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In Laxman v Maharashtra, 1the Supreme Court held:

A dying declaration can be oral or in writing and any adequate method of communication whether by words
or by signs or otherwise will suffice provided the indication is positive and definite.

In Meesala Ramakrishan v State ofAP,2 the Court has considered the evidentiary value of a dying declaration
recorded by

12002 SCC (Cri) 1491,


2,1994 (2) Ren CR (Criminal) 675: (1994) 4 SCC 182

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