There is a difference between when an accused person would recant the voluntariness of his confessional statement, on the ground of either torture, duress or promise from a person in position of authority, and where the accused deny making any confessional statement at all. In the former scenario, the court is duty bound to conduct a trial-within-trial to ascertain the voluntariness of the statement, but in the latter case the court can admit the statement and determine the weight attachable to it after subjecting it to the test to determine its veracity.
