Nandini Satpathy v. P. L. Dani And Anr
Nandini Satpathy v. P.L. Dani and Anr.
AIR 1978 SC 1025
Supreme Court of India
Background:
The case Nandini Satpathy v. P.L. Dani is a landmark judgment dealing primarily with constitutional law, specifically the right against self-incrimination under Article 20(3) of the Indian Constitution. It also deals with the scope and ambit of Article 20(3), which protects an accused person from being compelled to be a witness against themselves.
Facts of the Case:
Nandini Satpathy, a prominent politician and former Chief Minister of Odisha, was implicated in a corruption case.
The police sought to record her statement during the investigation.
She refused to give a statement before the police, asserting her right under Article 20(3) not to incriminate herself.
The issue arose whether a person can be compelled to answer questions put by the police during the investigation, or if the protection under Article 20(3) extends to all stages of investigation.
Legal Issues:
What is the scope of the protection under Article 20(3) of the Constitution of India?
Can a person refuse to answer police questions on the ground that it may incriminate them?
Does the right against self-incrimination apply only during trial or also during investigation?
Are statements made before police during investigation admissible as evidence?
Relevant Constitutional Provision:
Article 20(3):
"No person accused of any offence shall be compelled to be a witness against himself."
Judgment:
The Supreme Court laid down important principles regarding the right against self-incrimination:
Right Against Self-Incrimination Applies at All Stages:
The Court held that Article 20(3) protects a person from being compelled to answer questions that may incriminate them not only at the trial but also at the stage of investigation.
Therefore, a person has the right to refuse to answer any questions put to them by the police if those answers might incriminate them.
Statements Made to Police Cannot Be Used as Evidence:
The Court emphasized that statements made voluntarily to the police during investigation are not admissible as evidence in court.
The police cannot compel the accused to make any statement; any such compulsion is violative of Article 20(3).
Safeguard to Accused’s Rights:
The right against self-incrimination is a fundamental safeguard to prevent abuse of power by the police and authorities.
The Court recognized the importance of this right as a protection against forced confessions or involuntary statements.
Distinction Between Voluntary and Involuntary Statements:
If a statement is made voluntarily and without compulsion, it can be admissible.
But statements obtained by coercion or compulsion are inadmissible.
Significance:
This case firmly established the principle that Article 20(3) protects an accused person throughout the criminal process, including the police investigation phase.
It gave constitutional backing to the right to silence during investigation.
The judgment safeguards citizens from forced confessions and custodial torture.
It aligns with the rule of law and principles of fair trial.
Related Case Law:
Kartar Singh v. State of Punjab (1994) – reinforced the protection against self-incrimination during investigation.
Selvi v. State of Karnataka (2010) – held that involuntary confessions through scientific techniques like polygraph tests violate Article 20(3).
Maneka Gandhi v. Union of India (1978) – upheld principles of fair procedure related to personal liberty.
Summary:
Nandini Satpathy v. P.L. Dani is a landmark judgment reinforcing that:
No accused person can be compelled to answer questions or make statements that may incriminate them.
This protection applies not only during the trial but also at the investigation stage.
Statements made to police under compulsion are inadmissible as evidence.
The right against self-incrimination is a fundamental constitutional safeguard ensuring fair treatment of accused persons.
RELATED Blog
0 comments