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State of Punjab vs Randhir Singh Etc.

Not available · 2024 INSC 489Decided 9 Jul 2024
Not available
Justice Aravind Kumar · Justice Sandeep Mehta

Background

The accused, Randhir Singh, his mother, brother and sister-in-law were tried for the death of Randhir's wife, who died of extensive burn injuries in 1998. The trial court convicted all four accused of murder based on two competing accounts of a "dying declaration" made by the victim before her death, but the High Court of Punjab and Haryana reversed the conviction and acquitted everyone, prompting the State of Punjab to appeal to the Supreme Court.

Decision Breakdown

The Supreme Court scrutinised the two conflicting dying declarations and found serious inconsistencies: key eyewitnesses who claimed to be with the victim never mentioned any dying declaration being recorded, doctors found no evidence of kerosene smell or burns consistent with the prosecution's story, and one declaration (recorded by a police officer allegedly influenced by the victim's brother, himself a policeman) appeared to be a fabricated, post-investigation document. Defence witnesses and a version of the victim's own statement instead suggested she caught fire accidentally while making tea, and her husband had rushed her to hospital rather than caused her death. Finding the High Court's acquittal was a sound appreciation of the evidence, the Supreme Court dismissed the State's appeal and upheld the acquittal.

Lesson Learnt

A conviction cannot rest on a dying declaration alone if it is inconsistent, uncorroborated, or shows signs of being tailored by interested parties. Courts must carefully test such evidence against independent facts before treating it as conclusive proof of guilt.

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

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