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2026 Supreme(SC) 469

ARAVIND KUMAR, N. V. ANJARIA
Narendra Singh – Appellant
Versus
State Of Madhya Pradesh – Respondent


Advocates appeared:
For the Appellant(s) : Mr. Parijat Sinha, AOR Mr. Divyam Dhyani, Adv. Mr. Shaurya Nagpal, Adv. Ms. Reshmi Rea Sinha, Adv. Mr. Rudra Dutta, Adv. Ms. Priyal Jain, Adv. Mr. Alok Bhatt, Adv. Mr. Rajeev Kumar Bansal, AOR Mr. Kshitij Singh, Adv. Mr. Rajesh Sonthalia, Adv. Mr. Brijesh Kumar Yadav, Adv. Mrs. Shefali Jain, Adv. Mr. Manish Das, Adv. Mr. Mukul Biswas, Adv. Mr. Pashupathi Nath Razdan, AOR
For the Respondent(s): Mr. Rajeev Kumar Bansal, AOR Mr. Kshitij Singh, Adv. Mr. Parvinder, Adv. Mrs. Shefali Jain, Adv. Ms. Kavita Singh, Adv. Mr. Rajat Kumar, Adv. Mr. Mahendra Kumar Jain, Adv. Mr. Devesh Kumar, Adv. Mr. Vidya Sagar, Adv. Mr. Pashupathi Nath Razdan, AOR

Judgement Key Points

What is the court’s stance on using a dying declaration as the sole basis for conviction and the need to weigh it against surrounding circumstances? What is the applicable approach when conflicting dying declarations or evidence create two possible inferences, particularly regarding dowry cruelty and section 498A IPC?


JUDGMENT :

ARAVIND KUMAR, J.

1. Three Criminal Appeals have been filed against the order of the High Court of Madhya Pradesh at Jabalpur in Criminal Appeal No. 1248 of 2002, wherein the High Court was pleased to set aside the conviction of the accused persons namely Nagendra Singh (Husband), Narendra Singh (Father-in-Law) and Lila Singh (Mother-in-Law) u/s 302 of the Indian Penal Code (IPC) acquitting them of the charge u/S. 302 of IPC. However, the High Court upheld their conviction u/s 498A of IPC, reduced the sentence to the period they have already undergone and maintained the fine of Rs. 1000/- each as imposed by the Learned Additional Sessions Judge.

2. Criminal Appeal No. 302 / 2014 has been filed by Narendra Singh, the father-in-law of the deceased challenging his conviction u/s 498A IPC. Criminal Appeal No. 309 / 2014 has been filed by Pushp Raj Singh Baghel, the brother of the deceased (defacto complainant) against all three accused persons challenging their acquittal u/s 302 IPC and Criminal Appeal No. 307 / 2014 has been filed by the State of Madhya Pradesh against all three accused persons challenging their acquittal u/s 302 IPC. Hence, all these three criminal appeals ar

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      Judicial Analysis

      Banti @ Laxminarayan VS State of Rajasthan - 2023 0 Supreme(Raj) 1805: Treatment unclear. The snippet discusses witness testimony (e.g., "Bhikkan Singh-complainant(PW.1) has not supported the prosecution version" and several PWs "have turned") but contains no keywords or phrases indicating judicial treatment such as followed, distinguished, criticized, overruled, reversed, or abrogated. No evidence of how this case has been treated in subsequent decisions.

      State of Rajasthan VS Narsi Ram - 2024 0 Supreme(Raj) 945: Treatment unclear. The snippet cites another case ("State of Karnataka, reported in (2007) 4 SCC 415") and mentions an appeal ("the present appeal at the instance of the State"), but does not indicate how this specific case itself has been treated by other courts. No treatment keywords present.

      Shankar VS State of Rajasthan - 2026 0 Supreme(SC) 341: Treatment unclear. The snippet describes factual details (e.g., testimony about injuries from burning and death) and mentions counsel, but lacks any indicators of judicial treatment patterns like followed, overruled, or reversed. No relevant keywords or phrases.

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