In a significant ruling, the Supreme Court has upheld the conviction of a man accused of setting his wife on fire, reinforcing the evidentiary value of a dying declaration in criminal trials. The bench led by Justice Sanjay Karol dismissed the appeal, finding no legal error in the earlier judgments.
Background of the Case
The case involves Shankar, who was convicted for the murder of his wife, Sugna Bai, in Rajasthan. According to the prosecution, the incident occurred in October 2012, barely a month after their marriage.
The woman had reportedly been facing abuse due to her husband’s alleged alcohol consumption and violent behavior. On the day of the incident, she was allegedly beaten, doused with kerosene, and set on fire inside their rented room.
She sustained severe burn injuries and was taken to a hospital, where her statement was recorded. She later died during treatment.
The Trial Court in Bundi convicted Shankar under Sections 302 (murder) and 342 (wrongful confinement) of the Indian Penal Code, sentencing him to life imprisonment. The Rajasthan High Court later upheld the conviction.
Hearing the appeal, the Supreme Court examined whether there were any serious legal errors in the findings of the lower courts. The bench noted that interference in such concurrent findings is limited.
A key issue raised by the appellant was regarding the validity of the dying declaration. However, the Court found no merit in this challenge.
Referring to the record, the bench observed that the dying declaration was recorded by a Magistrate after obtaining medical certification of the victim’s condition.
“The statement was recorded in question-answer form, and the doctor had certified that the victim was conscious and fit to give her statement,” the Court noted.
The Court also rejected the argument that the declaration was unreliable due to alleged procedural lapses. It clarified that minor technical issues, such as certification being on the same sheet, do not affect its credibility.
On the claim of tutoring by the victim’s family, the bench was clear:
“This appears to be nothing but a bald assertion,” it said, finding no evidence to support such an allegation.
Even though some witnesses turned hostile, the Court emphasized that medical evidence supported the prosecution’s case and aligned with the victim’s statement.
The judgment highlighted the importance of dying declarations in criminal law.
“The law recognizes that a person on the verge of death is unlikely to lie,” the bench observed, explaining why such statements are given special weight in evidence.
It added that if a dying declaration is consistent and trustworthy, it can form the sole basis of conviction.
After examining all aspects, the Supreme Court found that the prosecution had successfully proved the case beyond reasonable doubt.
“Taking a cumulative view… the appeal must fail,” the Court concluded while dismissing the appeal.
The conviction and life sentence awarded to the appellant were thus upheld. Pending applications, if any, were also disposed of.
Case Title: Shankar vs State of Rajasthan
