Supreme Court Reinforces Reliability Standards for Dying Declarations and Upholds Acquittals in MANJUNATH v. State of Karnataka

Introduction

MANJUNATH v. State of Karnataka (2023 INSC 978) is a landmark judgment delivered by the Supreme Court of India on November 6, 2023. The case revolves around the reliability and admissibility of dying declarations in criminal proceedings, specifically addressing the standards required for such declarations to form the sole basis for conviction. The appellants, six individuals accused of grievous assault leading to death, challenged the High Court of Karnataka's conviction based primarily on a dying declaration. The Supreme Court's comprehensive analysis and eventual decision to restore the acquittals underscore the judiciary's commitment to safeguarding the principles of justice and the presumption of innocence.

Summary of the Judgment

The appellants, six in number, were convicted by the High Court of Karnataka under various sections of the Indian Penal Code (IPC) for grievous assault leading to the death of the deceased, T.V. Byregowda. The High Court's conviction was predominantly based on a dying declaration made by the deceased and corroborated by secondary evidence. However, upon appealing to the Supreme Court, the appellants contended that the dying declaration lacked reliability due to procedural irregularities and inconsistencies in witness testimonies. The Supreme Court meticulously examined the evidence, emphasizing the stringent requirements for accepting dying declarations as sole evidence. Conclusively, the Supreme Court set aside the High Court's conviction, reinstating the original acquittals pronounced by the trial court, thereby highlighting the necessity for robust and unequivocal evidence in criminal convictions.

Analysis

Precedents Cited

The Supreme Court extensively referred to established jurisprudence to substantiate its stance on dying declarations and evidentiary reliability:

Laxman v. State of Maharashtra (2002): Emphasized the inherent reliability of dying declarations, given the premise that an individual on the verge of death is unlikely to fabricate statements.
Sharad Birdhichand Sarda v. State of Maharashtra (1984): Laid down the foundational principles governing circumstantial evidence, reinforcing that it must unequivocally point to the accused's guilt while excluding all other hypotheses.
Jayamma v. State of Karnataka (2021): Highlighted that dying declarations need not necessarily be recorded before a Magistrate but should be free from coercion and ensuring their authenticity.
Amol Singh v. State Of M.P. (2008): Stressed that the reliability of a dying declaration takes precedence over its quantity, advocating for consistency and voluntariness in such statements.
Rai Sandeep @ Deepu alias Deepu v. State (NCT of Delhi) (2012): Defined the attributes of a "sterling witness," whose testimony can be relied upon without corroboration.
Sheo Swarup v. King Emperor (1934) and Ghurey Lal v. State of U.P. (2008): Reinforced the sanctity of the presumption of innocence and the high threshold required for overturning acquittals.

Legal Reasoning

The Supreme Court's legal reasoning was anchored in a meticulous evaluation of the dying declaration's authenticity and the overall evidentiary framework presented by the prosecution. Key aspects of their reasoning included:

Authenticity of Dying Declaration: The Court scrutinized the procedural integrity of the dying declaration, noting that the individual who recorded the statement was not examined, and the declaration lacked proper endorsement by a qualified authority.
Reliability of Witnesses: The testimonies of eyewitnesses were found riddled with inconsistencies and contradictions, undermining their credibility. The Court emphasized that for a witness to be deemed reliable, their testimony must be consistent, free from bias, and corroborated by other evidence.
Circumstantial Evidence: Although circumstantial evidence was presented, the Court determined that it did not conclusively establish the guilt of the accused beyond reasonable doubt. The lack of a clear nexus between the accused's possession of weapons and the nature of the injuries further weakened the prosecution's case.
Presumption of Innocence and Finality of Acquittals: Upholding the sanctity of acquittals, the Court reiterated that acquittals should only be overturned in the presence of compelling and unassailable evidence, which was not met in this case.

Impact

This judgment has profound implications for future criminal litigations, particularly those relying heavily on dying declarations. It reinforces the judiciary's stringent approach towards ensuring that such declarations are credible and free from procedural lapses. Key impacts include:

Elevated Scrutiny on Dying Declarations: Courts will now adhere to even more rigorous standards when evaluating the authenticity and reliability of dying declarations, ensuring that they meet all legal prerequisites.
Protection Against Unwarranted Convictions: By reinstating acquittals where evidence is found lacking, the judgment safeguards against miscarriages of justice, ensuring that individuals are not wrongfully convicted based on flawed evidence.
Guidance for Procedural Adherence: Law enforcement and prosecution attorneys will be guided to uphold strict procedural norms when recording and validating dying declarations, thus enhancing the overall quality of evidence presented in trials.
Reinforcement of Presumption of Innocence: The judgment reinforces the fundamental legal principle that an accused is presumed innocent until proven guilty beyond a reasonable doubt, thereby influencing the judicial approach in future cases.

Complex Concepts Simplified

Dying Declaration

A dying declaration is a statement made by a person who believes they are about to die, relating to the cause or circumstances of their impending death. Under Section 32 of the Indian Evidence Act, 1872, such declarations are admissible as evidence in court, even though they are considered hearsay because they are statements made out of the presence of the accused and not subject to cross-examination.

Circumstantial Evidence

This type of evidence relies on an inference to connect it to a conclusion of fact, such as a fingerprint at the crime scene. It is not direct evidence like eyewitness testimony but can be powerful when multiple pieces of circumstantial evidence converge to point towards a specific conclusion.

Ocular Evidence

Also known as eyewitness testimony, ocular evidence refers to the testimony given by individuals who directly observed the events in question. Its reliability depends on the witness's ability to observe without bias or distortion.

Presumption of Innocence

A fundamental principle of criminal law where the accused is considered innocent until proven guilty. This principle places the burden of proof on the prosecution to establish the accused's guilt beyond a reasonable doubt.

Conclusion

The Supreme Court's judgment in MANJUNATH v. State of Karnataka serves as a pivotal reference point for the admissibility and reliability of dying declarations in Indian jurisprudence. By meticulously evaluating the procedural integrity and consistency of the evidence, the Court has underscored the necessity for unwavering standards in criminal convictions. This decision not only reinforces the importance of robust and corroborative evidence but also safeguards the rights of the accused against potential miscarriages of justice. Moving forward, this judgment is poised to influence the handling of similar cases, ensuring that convictions are grounded in indisputable and reliable evidence, thereby fortifying the pillars of justice and the presumption of innocence within the legal framework.