The Supreme Court of India clarified the scope of Section 27 of the Evidence Act in Shaik Shabuddin v. State of Telangana, holding that materials voluntarily handed over by an accused during a police check or at the time of arrest cannot be treated as recoveries under Section 27. The Court observed that for Section 27 to apply, the discovery must be pursuant to information leading to the concealment of an object. Articles merely taken from the accused’s possession at the time of arrest do not qualify as admissible recovery evidence. The Court also rejected reliance on an inadmissible confession made in police custody and corrected the improper application of the “last seen” theory. While convictions under the SC/ST Act were set aside due to lack of proof of caste knowledge, convictions for rape and murder were upheld on the strength of medical and circumstantial evidence. The sentence was modified to 25 years’ imprisonment without remission.