In the recent Supreme Court judgment, Renuka Prasad vs. The State (2025 LiveLaw SC 559), the Court ruled that the testimony of an Investigation Officer (IO) based solely on Section 161 CrPC statements of witnesses is inadmissible in evidence. The Court emphasized that such statements are not substantive evidence and cannot form the basis for a conviction. Consequently, the Court allowed the appeal and set aside the conviction that was based on these inadmissible statements.

Sources