The Indian Evidence Act, 1872, made significant derogations from common law on the topic of confessions. § 25, which makes confessions to police officers inadmissible, is an illustration of this. It has been regularly examined by courts for interpretative and clarificatory purposes. Thus, a vast body of judicial dicta today exists on how to construe this provision. Sifting through this, one notices persistent confusion with respect to a precondition for applying this exclusionary rule, i.e., who is a police officer. This paper undertakes a systematic review of decisions to trace changing judicial techniques for determining who a police officer is for the purposes of § 25. This enables a holistic critique of the current position of the Supreme Court on the matter which, it is argued, thwarts the legislative object behind the provision and is bad in law. It is concluded that an unequivocal statement of legislative intent through an amendment is the only solution to this.