Introduction During the investigation by the police officer, if the accused person is willing to admit the guilt of the crime, then the police officer may send the accused to some Magistrate for recording his statement of confession about the crime. The Magistrate after being satisfied that the accused is making the statement voluntarily records his statement of confession according to section 164 of Criminal Procedure Code, 1973. Section 164 of Criminal Procedure Code is a salutary provision which lays down certain precautionary rules to be followed by the Magistrate recording a confession so as to ensure the voluntariness of the confession and the accused being placed in a situation free from threat or influence of the police. Now at the time of trial the accused person may agitate before the court that he made the confession to the Magistrate due to undue influence of police. In this case the confession made by the accused to the Magistrate before the ....