State of Himachal Pradesh v. Chaman Lal
Background
A wife suffered fatal burn injuries after allegedly being set alight by her husband; she named him in a dying declaration before dying over a month later. The Trial Court convicted him of murder; the High Court acquitted him, doubting the declaration's reliability.
Decision Breakdown
The Supreme Court restored the conviction, holding the dying declaration was voluntary and reliable, and the High Court wrongly discarded it over minor, adequately-explained discrepancies. A dying declaration alone can support a murder conviction without corroboration if it inspires confidence.
Lesson Learnt
A dying declaration can by itself convict someone of murder if reliable: minor inconsistencies in surrounding testimony don't automatically discredit it.