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As per case facts, the appellant lodged an FIR confessing to the murder of his employer following a sudden quarrel and obscene remark; the Trial Court convicted him of murder,
...and the High Court reduced the conviction to culpable homicide not amounting to murder by invoking IPC Section 300, Exception 4, leading to the appeal to the Supreme Court. The question arose whether a confessional FIR is admissible in evidence and if the case rightly falls under Exception 4 to Section 300 for lack of non-confessional corroborative evidence. Finally, the Supreme Court allowed the appeal and acquitted the appellant, holding that the High Court erred by relying on the confessional FIR, which is inadmissible under the Evidence Act, and noted that the remaining medical and unreliable witness evidence was insufficient for conviction. Furthermore, the Court clarified that Exception 4 was incorrectly applied as the deceased was unarmed, which pointed to the appellant taking undue advantage, and deemed the conduct alone insufficient for conviction.
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