Murder Conviction Overturned: Supreme Court Acquits Accused in Dying Declaration Case

The Supreme Court of India recently ruled on a significant case involving the conviction of an individual based on a dying declaration. The case, Balaji vs. The State of Maharashtra, revolved around the murder of a woman, allegedly by her brother, over a dispute concerning her personal life. The central issue in the appeal was whether the conviction was sustainable in the absence of reliable corroborative evidence and considering that the dying declaration had inconsistencies.

Balaji, the accused, was convicted by the Sessions Court and sentenced to life imprisonment under Section 302 of the Indian Penal Code (IPC). The Bombay High Court upheld the conviction. However, the Supreme Court examined the authenticity of the dying declaration, the medical condition of the deceased at the time of recording her statement, and the motive behind the crime before arriving at its final decision.

Background of the Case

The case dates back to 28 August 2006, when Lata, the deceased, was brutally stabbed multiple times. According to the prosecution, Balaji, her brother, attacked her in a fit of rage over her alleged illicit relationship with Mahendra Dhaware. The prosecution’s case relied heavily on Lata’s dying declaration, where she purportedly named Balaji as her assailant.

However, the defense argued that there were several inconsistencies in the prosecution’s version. The dying declaration had been altered, medical records indicated that Lata was semi-conscious and in no condition to provide a detailed statement, and there was no independent verification of the declaration by a magistrate. Moreover, the defense pointed out that Balaji had voluntarily gone to the police station without attempting to flee, which suggested his innocence.

Petitioner’s Arguments

The defense, representing Balaji, made the following key arguments:

• Alleged Tampering of the Dying Declaration: The defense contended that the dying declaration was manipulated. Initially, it contained the name of Mahendra Dhaware, but this was later struck off and replaced with Balaji’s name. This alteration cast serious doubt on the credibility of the document.
• Medical Condition of the Deceased: Lata had sustained 24 stab wounds, some of which were life-threatening. Medical records showed that she was semi-conscious, suffering from hemorrhagic shock, and struggling to breathe. The defense questioned how she could have given such a detailed statement in this condition.
• Absence of Magistrate Verification: The defense emphasized that the dying declaration had not been recorded in the presence of a magistrate, making it unreliable. The law mandates that a dying declaration should ideally be recorded by a magistrate to ensure its authenticity.
• Lack of Motive: The prosecution claimed that Balaji killed his sister because he was outraged by her relationship with Mahendra Dhaware. However, the defense pointed out that Balaji had known about the relationship for years and had never objected before. There was no immediate provocation leading to the alleged murder.
• Voluntary Surrender: The defense highlighted that Balaji voluntarily walked into the police station in bloodstained clothes, carrying a knife. If he had committed the crime in a fit of rage, he would likely have attempted to escape rather than surrender.

Respondent’s Arguments

The prosecution, representing the State of Maharashtra, countered these claims with the following arguments:

• Reliability of the Dying Declaration: The prosecution argued that the dying declaration was recorded in the presence of a doctor, who confirmed that the victim was conscious at the time. It maintained that Lata was in a fit state to provide a statement.
• Accused’s Bloodstained Clothes and Knife: The prosecution emphasized that Balaji arrived at the police station wearing bloodstained clothes and carrying the murder weapon. This was presented as strong circumstantial evidence linking him to the crime.
• Pre-existing Tensions: According to the prosecution, Balaji was angered by his sister’s relationship and had previously confronted her about it. This supported the argument that he had a motive for the crime.

Supreme Court’s Observations

The Supreme Court scrutinized the prosecution’s evidence and noted serious inconsistencies:

“The dying declaration has been tampered with. Though the name of Mahendra was written earlier, it was struck off, and in its place, the name of Balaji is inserted. No valid reason is forthcoming from the side of the prosecution for tampering with a vital document.”

The Court also examined the medical records and expressed doubts about the deceased’s ability to provide a coherent and detailed statement:

“The patient had multiple stab injuries, haemorrhage, and was in distress. In such a condition, it is highly doubtful whether she could have given such a detailed statement.”

The Court further emphasized the importance of ensuring that dying declarations meet strict evidentiary standards:

“A dying declaration must be wholly reliable, and if there is any suspicion regarding its authenticity, it cannot be the sole basis for conviction.”

Final Judgment

After a thorough review of the evidence, the Supreme Court ruled:

• The dying declaration was unreliable due to tampering and lack of independent verification.
• The prosecution failed to establish a clear motive, as Balaji had not objected to his sister’s relationship in the past.
• There was no direct evidence linking Balaji to the crime, and the prosecution’s case appeared to have inconsistencies.

The Supreme Court overturned the conviction and ordered Balaji’s immediate release:

“The prosecution has not proved its case beyond a reasonable doubt. The accused is acquitted of all charges.”

Implications of the Verdict

This ruling has significant legal implications:

• Strict Scrutiny of Dying Declarations: Courts must ensure that dying declarations are free from manipulation and recorded under proper judicial supervision.
• Protection Against Wrongful Convictions: The judgment reinforces the principle that no individual should be convicted based on unreliable evidence.
• Judicial Oversight in Evidence Collection: The case highlights the necessity of independent verification by magistrates in recording crucial statements.

The Supreme Court’s decision reinforces the principle that justice must be based on credible and legally admissible evidence, ensuring fairness in criminal trials.

Petitioner Name: Balaji.
Respondent Name: The State of Maharashtra.
Judgment By: Justice N.V. Ramana, Justice Mohan M. Shantanagoudar, Justice S. Abdul Nazeer.
Place Of Incident: Latur, Maharashtra.
Judgment Date: 14-03-2019.

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