Top Court Rules Medical Certification Key in Assessing Reliability of Victim Statements
In a significant ruling, the Supreme Court of India has clarified that the opinion of a treating doctor carries greater weight than that of a police officer when determining the reliability of a dying declaration.
A division bench comprising Justice Pankaj Mithal and Justice S. V. N. Bhatti held that once a doctor certifies a patient as mentally fit to give a statement, such certification cannot be disregarded.
Doctor’s Certification Takes Precedence
The Court emphasized that medical opinion is crucial in assessing whether a victim was in a condition to make a valid statement. It noted that even if a police officer claims the victim was unconscious, such an assertion cannot override the doctor’s professional assessment.
“The statement of the doctors who treated the deceased… cannot be overridden by the investigating officer,” the bench observed, reinforcing the evidentiary value of medical certification.
Case Background: Husband Convicted for Wife’s Murder
The ruling came while hearing an appeal filed by a man convicted of murdering his wife by allegedly setting her on fire during a domestic dispute. According to the prosecution, the accused poured kerosene on his wife and ignited her inside their home.
Despite sustaining severe burn injuries, the victim was taken to a hospital where a doctor certified that she was conscious and mentally fit to give a statement. Based on this certification, police recorded her dying declaration.
Defence Argument Rejected
The defence challenged the reliability of the dying declaration, arguing that the investigating officer had stated the victim was unconscious and unable to speak at the time.
However, the Court rejected this claim, pointing out that the doctor on duty had explicitly certified the victim’s mental fitness. The bench held that such medical evidence could not be undermined by contradictory police testimony.
Medical Evidence Strengthens Prosecution Case
The Court noted that multiple doctors confirmed the victim remained conscious despite critical burn injuries after being admitted on July 20, 2000. The dying declaration was recorded with proper medical endorsement and signatures.
Finding no inconsistencies or reasons to doubt the statement, the Court observed that there was no material to suggest the declaration was improperly recorded or fabricated.
Conviction Upheld
Relying on the dying declaration, supporting medical evidence, and eyewitness testimony from the couple’s daughter, the Court concluded that the prosecution had successfully proven its case.
The appeal was dismissed, and the conviction of the आरोपी was upheld, reinforcing the legal principle that medically certified dying declarations hold strong evidentiary value in criminal trials.
