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Sampat Babso Kale & Anr. v. The State of Maharashtra

Criminal Appeal · 2019 INSC 481Decided 9 Apr 2019
Criminal Appeal Nos. 694-695 of 2011
Justice S.A. Bobde · Justice Deepak Gupta

Background

The appellants, a husband and his sister, were tried for the murder of the husband's wife, who died of 98% burn injuries. The prosecution's case rested on two dying declarations alleging the appellants poured kerosene on her and set her on fire because she could not conceive; the defence claimed she committed suicide after being asked to go live with her in-laws in a village she found materially lacking. The Trial Court acquitted the appellants, giving them the benefit of the doubt, but the Bombay High Court reversed this, calling the trial court's reasoning "perverse," and convicted both appellants under Sections 302/498A read with Section 34 IPC with life imprisonment, leading to this appeal before the Supreme Court.

Decision Breakdown

The Supreme Court found genuine doubt about whether the victim was in a fit mental state to give a reliable dying declaration, given medical evidence that severe burns combined with painkillers could cause delusion, and held that in such circumstances corroborating evidence was needed. It identified several facts undermining the prosecution's version: physical evidence showed the fire occurred in the kitchen rather than the bedroom as alleged; the victim's mangalsutra and other ornaments an Indian married woman would not normally remove were found left behind, supporting the suicide theory; and the prosecution failed to examine any neighbours, including the one who accompanied the husband to seek an ambulance, leaving the dying declaration uncorroborated. The Court held the Trial Court's finding of reasonable doubt was not "perverse" but a proper appreciation of evidence, restored the acquittal, allowed the appeals, and ordered the imprisoned appellant's immediate release.

Lesson Learnt

An appellate court cannot overturn a trial court's acquittal merely by disagreeing with its weighing of the evidence: it must show the trial court's view was genuinely perverse; and a dying declaration, especially where the declarant's fitness of mind is in doubt, needs corroboration from other available witnesses before it can safely found a conviction.

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

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