INDEX-

SR.NO. PARTICULARS PG. NO.

ABBREVIATIONS & TABLE OF CASES 3

1. Introduction 4-5

2. Analysis and Interpretation of State Of Karnataka 6-8

vs Shariff

3. Analysis and Interpretation of Munnu Raja & Anr. 9-13

vs. The State Of Madhya Pradesh
4. Analysis and Interpretation of Munnu Raja & Anr. 18-22
vs. The State Of Madhya Pradesh

5. Analysis and Interpretation of State Of U.P. vs 14-17

Madan Mohan And Ors.

6. Conclusion 18-20

7 Bibliography 21

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 List of Cases
 Munnu Raja & Anr vs The Stae Of Madhya Pradesh
 State Of Karnataka vs Shariff
 State Of U.P. vs Madan Mohan And Ors

List of Statutes
 Code of Criminal Procedure, 1973
 Constitution of India
 Indian Evidence Act, 1872
 Indian Penal Code

Abbreviations
 AIR: All India Reporter
 Anr. : Another
 Art.: Article
 CrLJ: Criminal Law Journal
 CrPC: Criminal Procedure Cod
 F.I.R. : First Information Report
 IEA : Indian Evidence Act
 IPC : Indian Penal Code
 J.: Justice
 PW : Prosecution Witness
 SC: Supreme Court
 SCC: Supreme Court Cases
 Sec.: Section

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  U/s : Under Section

Chapter: 1 Introduction

The concept of dying declaration is based on the maxim “Nemo moriturus praesumitur mentire”
i.e. a man will not meet his maker with a lie in his mouth.

Hearsay evidences are not given any weightage in the courts because the person who is giving
this evidence is not telling his experiences but that of another person and who cannot be cross-
examined to verify the facts.

Dying declaration is an exception to this rule because if this evidence is not considered very
purpose of the justice will be forfeited in certain situations when there may not be any other
witness to the crime except the person who has since died. Sometimes it the best evidence in
such situations.

Section 32(1) of Indian Evidence Act

Dying Declaration's admissibility is explained in the section 32 (1) of Indian Evidence Act.
According to this section when the statement is made by a person as to the cause of his death, or
any of the circumstances of the transaction which resulted in his death, in cases in which the
cause of that person’s death comes into question. Such statements are relevant whether the
person who made this was expecting death or not. 1

Best form of dying declaration is in the form of questions and answers. If it is in the form of
narrations, it is still good because nothing is being prompted and everything is coming as such
from the mind of the person making it. Whenever this is being recorded in the form of questions
and answers precaution should be taken that exactly what questions are asked and what answers
are given by the patient those should be written.

1
1999 Cr.L.J 1122

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It is best that it is recorded by the magistrate but if there is no time to call the magistrate due to
the deteriorating condition of the victim it can be recorded by anybody e.g. public servant like
doctor or any other person. Courts discourage the recording of dying declaration by the police
officers but if there is nobody else to record it dying declarations written by the police officers
are also considered by the courts. If these are not recorded by the magistrate it is better that
signatures of the witnesses are taken who are present at the time of recording it.

First information report got recorded by the police has been taken as dying declaration by the
Honorable Supreme Court in a number of cases when the person did not survive to get his dying
declaration recorded. But when patient remained admitted in hospital for sufficient days i.e. for 8
days FIR cannot be treated as dying declaration2. A suicidal note written found in the clothes of
the deceased it is in the nature of dying declaration and is admissible in evidence under Section
32 of Indian Evidence Act

Summary of further chapters:

 Chapter 2 deals with the analysis and Interpretation of State Of Karnataka vs Shariff 3

which analyses the fact that a dying declaration can be acted upon without corroboration

 Chapter 3 deals with analysis and Interpretation of Munnu Raja & Anr vs The Stae Of
Madhya Pradesh4, which discusses when an F.I.R. can be treated as a dying declaration
and effect on the evidentiary value of the dying declaration if not recorded by the
magistrate.

 Chapter 4 deals with analysis and Interpretation of State Of U.P. vs Madan Mohan And
Ors5 which talks about situations in which the dying declaration becomes unreliable.

 Chapter 5 concludes the Project

2
William Holdsworth, 5 History of English Law, 183
3
AIR 2003 SC 1074
4
1976 AIR 2199
5
AIR 1989 SC 1519

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Chapter 2: Analysis and Interpretation of State Of Karnataka vs Shariff

INTRODUCTION
The issues in focus in this case is whether conviction can solely be based on the dying
declaration and if the dying declaration is not made in question and answer form does it reduce
the evidentiary value of the same.

