In Brief
In this murder appeal, the Supreme Court upheld the conviction of Gulzari Lal for murder and causing injuries under Sections 302 and 323 IPC read with Section 34. The appellant challenged the High Court's reliance on a dying declaration recorded without a formal medical certificate of fitness. The Court held that a dying declaration need not be formally certified by a doctor if the recorder (here, a Head Constable) was satisfied of the declarant's mental fitness. Crucially, the conviction rested not solely on the dying declaration but also on unshattered eye-witness testimony and an independent witness's account. Applying the doctrine of concurrent findings, the Court declined to interfere with the Trial Court and High Court's determinations on fact and conviction. The appeal was dismissed as devoid of merit."
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