April 20, 2001 : The Chhattisgarh High Court has upheld the conviction and life sentence of Ram Bai, who was found guilty of killing her sister-in-law, Vidya Bai, by setting her on fire during a domestic quarrel in 1998.
Justice R.S. Garg, delivering the judgment, dismissed the appeal filed by Ram Bai against the Sessions Court’s verdict from 2000, which had sentenced her to life imprisonment under Section 302 of the Indian Penal Code.
The case dates back to October 8, 1998, when a domestic dispute in a Raipur household turned tragic. According to the prosecution, Ram Bai poured kerosene oil on her sister-in-law, Vidya Bai, while she was cooking and set her ablaze. Vidya Bai sustained 85 percent burn injuries and later succumbed at the hospital on October 13, 1998.
Her husband, Balram, who tried to rescue her, suffered minor burns. Multiple dying declarations recorded before police and a magistrate consistently named Ram Bai as the attacker. Doctors confirmed that the victim was conscious and in a fit mental state when she gave her statements.
The defense argued that the fire was accidental and that the dying declarations were unreliable, claiming the victim was influenced by her mother to falsely implicate the accused. However, the court rejected these claims, noting that the declarations were consistent, recorded properly, and supported by medical and witness evidence.
Justice Garg emphasized that there was no evidence of tutoring or fabrication and found the defense witnesses, including the victim’s husband, unreliable due to inconsistencies and unnatural conduct. The court also dismissed a forensic expert’s late opinion, finding it speculative and unsupported by facts.
Citing Supreme Court precedents, the court reiterated that a truthful and voluntary dying declaration can form the sole basis for conviction if found reliable.
“The dying declarations recorded in this case were genuine and made when the deceased was in a fit mental condition,” Justice Garg observed, affirming the trial court’s findings.
With this ruling, the High Court confirmed Ram Bai’s conviction and life sentence, bringing closure to a case that revolved around domestic conflict, forensic debate, and the critical weight of a dying declaration in criminal law.
Case Reference : Criminal Appeal No. 1873/2000, Ram Bai vs. State of M.P.; Counsel for the Appellant/Petitioner/Plaintiff: Shri B.P. Sharma, Advocate.

