The Supreme Court of India upheld the conviction of a man for murdering his wife by setting her on fire, holding that a dying declaration recorded with a doctor’s certification regarding the victim’s mental fitness is reliable evidence.
The Bench of Justice Pankaj Mithal has observed that the evidence on record conclusively proved the guilt of the accused. It upheld the High Court’s judgment convicting the husband for offences under Sections 302 and 498A IPC and dismissed the appeal as devoid of merit.
The case arose from an incident in July 2000 involving a married couple who had been living together for nearly seventeen years and had four children. According to the prosecution, the relationship between the spouses had deteriorated over the years due to frequent quarrels and persistent monetary demands made by the husband.
On the night of July 20, 2000, the husband allegedly quarreled with his wife over money. In a fit of anger, he reportedly brought kerosene, poured it on her inside the bathroom of their house, and set her ablaze. The woman sustained severe burn injuries and was rushed to Victoria Hospital by neighbours and family members. She succumbed to her injuries three days later on July 24, 2000.
Following her death, an FIR was registered under Sections 302 (murder) and 498A (cruelty by husband) of the Indian Penal Code.
During the trial, the Trial Court acquitted the accused primarily on the ground that the prosecution evidence contained inconsistencies. The court also expressed doubts about the dying declaration allegedly made by the victim, noting that she had suffered more than 80–90% burns and might not have been in a condition to give a statement.
The Trial Court further reasoned that the bathroom where the incident allegedly took place was very small, making it improbable for two persons to be present inside at the same time. Based on these factors, the court extended the benefit of doubt to the accused.
The State appealed against the acquittal before the High Court. The High Court reversed the Trial Court’s decision and convicted the accused under Sections 302 and 498A IPC.
He was sentenced to life imprisonment for murder and two years’ simple imprisonment for cruelty, along with fines under both provisions. The accused then approached the Supreme Court challenging the High Court’s decision.
The Supreme Court examined several crucial pieces of evidence, including the testimony of the couple’s 16-year-old daughter, who stated that she had witnessed the incident. According to her testimony, her father poured kerosene on her mother and set her on fire after a heated quarrel.
Medical evidence also played a vital role. Doctors who treated the victim testified that she had sustained around 80% burn injuries but remained conscious when admitted to the hospital. One of the doctors certified that she was in a fit condition to give a statement when the police recorded her dying declaration in the hospital.
The dying declaration recorded by the police officer stated that the husband had poured kerosene on her and set her on fire following a dispute over money.
The Supreme Court found no reason to doubt the dying declaration since it had been recorded with the permission of the attending doctor, who certified that the victim was mentally fit to give a statement.
The Court also noted that the testimony of the couple’s daughter, the medical evidence, and the recovery of a kerosene tin, matchbox, and burnt clothes from the scene strongly corroborated the prosecution’s version.
Rejecting the defence argument that the victim could not have been conscious due to severe burns, the Court held that the doctors’ testimony clearly established that she was capable of making a statement.
The Court also directed the appellant, who was on bail during the pendency of the appeal, to surrender immediately to undergo the remaining sentence
Case Details
Case Title: Subramani Versus State of Karnataka
Case No.: Criminal Appeal No. 2432 Of 2010
Date: 17/03/2026
