In Brief
This case involved two men convicted of murder for setting another man on fire with kerosene. There were no eyewitnesses to the crime. The entire prosecution case rested on two dying declarations made by the victim—one to a hospital doctor and another to a police officer—before the victim died from 100% burn injuries. The appellants argued the dying declarations were unreliable because the victim had suffered complete burns and a magistrate had not recorded the statement. The Supreme Court upheld the conviction, holding that dying declarations can form the sole basis of conviction if they inspire confidence. The victim was conscious and coherent despite his injuries, provided specific details only he would know, and there was no evidence of fabrication or tutoring. The Court rejected claims of self-immolation as hearsay and found the appellants guilty under murder and common intention provisions."
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