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Satpal v. State of Haryana

Criminal Appeal · 2021 INSC 143Decided 3 Mar 2021
Criminal Appeal No. 261 of 2021
Justice Ashok Bhushan · Justice R. Subhash Reddy

Background

The appellant's wife, Pooja Rani, suffered 90% burn injuries and was admitted to hospital; before she died a week later, a Judicial Magistrate recorded her dying declaration in which she stated that her husband had poured kerosene oil on her and set her on fire, allegedly under the influence of his sister-in-law. The Trial Court convicted the appellant under Section 302 IPC (murder) and sentenced him to life imprisonment, while other family members who were initially charge-sheeted were discharged earlier in the process. The Punjab and Haryana High Court upheld the conviction, and the appellant challenged this before the Supreme Court, arguing the dying declaration was "tutored" because the deceased's family members were present in the hospital at the time.

Decision Breakdown

The Supreme Court held that the dying declaration was natural, credible and properly recorded: the Magistrate had specifically ensured that family members were sent out of the room before recording the statement, and this was corroborated by the Magistrate's own testimony as well as the evidence of the deceased's mother and maternal uncle describing prior torture. The Court rejected the argument that mere presence of relatives in the hospital (natural in such circumstances) rendered the declaration tutored, and noted the appellant had not examined any defence witnesses despite claiming neighbours were present. Finding the evidence sufficient to establish guilt beyond reasonable doubt and no error in the concurrent findings of the Trial Court and High Court, the Supreme Court dismissed the appeal and upheld the life sentence.

Lesson Learnt

A dying declaration recorded by a judicial officer after ensuring the victim's relatives are excluded from the room is treated as strong, reliable evidence and can alone sustain a murder conviction: simply because relatives are nearby at a hospital does not make such a statement "tutored" in the eyes of the law.

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

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