Supreme Court Upholds Conviction Based on Reliable Dying Declaration Supported by Medical Evidence Despite High Burn Injuries

Case Name: Subramani v. State of Karnataka
Citation: 2026 INSC 249
Date of Judgment/Order: 17 March 2026
Bench: Hon’ble Mr. Justice Pankaj Mithal; Hon’ble Mr. Justice S.V.N. Bhatti

Held: The Supreme Court held that a dying declaration can be relied upon for conviction even in cases involving severe burn injuries, provided it is supported by medical evidence establishing that the deceased was in a fit condition to make the statement, and such declaration, when corroborated by other evidence, forms a reliable basis for conviction.

Summary: The case arose from a prosecution where the appellant was accused of pouring kerosene on his wife and setting her on fire following a domestic dispute. The Trial Court acquitted the appellant citing inconsistencies and doubts regarding the victim’s ability to make a statement due to extensive burn injuries, whereas the High Court reversed the acquittal and convicted him under Sections 302 and 498A IPC. Before the Supreme Court, the appellant challenged the reliability of the dying declaration and the High Court’s interference with acquittal. The Court examined the testimony of eyewitness PW-3 (daughter of the deceased), medical evidence of doctors who treated the victim, and the post-mortem findings, all of which consistently established that the deceased had suffered 80–90% burns but remained conscious and capable of making a statement. The Court noted that the dying declaration was recorded with medical certification of fitness and was corroborated by surrounding circumstances including recovery of kerosene and matchbox from the scene. It held that minor inconsistencies or absence of a nurse at the time of recording did not vitiate the declaration.

Decision: The Supreme Court dismissed the appeal, upheld the conviction and sentence awarded by the High Court under Sections 302 and 498A IPC, and directed the appellant, who was on bail, to surrender forthwith to undergo the remaining sentence, while disposing of all pending applications.