The court affirms life imprisonment for Tilluka @ Manoj in the murder of Satyavati, relying on her recorded dying declaration as key evidence.
In a significant ruling, the Allahabad High Court has upheld the conviction of Tilluka @ Manoj, sentenced to life imprisonment for the murder of Satyavati, based on her dying declaration. The division bench, consisting of Justices J.J. Munir and Vinai Kumar Dwivedi, delivered the judgment on July 2, 2026, affirming the decision of the Special Judge (D.A.A.)/Additional Sessions Judge-III, Agra, dated October 25, 2019.
The case revolves around the tragic incident on July 2, 2015, when Satyavati was allegedly set ablaze by her cousin, the appellant, Tilluka @ Manoj, after a dispute over a loan. Despite the lack of eyewitnesses, the court relied heavily on Satyavati's dying declaration, recorded by the Additional City Magistrate J.P. Chauhan, soon after the incident. In her statement, Satyavati identified Tilluka as the assailant, a declaration made in a conscious and voluntary state, as corroborated by medical personnel.
The defense argued that discrepancies, such as the type of oil used and the delay in lodging the FIR, undermined the reliability of the prosecution's case. However, the court dismissed these concerns, emphasizing the credibility of the dying declaration and the corroborative circumstantial evidence provided by res gestae witnesses, who arrived shortly after the incident and heard Satyavati's cries.
The court also addressed procedural challenges raised regarding the contradiction of witness statements under Section 161 CrPC. It clarified the proper method for such contradictions, asserting that omissions in police statements must be explicitly marked and proved to challenge a witness's credibility.
In delivering the judgment, the court underscored the legal principles surrounding dying declarations, noting that such statements can solely form the basis for conviction if deemed truthful and voluntary. The court found no evidence of tutoring or prompting, affirming the lower court's decision and dismissing the appeal.
This ruling reaffirms the judicial stance on the admissibility and weight of dying declarations, especially in cases where corroborative evidence is lacking. It highlights the rigorous scrutiny applied by courts to ensure that justice prevails, even amid procedural complexities and challenges.
Bottom line:-
Dying declaration recorded by a Magistrate, even without formal medical certification, is valid if the Magistrate finds the declarant in a fit state of mind and the declaration is truthful and voluntary. Conviction can be based solely on such dying declaration if it inspires full confidence and is corroborated by circumstantial evidence.
Statutory provision(s): Indian Penal Code, 1860 Section 302, Criminal Procedure Code, 1973 Section 161, Section 313 Cr.P.C.
Tilluka @ Manoj v. State of U.P., (Allahabad)(DB) : Law Finder Doc id # 2935024
