Facts: The case involves the death of an elderly couple following a fire that gutted their shanty on 23.11.2016. The prosecution alleged that the younger son (A1) and daughter-in-law (A2) intentionally set the hut ablaze due to a property dispute. The prosecution's case rested heavily on multiple oral and written dying declarations made by the mother before she succumbed to her injuries. The defense contended that the fire was accidental, caused by a gas cylinder burst, and that the accused were being falsely implicated by the elder son and a neighbor to exclude A1 from his ancestral property share.
Procedural Posture: The Trial Court convicted the accused for murder and arson. On appeal, the High Court set aside the conviction and acquitted the accused. The elder son of the deceased (the appellant herein) challenged the acquittal before the Supreme Court of India.
Issue: Whether the multiple dying declarations were reliable enough to sustain a conviction and whether the investigation and trial process adhered to the established principles of criminal jurisprudence.
Holding: No, the appeal is dismissed, and the High Court's order of acquittal is affirmed.
Reasoning: The Court reasoned that the dying declarations lacked credibility as they were recorded amidst a crowd of interested witnesses and without medical certification of a "fit state of mind". The Investigating Officer (I.O.) failed to conduct a forensic examination of the scene or prepare a scene mahazar, leaving the cause of fire (arson vs. accident) unverified. Furthermore, the Trial Court committed a grave procedural error by failing to put incriminating circumstances to the accused during their examination under Section 313 of the Cr.P.C. The Court emphasized that while a dying declaration can be the sole basis of conviction, it must inspire full confidence and be free from tutoring. The evidence in this case moved only from "maybe true" to "not proven", falling short of the "must be true" standard required for criminal conviction.