RAJA RAM JAISWAL vs STATE OF BIHAR

The Supreme Court held that an Excise Inspector is deemed a 'police officer' under Section 25 of the Indian Evidence Act, 1872, and thus confessions made to him during an investigation are inadmissible. The Court clarified that the term 'police officer' should be interpreted broadly, but not so broadly as to include individuals with limited police powers. The conviction of the appellant under Section 47(a) of the Bihar and Orissa Excise Act, 1915, was upheld as the confession was deemed inadmissible, but the evidence from other witnesses was sufficient to sustain the conviction.