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Supreme Court of India 2022-10-31 allowed

The State of Jharkhand vs Shailendra Kumar Rai @ Pandav Rai

Bench: 2 — Dhananjaya Y Chandrachud, Hima Kohli

In Brief

The State of Jharkhand appealed against the High Court's acquittal of Shailendra Kumar Rai, who was charged with raping a minor girl and setting her on fire. The victim died from septicemia caused by severe burn injuries. The Supreme Court held that her dying declaration to the police was admissible under Section 32(1) of the Evidence Act as it related to the cause of her death and the circumstances leading to it. The Court upheld the Sessions Court's conviction, finding the dying declaration credible and sufficient proof beyond reasonable doubt. The Court deprecated the use of the 'two-finger test' in sexual assault cases, calling it baseless and patriarchal, and directed governments to remove it from medical curricula.

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Criminal Law Evidence Law Rape and Sexual Assault Dying Declarations Murder Hostile Witnesses Medical Evidence Gender-Based Violence Criminal Procedure Two-Finger Test Women's Rights and Dignity

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