Facts:
The respondents Shariff and his wife have been married for 10 years and have three children.
Shariff started ill-treating his wife after the birth of the third child. A Panchayat was held
wherein he was asked to behave properly and look-after his wife.

On July 24, 1986 the accused started quarreling with his wife and demanded money which she
had earned sometime back by selling agarbattis.

Accused set the deceased on fire by pouring kerosene on her and lighting a matchstick. At the
hospital, she made a dying declaration that she is in the hospital because of her husband. He
poured kerosene on her and set her on fire by a matchstick.

The accused was convicted under section 302 of the IPC by the Sessions Judge Bangalore Rural
District, Bangalore. However, the High Court held him not guilty and acquitted him.

The Petitioners approached the Supreme Court by the way of Special Leave Petition against the
order of the High Court of Karnataka.

CONTENTIONS
Appellants-

Shri M. Veerappa, learned counsel appearing for the State of Karnataka assailed the judgment
and order of the High Court.

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He submitted that the prosecution produced reliable evidence to establish its case and the High
Court has erred in discarding the testimony of the witnesses and also several dying declarations
of the deceased which were reliable and trustworthy and the reasons given for acquitting the
accused are wholly perverse and contrary to settled principles of law.

Respondents -

Shri Ajay Kumar Jain, who appeared Amicus Curiae for the accused- respondent, has submitted
that the evidence on record adduced by the prosecution was wholly untrustworthy and in the
facts and circumstances of the case the dying declarations of the deceased could not be relied
upon and, therefore, the High Court was perfectly justified in acquitting the accused- respondent.
Shri Jain has further submitted that at any rate this was a case in which two views were possible
and the High Court having taken a view in favour of the accused and having acquitted him, it
will not be proper for this Court to interfere with the impugned judgment and order and to
convict the accused.

JUDGEMENT

The Supreme Court held that “It is well settled that, as a matter of law, a dying declaration can
be acted upon without corroboration.” In addition, it cannot be said that unless the dying
declaration is in question-answer form, it could not be accepted.

Having regard to the value attached to a dying declaration as it comes from the mouth of a dying
person though, unlike the principle of English law he need not be under apprehension of death.
Hence the appeal succeeded in the Supreme Court and the impugned judgment and order of the
High Court is set aside and that of the learned Sessions Judge is restored. The accused-
respondent shall surrender and undergo the sentence imposed by the learned Sessions Judge. The
Chief Judicial Magistrate concerned shall take immediate steps to take the accused-respondent in
custody.

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 ANALYSIS
The Supreme Court in Khushal Rao v. State of Bombay6 said that it cannot be laid down as an
absolute rule of law that a dying declaration cannot form the sole basis of conviction unless it is
corroborated; each case must be determined on its own facts keeping in view the circumstances
in which the dying declaration was made; it cannot be laid down as a general proposition that a
dying declaration is a weaker kind of evidence than other pieces of evidence; a dying declaration
stands on the same footing as another piece of evidence and has to be judged in the light of
surrounding circumstances and with reference to the principles governing the weighing of
evidence.

Thus, it can be said that in the said case of (State of Karnataka Vs. Shraiff) the Supeme Court did
not make any mistake in convicting the respondent solely on the basis of the dying declarations
of the deceased. Other pieces of evidence though present, were unreliable. The dying the
declarations were the only evidence that were reliable. Hence the Supreme Court was justified in
convicting the petitioners solely on the basis of the dying declarations without any other
corroboration.

The primary effort of the court should be that the contents of the dying declaration should be
truthful. Once this fact has been established, conviction can be based solely on Dying
Declaration without any corroboration.

The High Court did not consider the dying declarations reliable because they were not in
question and answer form. Very often, the deceased is merely asked as to how the incident took
place and the statement is recorded in a narrative form. In fact, such a statement is more natural
and gives the version of the incident as it has been perceived by the victim. Thus, the Supreme
Court was justified in considering the dying declarations even when they were not in question
and answer form. Thus, the Supreme Court has applied the Golden Rule of interpretation in the
aforementioned case. Since it is not given in the statute that the dying declaration should be in
question and answer form.

6
AIR 1958 SC 22

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 Chapter 3: Analysis and Interpretation of Munnu Raja & Anr. vs. The
State Of Madhya Pradesh

INTRODUCTION
This case involves three dying declarations. It deals with the treatment of F.I.R. as a dying
declaration and discusses whether it is necessary that a magistrate take down a dying declaration.

