Raja Ram v/s State of M.P.

INTRODUCTION- 

The appellant in this case is contesting both his conviction under IPC Section 498A and the sentence that was imposed after his appeal was denied by the Madhya Pradesh High Court. The charges of the prosecution are based on an occurrence where the appellant’s wife was brought to a hospital in a burned state, which ultimately resulted in her death. Several defendants were given charges under sections 498A and 304B of the IPC by the trial court. The appellant disputed the use of the deceased’s “dying declaration,” stating that given the circumstances of her death, it was inadmissible. He emphasised the conflicting statements made by the dying witnesses and the absence of critical witnesses’ testimony. The defence argued that remarks made in relation to the deceased are only made relevant under Section 32 of the Evidence Act. The closeness and content of the dying declarations were highlighted by the state in its defence of sustaining the convictions. The defence cited discrepancies and drew attention to the second declaration’s lack of a doctor’s endorsement. Additionally important were hostile witnesses. The legitimacy of the dying pronouncements and the circumstances surrounding them will now be decided by the court.

FACTS-

1. On April 23, 2009, at ten o’clock in the morning, word came from the hospital that a woman in charred condition had been brought there by her husband (the appellant). 
2. At the district hospital in Guna, Pushpa was hurt and passed away from her wounds on May 10, 2009. An autopsy was performed. The items that were confiscated were sent for FSL. 
3. Following their investigation, the police filed a charge sheet against the appellants alleging violations of Sections 302, 307, 304B, and 498A/34 of the Indian Penal Code (IPC) as well as Sections 3 and 4 of the Dowry Prohibition Act.
4. The appellant and the other defendants were found guilty and punished by the trial court for the offence under Section 498A IPC, while Santi Bai was found guilty and sentenced for the offence under Section 302 IPC.
5.  The appellant and the additional defendant contested their conviction and punishment. By the contested ruling, the High Court dismissed their appeals. As a result, the conviction and sentence of the appellant under Section 498A IPC were upheld.

ISSUES-

1. Whether the accused is liable u/s 302 for the murder?
2. Whether the court can rely on the dying declaration given by the deceased?

CONTENTIONS-

The appellant Rajaram’s knowledgeable attorney argued that the courts below erred by relying on the deathbed statement made by the deceased, his wife. It was contended that a person’s statement about the reason for her demise or about any other aspect of the event that led to her death would be admissible in court. Therefore, it was maintained, the charges made by the dead in her deathbed declaration against the accused, i.e., the appellant Rajaram, would be inadmissible since they were unrelated to the events surrounding the transaction that caused her death.

Finally, it was argued on behalf of the appellant that he could not have been found guilty based on the deathbed declaration since the prosecution was unable to establish the accusation on the count under Section 304B.

The state’s position is that the concurrent judgements of the lower courts do not need intervention and that the appeal entails a consideration of the facts. This court should not use its discretionary authority to overturn or otherwise interfere with the findings since nothing about them can be described as perverse or irrational based on the facts presented.

JUDGEMENT- 

1. It was decided that if the court determines that no accused can be convicted based on the evidence presented by the prosecution, then the non-appealing accused may be declared innocent.
2. The prosecution was ruled to have failed to establish its case beyond a reasonable doubt by the court. The court additionally determined that the dying confession of the dead, in which she claimed her husband had lit her ablaze, was inadmissible as evidence since it was not made during the event that led to her demise.
3. The Supreme Court further ruled that even though the non-appealing accused had not contested their convictions, they yet needed to get the benefit of acquittal. The court reasoned that it is its obligation to acquit all defendants if it determines that no defendant can be found guilty based solely on the evidence presented by the prosecution.
4. According to the ruling, an accused person may still be exonerated even if they choose not to appeal if the court determines that the prosecution failed to show its case beyond a reasonable doubt.

REFERENCES-

1. Indiankanoon.com
2. Casemine.com

This case analysis is written by Anshula Grover, intern at Legal Vidhiya and a student at Shoolini University.

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