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Monday, May 27

Dying declaration, requirement of certificate by Doctor not essential in every case

State of Madhya Pradesh vs. Dal Singh & Ors, Criminal Appeal No. 2303 of 2009, Decided on May 21, 2013


The Hon’ble Supreme Court held that:

The law on the issue can be summarised to the effect that law does not provide who can record a dying declaration, nor is there any prescribed form, format, or procedure for the same. The person who records a dying declaration must be satisfied that the maker is in a fit state of mind and is capable of making such a statement. Moreover, the requirement of a certificate provided by a Doctor in respect of such state of the deceased, is not essential in every case. Undoubtedly, the subject of the evidentiary value and acceptability of a dying declaration, must be approached with caution for the reason that the maker of such a statement cannot be subjected to cross-examination. However, the court may not look for corroboration of a dying declaration, unless the declaration suffers from any infirmity.” [Para 14]


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