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Supreme Court of India 2026-03-11 dismissed

Sanjay Kumar Sharma vs State of Bihar & Ors

Bench: 2 — Sanjay Kumar, K. Vinod Chandran

In Brief

A man was convicted by trial court for allegedly setting fire to his parents' house, killing them both. The High Court acquitted him, citing inconsistent and unreliable dying declarations, weak witness credibility, and serious investigative lapses. The Supreme Court dismissed the State's appeal and upheld the acquittal. The Court held that dying declarations must inspire full confidence and be free from tutoring or coercion to sustain conviction. Here, the declarations were inconsistent, lacked proper medical certification, and were recorded without adequate safeguards. Additionally, the investigation was defective and the accused was not properly examined under criminal procedure. The Court emphasised that suspicion, however strong, cannot replace proof beyond reasonable doubt in criminal cases.

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Criminal Procedure Evidence Law Dying Declarations Section 32 Indian Evidence Act Section 313 CrPC Fair Trial Burden of Proof Investigation Procedure Hearsay Exception

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