Introduction:

In a pivotal judgment, the Supreme Court affirmed the conviction of an accused under Section 302 of IPC, solely relying on the dying declaration of the deceased victim. The case, titled “NAEEM VERSUS STATE OF UTTAR PRADESH,” presented the court with the task of evaluating the credibility and trustworthiness of the dying declaration in determining the accused’s guilt. The Bench, comprised of Justices B.R. Gavai and Sandeep Mehta, referenced legal precedents and emphasized the importance of ensuring the deceased’s fit mental state during the declaration. The court’s decision sheds light on the admissibility of dying declarations as standalone evidence in criminal cases.

Arguments:

The accused/appellant contested the reliance on the dying declaration, asserting that it was recorded after the victim’s discharge from the hospital, raising doubts about her mental state. The defense argued that such declarations must be scrutinized carefully, especially when recorded post-hospital discharge. In response, the prosecution highlighted the victim’s conscious and fit state during the statement, supported by medical certifications.

Court’s Judgement:

The Supreme Court dismissed the appellant’s contention, emphasizing that the dying declaration was made in a fit state of mind and was free from external influence. Citing medical certifications, the court established the victim’s consciousness and fitness at the time of the declaration. The judgment emphasized that, when satisfied about the declaration’s truthfulness and voluntariness, the court can base a conviction without additional corroboration. The court’s detailed scrutiny affirmed the dying declaration’s coherence, consistency, and reliability, ultimately sustaining the accused’s conviction under Section 302 of IPC.