Supreme Court of India has emphasized the need to avoid overreliance on dying declarations as the sole basis for convicting individuals in criminal cases. The ruling came in the case of Irfan alias Naka vs. State of Uttar Pradesh, shedding light on the potential inaccuracies and doubts surrounding such declarations.

Dying declarations, which are statements made by individuals recounting the circumstances leading to their impending death, have been a significant aspect of criminal trials. However, the Court, comprising Justices BR Gavai, JB Pardiwala, and Prashant Kumar Mishra, has outlined important considerations that should be taken into account when assessing the weightage of a dying declaration in court proceedings.

The Court's decision revolves around eleven key factors that judges should carefully evaluate before relying on a dying declaration for a conviction. These factors encompass the circumstances under which the declaration was made, the timing of the statement, potential doubts about its authenticity, external influences, proper documentation, clear observation of the incident, consistency in the statement, voluntariness, and the mental state of the declarant, among others.

The Court stressed that there cannot be a one-size-fits-all approach to accepting dying declarations, and it is the responsibility of the courts to meticulously analyze their credibility based on the specifics of each case. The ruling notably led to the acquittal of Irfan, a death-row prisoner, as doubts arose about the accuracy and manner in which the dying declarations had been recorded initially.

While acknowledging the significance of dying declarations, the Court highlighted their reliability rooted in ethical and religious beliefs, particularly in cases where the victim is the sole witness. However, it firmly stated that these declarations must be both voluntary and truthful, originating from a mentally sound victim.

In its decision, the Supreme Court maintained that although dying declarations can serve as evidence, doubts regarding their credibility must prompt courts to seek corroborative evidence. The Court strongly cautioned against securing convictions solely based on dying declarations, especially when uncertainties loom over their accuracy.

Representing the accused in the case, Senior Advocate Gopal Sankaranarayanan argued against the validity of the dying declarations. On the other side, the Additional Advocate General, Ardhendumauli Kumar Prasad, appeared on behalf of the Uttar Pradesh government.

Case Title: Irfan alias Naka vs. State of Uttar Pradesh