Introduction
In a significant reaffirmation of settled criminal law principles, the Supreme Court of India has held that absence of motive is not fatal to the prosecution when there is clear and credible direct evidence, such as a dying declaration. The Court restored the conviction of a husband accused of murdering his wife, overturning the Himachal Pradesh High Court’s acquittal which was primarily based on the alleged failure of the prosecution to establish motive.
The ruling, delivered by a Bench comprising Justice B.V. Nagarathna and Justice R. Mahadevan, reiterates the evidentiary value of dying declarations under Indian criminal jurisprudence and clarifies the limited role of motive in cases based on direct evidence.
Case Details
- Case Title: State of Himachal Pradesh v. Chaman Lal
- Citation: 2026 LiveLaw (SC) 48
- Date of Judgment: 15 January 2026
- Coram: Justice B.V. Nagarathna and Justice R. Mahadevan
Factual Background
According to the prosecution, the respondent-husband set his wife ablaze, leading to her death. Before succumbing to burn injuries, the deceased recorded a dying declaration before an Executive Magistrate, in which she categorically named her husband as the person who had set her on fire.
The trial court, relying heavily on the dying declaration, convicted the accused for murder. However, in 2014, the Himachal Pradesh High Court overturned the conviction, reasoning that:
- There was no pending litigation or overt animosity between the spouses
- The prosecution had failed to establish a clear motive explaining why the accused would commit such a grave offence
Aggrieved by the acquittal, the State of Himachal Pradesh approached the Supreme Court.
Issues Before the Supreme Court
The principal issue before the Court was:
Whether failure to prove motive can vitiate a conviction when there exists direct evidence in the form of a credible dying declaration?
Supreme Court’s Observations
Setting aside the High Court judgment, the Supreme Court made crucial observations on the role of motive in criminal trials and the evidentiary value of dying declarations.
1. Motive Is Secondary Where Direct Evidence Exists
Justice Mahadevan, authoring the judgment, categorically held:
“Motive assumes significance primarily in cases based on circumstantial evidence. Where there is direct evidence in the form of a credible and trustworthy dying declaration, the absence of strong proof of motive is not fatal to the prosecution case.”
The Court clarified that motive is not an indispensable ingredient in every murder case. Its relevance increases only when the prosecution relies exclusively on circumstantial evidence.
2. Dying Declaration as Substantive Evidence
The Bench reiterated the well-settled position that a dying declaration, if found voluntary, consistent, and credible, can form the sole basis of conviction, without requiring corroboration.
In the present case:
- The dying declaration was recorded by a competent authority (Executive Magistrate)
- The deceased clearly named her husband as the perpetrator
- There were no material inconsistencies or circumstances casting doubt on its authenticity
Hence, the Court treated it as direct and substantive evidence.
3. Background of Matrimonial Discord Was Established
Rejecting the High Court’s reasoning that absence of litigation indicated lack of motive, the Supreme Court noted that:
- The evidence on record revealed frequent quarrels, humiliation, and verbal abuse by the accused
- The deceased was repeatedly branded a “Kanjri” and asked to leave the matrimonial home
- The dying declaration itself referred to persistent ill-treatment and matrimonial discord
The Court observed that these facts furnished a plausible background for the commission of the offence, even if motive was not established with mathematical precision.
4. Appellate Courts Must Exercise Caution While Reversing Convictions
The Supreme Court strongly criticised the High Court for re-appreciating evidence in a manner inconsistent with settled principles governing appellate interference.
It held:
“The High Court fell into manifest error in reversing the well-reasoned judgment of conviction recorded by the trial court by re-appreciating the evidence contrary to settled principles.”
The Court emphasised that an appellate court must not lightly overturn a conviction, particularly when the trial court’s findings are based on credible evidence.
Final Verdict
Allowing the State’s appeal, the Supreme Court:
- Set aside the acquittal of the accused
- Restored the conviction recorded by the trial court
- Directed the respondent-husband to surrender and undergo the remaining sentence
Legal Significance of the Judgment
1. Reinforces the Evidentiary Strength of Dying Declarations
The ruling strengthens the jurisprudence that a truthful dying declaration can independently sustain a conviction, reinforcing public confidence in this form of evidence.
2. Clarifies the Limited Role of Motive
By holding that motive is secondary in cases involving direct evidence, the Court prevents undue acquittals based on speculative reasoning and ensures that substantive justice prevails over technical doubts.
3. Guidance for High Courts in Criminal Appeals
The judgment serves as a reminder that appellate courts must respect trial court findings unless there are compelling reasons to interfere, especially in serious offences like murder.
Conclusion
The Supreme Court’s decision in State of Himachal Pradesh v. Chaman Lal is a reaffirmation of fundamental principles of criminal law. It underscores that justice cannot be derailed merely due to the absence of a clearly established motive when direct and credible evidence exists.
By restoring the conviction based on a reliable dying declaration, the Court has ensured accountability in cases of domestic violence and homicide, while also clarifying the proper approach courts must adopt in evaluating evidence. The ruling is likely to have lasting implications on how motive and dying declarations are assessed in future criminal trials.
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