Seema, badly burnt, reaches a police station in Rewa and dictates an FIR saying that her husband poured…

Section 26(a) of the BSA makes a dead person's statement about the cause of death relevant, whether or not she expected to die, and it does not require any particular person to record it. So "It may be treated as a dying declaration under section 26(a) of the BSA, and the lack of a fitness certificate is not by itself fatal"; the Supreme Court has held that a doctor's certificate is not essential if the court is otherwise satisfied that the declarant was in a fit state of mind. Section 23 bars only confessions by an accused to the police, not statements by a victim.