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Gorabai vs. The State of Madhya Pradesh

Criminal Appeal · 2022 INSC 734Decided 20 Jul 2022
Criminal Appeal No. 1293 of 2018
Sanjiv Khanna · Bela M. Trivedi

Background

Nandabai and her three minor daughters suffered fatal burn injuries at their home in 1996. Before dying, Nandabai made both an oral dying declaration to family members and a written dying declaration recorded by a police officer, naming her mother-in-law Seventibai, Kalabai, Gaurabai (also called Gorabai), Natwar and Hosilal as the people who poured kerosene and set them on fire. The accused were convicted by the trial court and their conviction was upheld by the High Court, leading to this appeal before the Supreme Court.

Decision Breakdown

The Supreme Court examined the dying declarations and found them fully corroborated by multiple eyewitnesses, medical evidence, and evidence of motive (a family dispute over alleged illicit relations). The Court held that minor discrepancies between different witnesses' accounts of the dying declaration did not undermine the core, consistent narrative implicating the accused. Since the two dying declarations (oral and written) and surrounding circumstantial evidence formed a cohesive and credible chain, the Court found no reason to interfere with the concurrent findings of guilt. The appeals were dismissed and the convictions and sentences were upheld.

Lesson Learnt

A dying declaration, when consistent across multiple witnesses and corroborated by independent evidence (medical reports, motive, recovered material), can be strong enough to sustain a conviction even where individual witnesses have minor variations in their testimony. Courts look at the substance of corroboration, not trivial inconsistencies.

Official source (sci.gov.in)View Judgment (PDF)

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