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Supreme Court of India 2021-05-07 allowed

Jayamma & Anr vs State of Karnataka

Bench: 3 — Surya Kant

In Brief

Two appellants were convicted by the High Court of murder under IPC Sections 302 and 34, reversing the trial court's acquittal. The conviction rested solely on a dying declaration recorded from a burn victim (deceased) who had 80% injuries. The Supreme Court set aside the conviction, finding critical infirmities: the victim was administered sedative painkillers; contradictions existed between the doctor's and police officer's accounts of hand injuries; the doctor's fitness endorsement came after recording the statement, not before; the narrative was unusually detailed and accurate for an illiterate victim in agony; and all eyewitnesses except the police and doctor had resiled. The Court held that where a dying declaration lacks proper safeguards and corroboration, and the trial court's acquittal was based on reasoned analysis of evidence, the High Court cannot casually reverse it merely upon preferring its own view."

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Criminal Procedure Dying Declaration Evidence Burden of Proof Eyewitness Testimony Homicide Appellate Powers

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