Question:

In which case did the Supreme Court hold that dying declaration can be the sole basis of conviction if found reliable?

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A reliable dying declaration can be the sole basis of conviction. The leading case is Khushal Rao v. State of Bombay.
Updated On: May 22, 2026
  • Moti Ram v. State
  • Tukaram v. State
  • Khushal Rao v. State of Bombay
  • Pakala Narayan Swamy v. Emperor
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The Correct Option is C

Solution and Explanation

Concept: A dying declaration is a statement made by a person as to the cause of his death or circumstances of the transaction resulting in his death.

Step 1:
Understand evidentiary value of dying declaration.
Dying declaration is relevant because the law assumes that a person near death is unlikely to lie. \[ \text{Dying declaration} \Rightarrow \text{Relevant evidence} \]

Step 2:
Understand the rule of reliability.
If a dying declaration is found truthful, voluntary and reliable, it may form the sole basis of conviction. \[ \text{Reliable dying declaration} \Rightarrow \text{Can support conviction} \]

Step 3:
Identify the case.
The Supreme Court laid down this principle in Khushal Rao v. State of Bombay. Therefore, the correct answer is Khushal Rao v. State of Bombay.
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