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Issues: (i) Whether the appellant's confession was voluntary; (ii) Whether the confession was true; (iii) Whether the retracted confession was corroborated sufficiently to sustain conviction.
Issue (i): Whether the appellant's confession was voluntary.
Analysis: The confession was recorded by a Magistrate after the prescribed warnings were administered and time for reflection was given. The record showed compliance with the procedure under the Criminal Procedure Code and the Madras Criminal Rules of Practice. The alleged police pressure was not substantiated, and the form of the question put by the Magistrate did not amount to inducement.
Conclusion: The confession was held to be voluntary.
Issue (ii): Whether the confession was true.
Analysis: The confession was compared with the surrounding evidence and the probabilities of the case. Minor absence of detail, such as the omission of every injury or every circumstance spoken to by witnesses, did not render it false. There was nothing in the confession that was inconsistent with the prosecution version.
Conclusion: The confession was held to be true.
Issue (iii): Whether the retracted confession was corroborated sufficiently to sustain conviction.
Analysis: A retracted confession cannot ordinarily be the sole basis of conviction unless corroborated as a matter of prudence. The necessary corroboration need not extend to every detail; general corroboration of the broad features of the confession is sufficient. The presence of human blood on the seized articles, coupled with the absence of any explanation, furnished adequate corroboration.
Conclusion: The retracted confession was sufficiently corroborated and could be acted upon.
Final Conclusion: The conviction was upheld because the confession was voluntary and true, and its broad version was supported by corroborative circumstances.
Ratio Decidendi: A retracted confession may form the basis of conviction if it is found to be voluntary and true and is supported by general corroboration of its essential features; every detail in the confession need not be independently proved.