FACTS
The appellants, Munnu Raja and Chhuttan, were tried by the learned Sessions Judge, Chatarpur
on the charge that at about 10 a.m. On April 30, 1969, they committed the murder of one
Bahadur Singh.

Santosh Singh (P.W. 1 ) and Mst. Gumni (P.W. 4) claimed to be eye the witnesses.

Santosh Singh stated that he saw Chhuttan assaulting Bahadur Singh with a spear but that he did
not see Munnu Raja at all. On the other hand, Mst. Gumni stated that it was Munnu Raja and not
Chhuttan who assaulted the deceased.

Hence, the two principal witnesses turned hostile, the learned Sessions Judge thought it unsafe to
rely on their testimony. The learned Judge was also not impressed by the three dying
declarations. He concluded that the prosecution had failed to establish its case beyond a
reasonable doubt.

Therefore, the learned Sessions Judge acquitted the appellants.

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The State Government filed an appeal in the High Court of Madhya Pradesh. The High Court did
not discard the evidence of the eyewitnesses but utilised it by way of corroboration to the dying
declarations alleged to have been made by the deceased.

The order of acquittal was set aside and the High Court convicted the appellants under s: 302
read with s. 34 of the Penal Code and sentenced each of them to imprisonment for life.

The appellants filed this appeal under s. 2(1) of the Supreme Court (Enlargement of Criminal
Appellate Jurisdiction) Act, 1970.

CONTENTIONS
Appellants -

It was contended by the learned counsel for the appellants that the oral statement which Bahadur
Singh made cannot constitute a dying declaration because he did not give a full account of the
incident which resulted in his death

In regard to the second dying declaration the main objection of the learned counsel is that it was
made to the investigating officer himself and ought therefore be treated as suspect.

Respondent -

The counsels for the respondent contended that as regard to these dying declarations, the
judgment of the Sessions Court suffers from a patent infirmity in that it wholly overlooks the
earliest of these dying declarations, which was made by the deceased soon after the incident in
the house of one Barjor Singh.

The second statement which has been treated by the High Court as a dying declaration is Ex. P-
14, being the first information report which was lodged by the deceased at the police station.

The learned Sessions Judge probably assumed that since the statement was recorded as a first
information report, it could not be treated as a dying declaration which can be treated as an error
of the Sessions Court. After making the statement before the police, Bahadur Singh succumbed

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to his injuries and therefore the statement can be treated as a dying declaration. The maker of the
statement is dead and the statement relates to the cause of his death.

JUDGEMENT

The Sessions Court rightly discarded the evidence of the hostile eye witnesses. They resiled
from their Police Statements and it is evident that they have no regard for truth. Their evidence
cannot be used to corroborate the dying declarations.

In regard to the dying declarations the Sessions Court wholly overlooked the earliest dying
declaration which was made by the deceased soon after the incident. The second dying
declaration was the first information report lodged by the deceased at the Police Station. The
Sessions Judge was clearly in error in holding that the first information report cannot be
treated as a dying declamation. After making the statements before the police the deceased
succumbed to his injuries and, therefore, the statement can be treated as a dying declaration,
and is admissible under section 32(1) of the Evidence Act, The maker of the statement is dead
and the statement relates to the cause of his death.

It is, well settled that though a dying declaration must be approached with caution for the
reason that the maker of the statement cannot be subjected to cross examination, there is
neither a rule of law nor a rule of prudence that a dying declaration cannot be acted upon unless
it is corroborated.

The second dying declaration was not made to the Investigating officer. It was made by
way of First Information Report and it was only after the information was recorded that the
investigation commenced. The High Court was right in relying on the first and second
dying declarations. Considering the facts and circumstances of the case these two dying
declarations can be accepted without corroboration.

The High Court ought not to have relied on the third dying declaration which is said to have been
made by the deceased in the hospital. The Investigating officer ought to have requisitioned the
services of a Magistrate for re-cording that dying declaration, Investigating officers are

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naturally integrated in the success of the investigation and the practice of the Investigating
Officer himself recording a dying declaration during the course of investigation ought not to be
encouraged.

Thus, the Supreme Court held that the High Court in reversing the order of acquittal passed by
the Sessions Court did not violate any of the principles governing appeals against acquittal.

ANALYSIS

There were three dying declarations in the aforementioned case.

