Subramani v. State of Karnataka 2026 INSC 249 - Dying Declaration

Indian Evidence Act 1872 - Section 32 - In this case, IO deposed that the deceased was not in a conscious state of mind - SC observed : That would not override the statement of the doctors who treated the deceased, especially the one who was on duty and had permitted the police to record the statement of the deceased on being satisfied that she was in a fit condition to make a statement. [Context: The Supreme Court upheld the Karnataka High Court’s reversal of acquittal and confirmed the conviction of Subramani under Sections 302 and 498A IPC for burning his wife Chennamma to death after years of cruelty and demands for money. Relying on the eyewitness testimony of their 16‑year‑old daughter, the medical evidence, recovery of kerosene and matchbox from the scene, and a duly certified dying declaration recorded in hospital, the Court found the prosecution case fully proved. It held that minor discrepancies and the opinion of some witnesses about the victim’s consciousness could not override the clear evidence of the treating doctors and the consistent account that the husband poured kerosene and set her on fire.]