State of Madhya Pradesh v. Ramveer Singh
Background
Ramveer Singh was accused of pouring kerosene on a young woman and setting her on fire, allegedly in revenge because the victim's family had reported his son for raping her. The victim died of her burns the same evening after a dying declaration was recorded at the hospital. The Trial Court convicted him of murder and house-trespass based on that dying declaration and the testimony of the victim's grandmother, an alleged eyewitness. The Madhya Pradesh High Court, however, reversed the conviction and acquitted him, finding both pieces of evidence unreliable, and the State appealed to the Supreme Court against that acquittal.
Decision Breakdown
The Supreme Court closely examined the circumstances of the dying declaration's recording and agreed with the High Court that it was highly unsafe to rely on it: the doctor present admitted the victim's pulse and blood pressure were not even measurable at the time, her voice was barely audible, and two witnesses present had to interpret and relay what she was saying, raising real doubt about whether the statement genuinely and accurately reflected her own words. The alleged eyewitness account had already been disbelieved by both the Trial Court and the High Court. The Supreme Court reiterated the settled rule that in an appeal against an acquittal, interference is warranted only if the acquittal is perverse and the evidence permits no view other than guilt; here, given the serious doubts riddling the prosecution's case, that high threshold was not met, and the appeal was dismissed.
Lesson Learnt
A dying declaration carries great weight in law, but only if it is recorded in circumstances that genuinely inspire confidence in the victim's physical and mental capacity to make a clear statement; where doubt surrounds how it was recorded, courts will not treat it as conclusive proof. Appellate courts also give real deference to an acquittal. They will not overturn it just because a different view was also possible on the same evidence.