*Sadashiv Dhondiram Patil V. The State of Maharashtra (2025 SC)* 1. Police Patil of the village is not a “police officer” u/s.25 IEA and hence the confession given to him is admissible. 2. ⁠However, an extra-judicial confession is a very weak evidence and if given in suspicious circumstances, its credibility becomes doubtful and it loses its importance. Extra-judicial confession must be true, trustworthy and voluntary i.e. free from any inducement and coercion. 3. It is very difficult ⁠to rely upon the extra-judicial confession if the exact words or even the words as nearly as possible have not been reproduced, the said statement cannot be said to be voluntary. In such circumstances, the same may have to be excluded from the purview of consideration. An omnibus and vague deposition cannot be relied upon. 4. ⁠The initial burden of proof is always on the prosecution. The prosecution has to first lay down the foundational facts before invoking the S.106 IEA. 5. ⁠Motive, however strong, cannot be the sole basis of conviction. 6. ⁠S.27 IEA: Just because the panch witnesses have turned hostile does not mean that such discovery should be disbelieved. From the plain reading of the oral evidence of the Investigating Officer, if the discovery is believable and inspires confidence, the same can definitely be looked into as one of the incriminating pieces of evidence against the accused. But the I.O. has to orally prove the contents of the panchnama as witness.