penal Code. Virsa Singh, the appellant, was charged with the murder of his wife and convicted by the trial court. However, the case took a significant turn when the appellant retracted his confession, alleging that it was obtained under duress and coercion by the investigating officers. The main issue before the court was the admissibility of the appellant's confession as evidence and the circumstances under which it was obtained.


In a notable judgment delivered on March 11, 1958, the Supreme Court of India pronounced its verdict in the Virsa Singh case. The court held that the appellant's confession was not voluntary and was obtained under duress, coercion, and inducement by the investigating officers. The judgment emphasized the importance of ensuring that confessions were made voluntarily and without any external pressure or undue influence. The court further ruled that evidence obtained through involuntary confessions was inadmissible in court and violated the fundamental right against self-incrimination guaranteed under Article 20(3) of the Indian Constitution. As a result, the appellant's confession was deemed inadmissible, leading to the acquittal of the appellant in the murder case.


The Virsa Singh case had significant implications for criminal jurisprudence in India, particularly regarding the admissibility of confessions as evidence. Firstly, the judgment reaffirmed the principle that confessions obtained under duress or coercion were unreliable and violated constitutional protections against self-incrimination. It underscored the importance of procedural safeguards to prevent the abuse of investigative powers by law enforcement authorities. Secondly, the case highlighted the judiciary's role in upholding individual rights and ensuring fair trial standards in criminal proceedings. By excluding the appellant's involuntary confession, the court safeguarded the integrity of the criminal justice system and upheld the principles of justice, fairness, and constitutional rights.

Cases Linked to Virsa Singh vs The State Of Punjab:

Nandini Satpathy vs P. L. Dani (1978)

D.K. Basu vs State of West Bengal (1997)

Selvi vs State of Karnataka (2010)

Sarwan Singh Rattan Singh vs State of Punjab (1957)

Palvinder Kaur vs State of Punjab (1953)

Kartar Singh vs State of Punjab (1994)