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Supreme Court of India 2021-05-07 allowed

Lachma s/o Chandyanaika & Anr vs State of Karnataka

Bench: 2 — Surya Kant, Aniruddha Bose

In Brief

Two appellants were convicted by the High Court of Karnataka for murder (Section 302 IPC) based on a dying declaration allegedly made by the victim who died from extensive burn injuries. The Supreme Court reversed the High Court's judgment and acquitted them. The Court held that while dying declarations can form the sole basis for conviction, the purported declaration was deeply flawed: the victim suffered 80% burns and was administered painkillers; medical fitness certification was made after recording rather than before; contradictions existed regarding burn injuries to the victim's hands; hostile witnesses (including the victim's son) suggested suicide; and no corroborative evidence existed. The Court reaffirmed that High Courts should not routinely reverse acquittals when trial courts reach a 'possible view' supported by evidence, and that dying declarations riddled with procedural defects and procedural concerns cannot sustain conviction.

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Criminal Law Evidence - Dying Declaration Criminal Procedure - Appellate Review Homicide Credibility of Evidence

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