Munuwa @ Satish Etc. vs. The State of Uttar Pradesh
Background
In 1979, a college principal was shot and later died, with a security guard also injured in the same incident. Three men were convicted of murder and sentenced to life imprisonment by the trial court in 1981, and the conviction was upheld by the Allahabad High Court only in 2010: nearly three decades later. The prosecution's case rested substantially on eyewitness testimony and two differing "dying declarations" made by the victim before he died.
Decision Breakdown
The Supreme Court found serious deficiencies undermining the conviction: the prosecution never explained the complete absence of blood stains at the alleged crime scene or produced the victim's blood-stained clothing; no empty cartridges, bullets/pellets, or the murder weapon were ever recovered, and no ballistics expert was examined despite the victim being shot seven times; and the victim's two dying declarations directly contradicted each other on the motive, the location of the attack, and who else was present, with the second declaration containing suspicious additions. Applying the rule that dying declarations must be consistent to be relied upon, and noting the trial court itself had rejected the later declaration as unreliable, the Court held the prosecution had not proved its case beyond reasonable doubt. It quashed the convictions and acquitted all the accused.
Lesson Learnt
A conviction, especially one carrying a life sentence, cannot rest on eyewitness accounts and dying declarations alone if the physical evidence (recoveries, forensic corroboration) that ought to exist is missing without explanation, and if the victim's own successive statements about what happened are inconsistent with each other.