सं Samvidhan

Bharatiya Nagarik Suraksha Sanhita, 2023

Section 180

Examination of witnesses by police

Why this exists

This provision continues the long-standing power police have had (originally under Section 161 of the Code of Criminal Procedure, 1898 and later 1973) to gather information from witnesses during investigation without needing a magistrate's order at every step. The self-incrimination exception reflects the constitutional protection under Article 20(3) against being forced to be a witness against oneself. The audio-video recording option and the requirement of a woman officer for recording statements of women victims in sexual offence cases were added to modernize evidence-gathering and to make the process less intimidating and more sensitive for vulnerable witnesses, building on reforms introduced after the 2012 Delhi gang-rape case and the Nirbhaya-related 2013 amendments to the CrPC.

How courts read it

Under the identical predecessor provision (Section 161 CrPC), courts have held that statements recorded by police during investigation are not substantive evidence and cannot be used as direct proof of facts; they can only be used to contradict a witness at trial under Section 145 of the Evidence Act, as clarified in Tahsildar Singh v. State of U.P. Courts have also read the 'truly answer' obligation alongside the constitutional right against self-incrimination — in Nandini Satpathy v. P.L. Dani, the Supreme Court held that a person can refuse to answer questions that may expose them to criminal liability, reinforcing the protection built into sub-section (2). These interpretive principles are expected to continue to apply to Section 180 BNSS since its text mirrors the earlier provision.

Common misconceptions
  • Myth: A statement given to police under this section is direct evidence that can convict someone.
    Fact: Courts have held that such statements are not substantive evidence; they are mainly used to check for contradictions if the witness later says something different in court.
  • Myth: A witness must answer every question the police ask, no matter what.
    Fact: Sub-section (2) specifically allows a person to refuse to answer questions that would expose them to a criminal charge, penalty, or forfeiture.
  • Myth: Police statements always have to be handwritten on paper.
    Fact: The section now allows statements to be recorded through audio-video electronic means as well.