BAIRON SINGH vs STATE OF M.P.

The Supreme Court clarified the application of Section 32(1) of the Indian Evidence Act, establishing that statements made by a deceased person regarding the cause of death or circumstances leading to it are admissible, whether the death is a homicide or suicide. The Court emphasized that the test of proximity should not be rigidly applied and that statements relevant to the death, even if made shortly before it, can be considered as part of the transaction. The judgment reinforced that the solemnity of the oath taken by a dying person lends credibility to their statements, which are admissible under Section 32(1) regardless of the opportunity for cross-examination.