News Delhi : The Supreme Court of India has held that the absence of strong proof of motive does not weaken the prosecution case when there is direct and reliable evidence in the form of a credible dying declaration. Setting aside an acquittal by the Himachal Pradesh High Court, the Court restored the conviction of a man for murdering his wife by setting her on fire.
A Bench comprising Justice B. V. Nagarathna and Justice R. Mahadevan delivered the judgment on January 15, 2026, while allowing a criminal appeal filed by the State of Himachal Pradesh against the High Court’s 2014 acquittal order.
The prosecution alleged that on December 7, 2009, Chaman Lal poured kerosene on his wife, Saro Devi, at their residence in Village Rampur, District Chamba, Himachal Pradesh, and set her on fire by lighting a matchstick. Villagers rushed to the spot on hearing her cries, and the accused also attempted to extinguish the fire. The deceased suffered about 70 percent burn injuries, while the accused sustained minor burns on his hand. Despite prolonged treatment, Saro Devi succumbed to her injuries on January 15, 2010.
On December 8, 2009, the Tehsildar-cum-Executive Magistrate recorded the dying declaration of the deceased in hospital after obtaining medical certification of her fitness. In her statement, she categorically stated that her husband had set her on fire after insulting her by calling her a “Kanjri” (woman of bad character).
Following investigation, a chargesheet under Section 302 IPC was filed. The Sessions Court, Chamba, convicted the accused and sentenced him to life imprisonment with a fine of ₹50,000. However, the Himachal Pradesh High Court set aside the conviction, extending the benefit of doubt to the accused.
The Supreme Court examined the limits of appellate interference with acquittal orders, reiterating that while such interference is exercised sparingly, it is justified where the High Court adopts a perverse or legally erroneous approach, misreads material evidence, or ignores vital circumstances leading to miscarriage of justice.
On the evidentiary value of dying declarations under Section 32(1) of the Indian Evidence Act, the Court relied on settled precedents to reiterate that a dying declaration can form the sole basis of conviction if it is voluntary, truthful, and reliable, and that corroboration is not a mandatory rule of law.
The Bench found that the dying declaration in the present case inspired full confidence. It was recorded by a neutral public officer after medical certification, the deceased was conscious and oriented, and there was no material suggesting tutoring, coercion, or manipulation. The Court rejected the High Court’s reliance on minor discrepancies regarding the timing of the recording and its hyper-technical doubts about the manner of recording.
Addressing the defence plea of self-immolation and reliance on hostile and defence witnesses, the Court held that such testimony could be accepted only to the extent it was corroborated by reliable evidence, which was absent in this case. The accused’s act of attempting to extinguish the fire and sustaining minor burns did not exonerate him and could equally be consistent with post-offence conduct.
Crucially, the Court held that motive assumes importance mainly in cases based on circumstantial evidence. Where there is direct evidence in the form of a trustworthy dying declaration, failure to establish motive with precision is not fatal to the prosecution. The Court also noted that evidence on record disclosed frequent quarrels, humiliation, and verbal abuse by the accused, providing a plausible background for the offence.
Concluding that the dying declaration was voluntary, truthful, and reliable, the Supreme Court held that the prosecution had proved the offence under Section 302 IPC beyond reasonable doubt. It set aside the High Court’s judgment, restored the trial court’s conviction and sentence, and directed the accused to surrender forthwith to undergo the remaining sentence, failing which coercive steps would follow.
Case Title: State of Himachal Pradesh v. Chaman Lal