Introduction 

• This is a landmark judgment where the Court laid down that confessions and admissions must either be accepted as a whole or rejected as a whole. 
• The Judgment was delivered by a 3 judge Bench of Supreme Court consisting of Justice Mehr Chand Mahajan, Justice N Chandrasekhara Aiyar and Justice Natwarlal H. Bhagwati. 

Facts   

• Palvinder Kaur was tried for offences under Sections 302 (murder) and 201 (causing disappearance of evidence) of the Indian Penal Code, 1860 (IPC) in connection with the death of her husband, Jaspal Singh. 
• The prosecution alleged that Palvinder Kaur and Mohinderpal Singh (a relative of Palvinder who was a fugitive from justice) administered potassium cyanide poison to Jaspal Singh on 6th February 1950. 
• According to the prosecution, after Jaspal's death, his body was placed in a trunk, kept in the house for about ten days, then moved to Baldevnagar Camp, and finally thrown into a well near village Chhat on19th February 1950. 
• The body was discovered on 11th March 1950, when villagers reported a foul smell coming from the well, and the police were notified. 
• The Sessions Judge convicted Palvinder Kaur under Section 302 and sentenced her to transportation for life, without recording a verdict regarding the charge under Section 201. 
• On appeal, the High Court acquitted Palvinder of the murder charge but convicted her under Section 201, sentencing her to seven years' rigorous imprisonment. 
• The High Court relied heavily on Palvinder's confession made on 15th April 1950, accepting the inculpatory parts while rejecting the exculpatory portions as inherently incredible. 
• In her confession, Palvinder claimed that Jaspal had accidentally consumed a chemical meant for washing photographs, mistaking it for medicine, and that she and Mohinderpal had disposed of the body out of fear. 

Issues Involved  

• Whether the Court can rely on inculpatory parts of confessions while rejecting the exculpatory parts? 

Observations 

• The Court established that confessions and admissions must either be accepted as a whole or rejected as a whole, and courts cannot selectively accept inculpatory parts while rejecting exculpatory parts. 
• The Court held that in the present facts the statement read as a whole was exculpatory in character and the whole  statement was inadmissible in evidence  and the High Court acted erroneously in accepting the former part of it and rejecting the latter part as false. 
• The Supreme Court ruled that the High Court erred in treating Palvinder's statement as a confession and using it as evidence to support charges under Section 201 of the IPC. 
• The Supreme Court determined there was no direct or indirect evidence to support the High Court's finding that Jaspal's death was caused by potassium cyanide poisoning. 
• The Court found that mere motive, even if proved, cannot establish the circumstances or cause of death in the absence of concrete evidence. 
• The Court noted that Mohinderpal's possession of potassium cyanide was a neutral circumstance, as the poison was never traced in Jaspal's body. 
• The Supreme Court emphasized that suspicious handling of a dead body alone cannot conclusively prove unnatural death, as people may act unusually even in cases of accidental death. 
• The Court observed that the prosecution's case was significantly weakened by police officers and witnesses who gave false testimony. 
• The Supreme Court concluded that liberty cannot be restricted based on mere suspicion, however strong, but only on definite proof.

Conclusion

• The Supreme Court allowed Palvinder Kaur's appeal, establishing that confessions must be accepted or rejected in their entirety and that criminal convictions cannot rest on mere suspicion without definite proof. 
• This landmark judgment reinforced the principle that exculpatory statements aren't confessions and set important precedents for evaluating evidence in criminal cases.