27.1. This Court has, in various judgments, clarified this position. Illustratively, in Jaikam Khan v. State of U.P. MANU/SC/1259/2021 : (2021) 13 SCC 716 it was observed:
One of the alleged recoveries is from the room where deceased Asgari used to sleep. The other two recoveries are from open field, just behind the house of deceased Shaukeen Khan i.e. the place of incident. It could thus be seen that the recoveries were made from the places, which were accessible to one and all and as such, no reliance could be placed on such recoveries.
(Emphasis supplied)
 27.2. Also, in Nikhil Chandra Mondal v. State of W.B. MANU/SC/0211/2023 : (2023) 6 SCC 605 the Court held:
20. The trial court disbelieved the recovery of clothes and weapon on two grounds. Firstly, that there was no memorandum statement of the Accused as required Under Section 27 of the Evidence Act, 1872 and secondly, the recovery of the knife was from an open place accessible to one and all. We find that the approach adopted by the trial court was in accordance with law. However, this circumstance which, in our view, could not have been used, has been employed by the High Court to seek corroboration to the extra- judicial confession.
IN THE SUPREME COURT OF INDIA
Criminal Appeal No. 866 of 2011
Decided On: 06.11.2023
Manjunath and Ors. Vs. State of Karnataka
Hon’ble Judges/Coram:
Abhay Shreeniwas Oka and Sanjay Karol, JJ.
Author: Sanjay Karol, J.
Citation:Â MANU/SC/1212/2023.
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