38.
The answer is: C
Explanation
The correct option is C: Deceit.
Section 24 of the Indian Evidence Act, 1872 states that a confession made by an accused person is irrelevant in a criminal proceeding, if the making of the confession appears to the Court to have been caused by any inducement, threat, or promise, having reference to the charge against the accused person, proceeding from a person in authority and sufficient, in the opinion of the Court, to give the accused person grounds, which would appear to him reasonable, for supposing that by making it he would gain any advantage or avoid any evil of a temporal nature in reference to the proceedings against him. Therefore, deceit is not mentioned as a ground under section 24 rendering a confession by an accused person irrelevant.