The Supreme Court was right not to rely on the testimony of Santosh Singh and Mst. Gumni.
They resiled from their police statements and it is evident that they have no regard for truth.
Their evidence cannot be used to corroborate-the dying declarations either.

Thus, the Supreme Court was left with the three dying declarations made by Bahadur Singh and
since the prosecution placed great reliance on them it was necessary to hear the learned counsel
fully on the facts and circumstances leading to the dying declarations.

The High Court held that these statements were essentially true and do not suffer from any
infirmity.

It is well settled that though a dying declaration must be approached with caution for the reason
that the maker of the statement cannot be subject to cross-examination. But, there is no law nor a
rule of prudence which says that a dying declaration cannot be acted upon unless it is
corroborated. Thus, the Supreme Court was justified in dismissing the appeal saying that
considering the facts and circumstances of the case, these two statements can be accepted
without corroboration.

However, High Court ought not to have placed any reliance on the third dying declaration which
was said to have been made by the deceased in the hospital. If the investigating officer thought
that Bahadur Singh was in a precarious condition, he ought to have requisitioned the services of

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a Magistrate for recording the dying declaration. Investigating officers are naturally interested in
the success of the investigation and the practice of the investigating officer himself recording a
dying declaration during the course of investigation ought not to be encouraged. Therefore, the
Supreme Court was justified excluding from its consideration the third dying declaration, as a
magistrate should have been called.

Therefore, the Supreme Court was justified in dismissing the appeal of the appellants and did
justice.

Here, the Supreme Court has used the literal rule of interpretation. The Section 32(1) of the IEA
clearly states that "when the statement is made by a person as to cause of his death", thus the
F.I.R. is within the purview of this section clearly and no absurdity or inconsistency.

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 Chapter 4: Analysis and Interpretation of State Of U.P. vs Madan
Mohan And Ors.

FACTS
The three respondents were convicted by the learned Additional Sessions Judge, Kanpur under
Sections 148 I.P.C. and 302/149 I.P.C. for the murders of Ram Shanker and his friend Satya
Narain Singh. They were sentenced to suffer rigorous imprisonment for two years under Section
148 I.P.C. and imprisonment for life.

The High Court of Allahabad allowed their appeal and set aside the order of conviction and
sentence passed by the Trial Court. They were acquitted of all the charges levelled against them
and their bail bonds were discharged. The State of U.P. feeling aggrieved by the order of
acquittal approached the Supreme Court by way of special leave.

The incident in question occurred on 29th December, 1972 at about 7. 30 p.m. near block No. 10
in Govind Nagar locality of the city of Kanpur. In the said incidents Ram Shanker and his friend
Satya Narain received fatal injuries. Ram Shanker died on the spot about 65 steps away from the
place of occurrence whereas his companion Satya Narain expired in the hospital on 8th January,
1973. It may here be mentioned that both the deceased persons had a criminal record. The
Investigating Officer PW 7, Jagdish Kumar has stated that both the deceased were bad characters
of Govind Nagar area and several cases of marpit were pending against them, particularly Ram
Shanker. Besides, there were cases pending against Ram Shanker under Section 25, Arms Act
and Section 392 I.P.C. also. PW 1 Sheo Shanker, the brother of the deceased Ram Shanker, also
admits that there were two to four cases pending against his brother, including a couple of cases
under Section 25, Arms Act.
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One Sneh Lata Aggarwal resided in the house of one Tiwarijee in ‘E’ Block of Govind Nagar.
The deceased Ram Shanker had illicit relations with her. His brother PW 1 admits this fact also.
Ram Shanker and his companion Satya Narain used to visit her regularly which was not liked by
the landlord Tiwarijee. A couple of days prior to the incident Tiwarijee had reprimanded them
for visiting Sneh Lata. This had annoyed the two deceased. They had, therefore, beaten up
Tiwarijee. On the morning of 29th December, 1972, the respondent No. 1 Madan Mohan is
alleged to have admonished the deceased Ram Shanker for beating Tiwarijee and is further
alleged to have threatened to kill him (Ram Shanker) if he misbehaved in future. According to
the prosecution, on the evening of 29th December, 1972, the three respondents along with two or
three others cordoned the two deceased on the footpath near the residence of the respondents and
inflicted knife blows to them which ultimately proved fatal. As stated earlier, Ram Shanker died
on the spot while his companion Satya Narain died in the hospital a few days later.

