VidhiSangh

Supreme Court of India · 03/03/2021

SATPAL versus STATE OF HARYANA

[2021] 2 S.C.R. 493 · 2021 INSC 143

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Summary

The Supreme Court upheld the husband’s murder conviction based on a natural and credible dying declaration recorded by a Magistrate and corroborative testimony. The victim was fit to make the statement despite severe burns. Relatives had reached the hospital but were excluded when it was recorded; their presence elsewhere did not establish tutoring. The prosecution evidence established guilt beyond reasonable doubt, and the concurrent findings warranted no interference.

Issues

  1. Whether relatives’ presence at the hospital rendered the dying declaration tutored or unreliable.
  2. Whether the evidence sustained the murder conviction.

Held

Result

Criminal appeal dismissed; murder conviction and sentence upheld.

Judgment PDF: Supreme Court of India, [2021] 2 S.C.R. 493.