Mapa Mudiyanselage Ananda Kumara vs. The Hon Attorney General – CA HCC/0044/20-2022
In the case between the Hon Attorney General for the Democratic Socialist Republic of Sri Lanka (Respondent) and Mapa Mudiyanselage Ananda Kumara (Accused-Appellant), the court addressed the issue of whether a conviction for murder could be sustained primarily on dying declarations. The court held that such evidence, if found credible and reliable, may suffice for conviction even in the absence of corroboration or proven motive. The principle reaffirmed is that, under Section 32(1) of the Evidence Ordinance, dying declarations can lawfully form the exclusive basis of conviction if they satisfy judicial scrutiny. The decision relied on established authorities governing the evidentiary standards for dying declarations and clarified the irrelevance of motive when sufficient evidence of guilt

