A voluntary and reliable dying declaration constitutes a valid sole basis for conviction.

The appellant, Jawanji (the deceased's uncle), visited the house of the deceased, Pushpaben, on 14/08/2011.

He pressured her to divorce her husband, Kanubhai (PW5), to remarry another person for a sum of ₹50,000

Upon her refusal, the appellant beat her.

When she retreated to the second floor, the appellant followed, poured kerosene from a primus, and set her ablaze with a matchstick before fleeing the scene

The deceased was treated at Civil Hospital, Ahmedabad, where she succumbed to septicemia due to burn injuries on 18/08/2011

The Trial Court convicted the appellant under Section 302 of the IPC on 23.09.2013, sentencing him to life imprisonment

The appellant challenged this conviction on grounds of procedural irregularities in recording the dying declaration and lack of corroborating evidence

1. Whether the dying declaration recorded by the Executive Magistrate was reliable and followed the requisite procedural safeguards regarding the declarant's fitness of mind?

2. Whether the prosecution proved the guilt of the appellant beyond reasonable doubt based on the consistency between the dying declaration, medical history, and ocular testimony?

The court primarily applied Section 302 of the Indian Penal Code regarding punishment for murder

It relied on the evidentiary value of a dying declaration, citing the Supreme Court precedent in Poonam Bai v. State of Chhattisgarh (2018), which established that a dying declaration can be the sole basis for conviction if it is truthful, voluntary, and inspires confidence, even if a doctor's certification is missing, provided the recorder is satisfied with the declarant's fitness

The court also considered Section 374 of the CrPC regarding the right to appeal

The Court found the dying declaration recorded by the Executive Magistrate (PW3) highly credible as it was in a question-answer format and supported by a medical endorsement of the declarant's "fit state of mind"

This was further corroborated by the medical "history" given by the deceased to the treating doctors (PW7 and PW8), where she consistently named the appellant as the assailant

The ocular testimony of the husband (PW5) established the appellant's presence at the scene, the motive (financial gain through forced remarriage), and the fact that the appellant fled immediately after the cries of the deceased were heard

The Court rejected the defense's argument regarding procedural lapses, noting that the Magistrate and doctors concurrently verified the victim's consciousness

The absence of burn injuries on the appellant did not create reasonable doubt given the sequence of events and spatial dimensions of the room

The Court held that the prosecution successfully proved the entire chain of events—motive, presence at the spot, and the homicidal act—through consistent oral, documentary, and scientific evidence

The appellant, who was on bail, was granted six weeks to surrender before the jail authorities