Say the ratio out loud before you open Reasoning — recalling it unprompted is exactly what the exam pays for.
Why it matters
A confession is normally pictured as something said to somebody — to a magistrate, to a police officer, to a friend. Sahoo removes that assumption. It holds that a man talking to himself can confess, and that the confession is relevant even though it was addressed to nobody.
That matters for the syllabus in two ways. It fixes the outer edge of what counts as a confession, and it explains the distinction between judicial and extra-judicial confessions: the category of extra-judicial confession is wide enough to include a remark overheard, a letter to a relative, even words said in the form of a prayer.
Facts
The accused was charged with the murder of his daughter-in-law, with whom he was always quarrelling. On the day of the murder he was seen going out of the house, saying words to the effect that he had finished her, and with her the daily quarrels. The words were not addressed to anyone; they were overheard.
Held
The statement was held to be a confession, and relevant in evidence. It is not necessary to the relevancy of a confession that it should have been communicated to some other person.
Reasoning
The reasoning runs straight from the definition rather than from any rule about audience.
Step one. A confession is an admission by a person charged with a crime, stating or suggesting the inference that he committed it. The definition looks at the content of the statement and at who made it. It says nothing about who was meant to hear it.
Step two. Communication is therefore not an ingredient. What makes the statement evidence is that the accused said it and that a witness can prove he said it. The soliloquy is proved like any other oral statement: by the evidence of the person who heard it.
Step three. Because the statement was made to no authority at all, it is an extra-judicial confession. A judicial confession is one made before a magistrate or in court in the due course of legal proceedings; everything else is extra-judicial, and an extra-judicial confession may be made to a private person, in a letter, or, as here, to no one.
Step four — the caution that always follows. An extra-judicial confession can found a conviction only if it passes the test of credibility. Because such a confession rests entirely on the word of the witness who reports it, courts as a matter of prudence look for material corroboration connecting the accused with the crime.
Exam use
Sahoo is the authority for two propositions that examiners like to test separately: that communication is not required, and that forms of confession are open-ended.
Use it in any question in which the incriminating words were overheard, written in a private letter, or spoken aloud in the absence of the person addressed. Use it also as the illustration when asked to distinguish judicial from extra-judicial confessions.
Pair it with the caution about extra-judicial confessions generally: the prosecution must establish that a confession was made, that evidence of it can be given because it was voluntary, and that it is true.