Pakala Narayana Swami v. Emperor, in its discussion of section 32(1) of the Indian Evidence Act, 1872…

In Pakala Narayana Swami v. Emperor the Privy Council held that a statement about the cause of the maker's death or the circumstances of the transaction resulting in death is relevant under section 32(1) of the Indian Evidence Act, 1872 (now section 26(a) of the Bharatiya Sakshya Adhiniyam, 2023) even if no death was expected when it was made, provided the circumstances have a proximate relation to the death. The case is thus a leading authority on "Dying Declaration".