"An Approver is a most unworthy friend, if at all, and
he, having bargained for his immunity, must prove his worthiness
for credibility in Court."1
1. INTRODUCTION
'The statement of an approver who has been tendered pardon
ought to be viewed with a great deal of circumspection', has
been the consistent view of the Hon'ble Supreme Court of India
in a series of judgments ranging from the time when the Code of
Criminal Procedure, 1898 was in force and thereafter under the Code
of Criminal Procedure, 1973 (the "CrPC")
till the coming into force of the Bharatiya Nyaya Suraksha Sanhita,
2023 (the "BNSS"), which would be in
effect from July 1, 2024.
Tendering of pardon and statements of approvers have been at the
center of much debate and attention in recent times. This article
aims to give a broad overview about the provisions relating to
tendering of pardon, evidentiary value of such statements, their
need and relevance, the practical challenges and limitations
