BACK TO BSA 2023AIR 1963 SC 1094
BSA 2023ACTIVE FRAMEWORKChapter III
Section 22
Confession Caused by Inducement, Threat or Promise
Of Admissions
Quick Legal SummaryIEA IEA S.24
Statutory Snapshot
THE STATUTE
Original Text
A confession made by an accused person is irrelevant in a criminal proceeding, if the making of the confession appears to the Court to have been caused by any inducement, threat or promise, having reference to the charge against the accused person, proceeding from a person in authority, and sufficient, in the opinion of the Court, to give the accused person reasonable grounds for supposing that by making it he would gain any advantage or avoid any evil of a temporal nature in reference to the proceedings against him.
Legal Commentary
BSA Section 22 is textually identical to IEA Section 24. The voluntariness doctrine for confessions is unchanged in the BSA — this was a deliberate preservation. The three-condition test (inducement/threat/promise + person in authority + reasonable grounds) applies identically.
All case law on IEA Section 24 — including the Pyare Lal Bhargava objective test, the Singhara Singh approver promise ruling, and the Section 27 discovery exception — applies directly under BSA Section 22.
Legislative Intent & Background
Preserved from IEA Section 24.Critical Provisions & Changes
BSA Section 22 is substantively identical to IEA Section 24.
Renumbered from S.24 to S.22.
Landmark Judicial Precedents
Pyare Lal Bhargava v. State of Rajasthan (1963)
Objective test for reasonable grounds — applies under BSA Section 22.
Practical Scenarios & Illustrations
Same as IEA Section 24 examples — applies to offences committed on or after July 1, 2024.
Questions & Answers
Yes — BSA Section 22 is identical to IEA Section 24. The three-condition test (inducement/threat/promise from person in authority + reasonable grounds for temporal advantage) is unchanged. All case law applies.
BSA Section 22 of the Bharatiya Sakshya Adhiniyam (BSA) 2023 (Confession Caused by Inducement, Threat or Promise) directly governs how courts evaluate and admit evidence in civil and criminal proceedings. BSA Section 22 is textually identical to IEA Section 24. The voluntariness doctrine for confessions is unchanged in the BSA — this was a deliberate preservation. The three-condition test (inducement/threat/promise + person in authority + reasonable grounds) applies identically.
All case law on IE... Advocates must ensure that evidence sought to be relied upon satisfies the conditions prescribed by this provision, failing which it may be excluded or accorded lesser weight by the court.