The prosecution relies on the evidence of two eye witnesses PW 1 Sheo Shanker, the brother of
the deceased Ram Shanker, and PW 2 Inder Singh. Both these witnesses arrived at the scene of
occurrence after the quarrel started and claim to have seen the respondents inflicting knife
injuries to the two deceased from a short distance. In addition the prosecution relies on the
statement of deceased Satya Narain recorded in the hospital on the next morning. The said
statements is admitted in evidence as a dying declaration. The Trial Court accepted the evidence
of the two eye witnesses as well as the dying declaration and convicted the respondents. The
High Court, however, came to the conclusion that the presence of the two eye witnesses at the
place of occurrence was doubtful and since the dying declaration gave out a version totally
different from the version of the two eye witnesses it refused to place reliance on the dying
declaration. The High Court, therefore, reversed the finding of conviction and acquitted all the
respondents.

CONTENTIONS

APPELLANT-

The learned counsel for the State took the Apex Court through the evidence of both the eye
witnesses as well as the evidence in regard to the dying declaration and contended that the High
Court had not properly appreciated the evidence placed on record. The learned counsel,
therefore, submitted that the Supreme Court must restore the decision of the Trial. Court.

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RESPONDENT-

The learned counsel for the respondent believe that the deceased had a criminal past and has a
large number of enemies. He contends that the respondents were falsely implicated and it was
someone else who killed the deceased. Moreover, the dying declarations give entirely different
versions as compared to the eye witnesses. Therefore, they cannot be relied upon.

JUDGEMENT

The Supreme Court averred that there can be no doubt that PW 1 and PW 2 can be said to be
chance witnesses. Their residences are a furlong or two away from the scene of occurrence. The
story of PW 1 that he closed the shop earlier than usual is difficult to believe because he does not
assign any reason for so doing. The allegation that respondent Chander Mohan’s complaint was
first in point of time but was registered later

Both the deceased had a criminal record. Several complaints were pending against Ram Shanker
He must be having many enemies. It might be possible that some of their common enemies got
together and killed them and PW 1 was not present but who came later filed the report on the
basis of the morning incident. Be that as it may, the fact remains that the genesis of the crime is
suppressed and no witness from the locality whose presence would be natural is examined which
creates a doubt regarding the truth of the prosecution version.

In the above circumstances, it is difficult to say that the High Court was not justified in taking
the view that it took. The view taken by the High Court is a reasonable view. Thus, the Supreme
Court thought it would not be justified in interfering with the same under Article 136 of the
Constitution. Therefore, the Apex Court dismissed this appeal.

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 ANALYSIS
The Supreme Court was justified in dismissing the appeal since the dying declaration gave out a
version totally different from the version of the two eye witnesses. In such a situation reliance
cannot be placed on the dying declaration .
The fact that while PW 1 and PW 2 stated that the incident occurred at about 7.30 p.m., the
deceased Satya Narain in his dying declaration gave the time of the incident as 6. 00 p.m. also
proves that the dying declaration was doubtful.
The version regarding the incident given by PW 1 and PW 2 also materially differs from the
version found in the dying declaration. The names’ of the accused disclosed in the dying
declaration are also different. There is no mention about the participation of respondent Chander
Mohan in the incident in the dying declaration. The dying declaration discloses that only
respondent Madan Mohan caused knife injuries to deceased Satya Narain whereas deceased Ram
Shanker was attacked by Kamla Tiwari, Rama and two others who were never prosecuted. Thus,
respondent Chander Mohan and respondent Daya Shanker alias Munna have not been assigned
any role by Satya Narain in his dying declaration. There is no mention about PW 1 and PW 2
having witnessed the occurrence even though the names of other witnesses are mentioned in the
dying declaration. The High Court was, therefore, right in coming to the conclusion that the
prosecution version regarding the incident as stated by PW 1 and PW 2 materially differs from
the version unfolded by the dying declaration.
Thus, the High Court rightly rejected the dying declarations and acquitted the accused and the
Supreme Court was justified in dismissing the appeal since the dying declaration were unreliable
as they gave a different version to the story.
The Supreme Court has used the Golden Rule of interpretation here as to sort out the absurdity
and inconsistency with reliability of the dying declaration.

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 Chapter 5: Conclusion & Suggestion

The following can be concluded from the research -

 Section 32(1) of the Indian Evidence Act deals with the concept of dying declaration.
According to this section -

When the statement is made by a person as to the cause of his death, or as to any of the
circumstances of the transaction which resulted in his death, in cases in which the cause
of that person's death comes into question. Such statements are relevant whether the
person who made them was or was not, at the time when they were made, under
expectation of death, and whatever may be the nature of the proceeding in which the
cause of his death comes into question.

