Dying declaration evidence remains reliable without doctor's certification when voluntariness, consistency, and fitness are established.

A dying declaration may be oral or written, need not follow any prescribed form, and does not invariably require a doctor's certificate if the recorder is satisfied that the declarant was fit physically and mentally. Its evidentiary value turns on voluntariness, truthfulness, and the surrounding circumstances. Minor inconsistencies between multiple declarations do not by themselves vitiate the prosecution case where the core version remains consistent. A thumb impression on a declaration is a factual question, and absent cross-examination challenging the condition of the thumb or the recording witnesses, the declarations cannot be rejected on speculation. On these principles, the declarations were treated as reliable and the acquittal was held unsustainable.

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Issues: Whether the dying declarations and FIR recorded by the victim, despite 100% burn injuries and absence of a doctor's certificate, were reliable enough to sustain conviction and justify interference with the High Court's acquittal.

Analysis: A dying declaration may be oral or written, may be recorded without any prescribed form, and does not invariably require a doctor's certification if the person recording it is satisfied that the declarant was in a fit physical and mental condition. The evidentiary value depends on voluntariness, truthfulness, and the surrounding circumstances. Minor discrepancies between two declarations do not by themselves destroy the prosecution case where the core version remains consistent. The presence of a thumb impression on a declaration is a question of fact, and in the absence of any challenge in cross-examination to the condition of the thumb or to the witnesses who recorded the declarations, the declarations cannot be discarded merely on speculation.

Conclusion: The dying declarations were held reliable, the High Court's acquittal was found unsustainable, and the conviction recorded by the trial court was restored.

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