Rajasthan Dowry Death Case: Supreme Court Acquits Accused Over Unreliable Dying Declaration

The case of State of Rajasthan vs. Mst. Ganwara revolved around the tragic death of a young woman named Shanti, who suffered severe burn injuries and later succumbed to them. The prosecution alleged that her mother-in-law, Ganwara, had set her on fire due to disputes over dowry. However, the Supreme Court upheld the Rajasthan High Court’s decision to acquit the accused, citing inconsistencies in the dying declaration and lack of corroborating evidence.

Background of the Case

On 5th September 1982, police received a call from P.B.M. Hospital, Bikaner, where Shanti had been admitted with severe burns. In her initial statement to the police, she alleged that her mother-in-law poured kerosene on her and set her ablaze due to disputes over dowry. However, in a subsequent statement recorded by a magistrate, Shanti made no mention of dowry harassment and stated that her mother-in-law had admitted her to the hospital.

The trial court convicted Ganwara under Section 302 IPC (murder) and sentenced her to life imprisonment. However, the Rajasthan High Court overturned the conviction, leading the State to appeal to the Supreme Court.

Arguments Presented

Prosecution’s Argument

• Shanti’s dying declaration to the police implicated the accused.
• The victim’s mother and siblings testified that Shanti had faced harassment over dowry demands.
• The trial court had convicted the accused based on the victim’s statements and circumstantial evidence.

Defense’s Stand

• The accused had no motive, and there was no independent evidence to prove dowry harassment.
• Shanti’s later statement before the magistrate contradicted her initial police statement.
• Witnesses who claimed to have heard Shanti’s accusations were her family members, making their testimonies unreliable.

High Court’s Ruling

The High Court found that the prosecution’s case lacked credibility due to contradictions in the dying declarations and the absence of neutral witnesses. It held:

“Under the circumstances of the case, it would be unsafe to confirm the guilt against the accused basing on the dying declaration.”

The High Court acquitted the accused, leading to the State’s appeal before the Supreme Court.

Supreme Court’s Verdict

The Supreme Court dismissed the appeal and upheld the acquittal, ruling:

“The intrinsic worth and reliability of dying declarations can be judged from their tenor and contents. Here, the dying declarations recorded at different times create a huge doubt on their veracity.”

The Court also noted that:

• The accused was reportedly away at a temple when the incident occurred.
• The prosecution witnesses were mostly the victim’s family members, making their testimony questionable.
• The magistrate’s dying declaration did not support the prosecution’s case.

The Court concluded:

“It is not the plurality of dying declarations that adds weight to the prosecution case, but their qualitative worth.”

Legal Significance

This ruling reinforces the principle that courts must scrutinize dying declarations carefully before relying on them for conviction. It emphasizes that multiple statements from the same victim do not automatically validate the prosecution’s case, especially if inconsistencies exist.

Conclusion

The Supreme Court’s decision serves as a significant precedent for cases involving dying declarations. It upholds the principle that convictions must be based on clear, consistent, and corroborated evidence, ensuring that justice is not compromised by unreliable testimony.

Petitioner Name: State of Rajasthan.
Respondent Name: Mst. Ganwara.
Judgment By: Justice N.V. Ramana, Justice Mohan M. Shantanagoudar.
Place Of Incident: Bikaner, Rajasthan.
Judgment Date: 28-08-2018.

Don’t miss out on the full details! Download the complete judgment in PDF format below and gain valuable insights instantly!

Download Judgment: State of Rajasthan vs Mst. Ganwara Supreme Court of India Judgment Dated 28-08-2018.pdf

Direct Downlaod Judgment: Direct downlaod this Judgment

See all petitions in Murder Cases
See all petitions in Dowry Cases
See all petitions in Judgment by N.V. Ramana
See all petitions in Judgment by Mohan M. Shantanagoudar
See all petitions in dismissed
See all petitions in supreme court of India judgments August 2018
See all petitions in 2018 judgments

See all posts in Criminal Cases Category
See all allowed petitions in Criminal Cases Category
See all Dismissed petitions in Criminal Cases Category
See all partially allowed petitions in Criminal Cases Category