The term Dying Declaration has not been defined in the Evidence Act but reading Section
32 and sub section (1) of Section 32, the term dying declaration may be defined as a
statement made by a person who is dead; and the statement contains the cause of his
death or any other circumstances of transaction which resulted in his death.

 Dying declaration is very important documentary evidence. It is hearsay evidence but

even then, it is given a lot of weightage in the court proceedings. The dying declaration
comes into picture where death of a person is involved. Thus, it usually comes in cases
which are under Section 309 (Attempt to Suicide) or 302 (Murder) of IPC. Thus, a dying
declaration is a very important piece of evidence in cases involving grievous offences.
Punishments for such offences are generally very severe in nature. Thus, a great emphasis
is placed upon a dying declaration in a case.

 There might be cases where the only piece of evidence that is available is the dying
declaration. It might be possible that there are no eyewitnesses or any other form of
evidence to produce before the court. In these situations, the question arises that whether
the conviction can be solely based based on the dying declaration or is it mandatory that
some other evidence is there to corroborate the dying declaration.

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 In cases, where dying declaration is the only evidence available, the statement of the
deceased is the only thing available with the courts. In addition, since, the person has
died; he cannot be called in the court for cross-examination. There might be a lot of cases
in which the deceased out of personal vengeance or persuasion of others, might falsely
implicate a particular person. In such cases, if conviction is based solely on dying
declaration then an innocent person, who had nothing to do with the offence might get
falsely implicated and suffer for something which he did not do.

 Therefore, the judiciary must exercise extreme caution in such cases. However, a dying
declaration cannot altogether be disregarded if no other evidence is there to corroborate
it. It should entirely depend on the facts and circumstances of the given case. But once,
the Court has come to the conclusion that the dying declaration was the truthful version
as to the circumstances of the death of the victim, there is no question of further
corroboration. Once the Court is satisfied that the dying declaration is true and voluntary
it can be sufficient to found the conviction even without any further corroboration.

 The law does not prescribe any particular format in which the dying declaration has to be
recorded. It is, however, preferred that it is in a question and answer from. It is possible
that a dying declaration was recorded by a doctor or relative of the deceased, or the
deceased himself and he had no idea whatsoever about the format. In such situations, the
evidentiary value of the dying declaration cannot be said to have reduced just because it
is not in the question and answer form. Thus, it does not matter in which form the dying
declaration is recorded, however, a question and answer from is preferred.

 There might be cases in which a person is under threat for his life and he visited a police
station and filed an F.I.R. against a particular person. In such cases, where a person dies
without a dying declaration but had lodged an F.I.R. against a particular person, the said
F.I.R. can be treated as a dying declaration if no other statement by the deceased is
available.

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 In a situation where a person has sustained some injuries and he goes to the Police and
files an F.I.R. and thereafter succumbs to death, the F.I.R. will be treated as his dying
declaration.

 There is no law which says that it is mandatory that a dying declaration be recorded by a
magistrate. However, it is preferable that a magistrate records it. There might be
situations in which the patient is severely injured and there might not be enough time to
call a magistrate to record the dying declaration. In such a situation, a dying declaration
can be recorded by anyone. However, a dying declaration made before a magistrate will
always have a higher evidentiary value.

 In cases, where the dying declaration produces a version of facts which the court thinks
are contrary to what actually happened the dying declaration will lose its evidentiary
value and thus the same cannot be relied upon.

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 Bibliography

Books referred:
 The Law of Evidence by Batuk Lal
 Indian Evidence Act by Avtar Singh
 Sarkar on Evidence

Websites referred:
 http://www.manupatrafast.com
 https://indiankanoon.org
 https://www.academia.edu
 http://www.legallyindia.com
 http://www.inbrief.co.uk
 https://www.scribd.com
 http://www.dnaindia.com
 http://www.livelaw.in/
 http://lawrato.com
 http://ijldai.thelawbrigade.com
 https://www.kaanoon.com
 http://www.lawkam.org/
 http://www.legalservicesindia.com/
 http://medind.nic.in/
 http://lawmantra.co.in/

Articles referred:
 Author: Y.Srinivasa Rao, M.A(English)., Published by Legal services India, May 31
2012, Category: Law - Lawyers and Legal Profession
 Author: Satish Sharma, Supreme Court Rules on Dying Declaration, Published by Vakil
No.1.com, May 24, 2013

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