In the landmark case Krishan v. State of Haryana (2013), the Supreme Court addressed the admissibility and evidentiary value of dying declarations under what was then Section 32 of the IEA (now Section 26 of BS

Krishan v. State of Haryana established the principle that while dying declarations are admissible under Section 26 of BSA (previously Section 32 IEA), they do not carry absolute credibility and must be corroborated in essential details by other evidence before forming the sole basis of conviction. The judgment emphasized that the solemn nature of dying statements requires Courts to treat them with caution and cross-verify them with other corroborating evidence. This principle balances the exception to hearsay rules with the requirement of fair trial and reliability of evidence. The decision also clarified that dying declarations can be made to anyone (including police) and admissibility is not contingent upon consciousness of imminent death as per Section 26(a) of BSA.