The Supreme Court recently overturned the conviction of a man sentenced to life imprisonment for murder, citing serious doubts about his mental state at the time of the offense.
A bench comprising Justice Abhay S Oka and Justice Ujjal Bhuyan emphasized that a person of unsound mind, referred to in law as a lunatic, cannot be held criminally responsible because they are unable to defend themselves. This right to self-defense is protected under Article 21 of the Constitution of India.
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“The law lays down that no act done by a lunatic is an offence. The reason is that a lunatic is not in a position to defend himself. Right to defend a charge for an offence is a fundamental right guaranteed under Article 21 of the Constitution of India,” the Court stated.
The appellant was convicted by the Trial Court under Sections 302, 352, and 201 of the Indian Penal Code, 1860, for an incident on September 27, 2018. He attacked Asam Gota with an iron pipe, killing him, and also chased a witness, Fagu Ram Karanga. The High Court later upheld this conviction.
Before the High Court, the appellant argued there was sufficient evidence to show he was mentally unstable during the incident. The court, however, dismissed this claim based on a medical report dated December 7, 2023, which declared the appellant to be of sound mind.
In the Supreme Court, the appellant's counsel highlighted witness testimonies indicating the appellant’s mental instability at the time of the incident. References were made to landmark cases—Dahyabhai Chhaganbhai Thakkar v. State of Gujarat and Rupesh Manger (Thapa) v. State of Sikkim—which establish that proving insanity under Section 84 of the IPC only requires raising a reasonable doubt.
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The State countered by stating the burden to prove insanity lies with the accused, which must be supported by evidence showing the accused’s conduct before, during, and after the offense. They argued that in the absence of medical proof from the time of the incident and with a later report showing normalcy, the High Court’s decision was justified.
The Court examined the precedents, including Surendra Mishra v. State of Jharkhand and Bapu Alias Gujraj Singh v. State of Rajasthan, which confirm that the accused must demonstrate legal, not just medical, insanity. The Court highlighted that an accused is protected if they were unaware of the nature or wrongfulness of their act at the time.
“Therefore, the burden to prove legal insanity is on the accused. It is enough if a reasonable doubt is created about the mental state of the accused at the time of the commission of the offence. The standard of proof to prove insanity is only a reasonable doubt,” the Supreme Court held.
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In the present case, the Court reviewed the depositions of witnesses. PW1 testified that the appellant had episodes of madness and was known in the village for his mental condition. PW2, an eyewitness, confirmed that the appellant’s mental health was poor, and he often quarreled with villagers. Similar statements were made by other witnesses, which the prosecution did not challenge in re-examination.
The Court found it surprising that the prosecution did not request a medical evaluation at the time, despite witness testimonies suggesting mental instability. It stated that the medical assessment conducted in December 2023, five years after the incident, was irrelevant for determining the accused’s mental condition during the crime.
As the prosecution witnesses’ statements created more than a reasonable doubt about the appellant’s mental state at the time of the offense, the Supreme Court concluded that he must be granted the benefit of doubt. The conviction and sentence were therefore set aside.
Appearance:
For Appellant: Mr. S. Mahendran, AOR
For Respondent: Mr. Abhishek Pandey, Standing Counsel Mr. Prashant Kumar Umrao, AOR
Case no. – Criminal Appeal No. 821/2025
Case Title – Dashrath Patra Appellant v. State of Chhattisgarh
