THE INDIAN PENAL CODE,1860

Shrikant Anand Rao Bhosale

V. State Of Maharshtra
2002 Cr. L.J. 4356 S.C.

Submitted To- Submitted By-

Dr. Pushpinder Kaur Shreya Bansal
BA-LLB (H)
52/14, Sec-A,
5th Semester
 Shrikant Anand Rao Bhosale V. State Of Maharshtra 52/14

ACKNOWLEDGEMENT

I would like to express my gratitude towards Dr. Pushpinder who has helped me in the making of
this project. Without her support and guidance, this project would have been impossible.

I would also like to thank Prof Sangita Bhalla for the opportunity to study in this esteemed
institution.

Last but not the least, I would like to thank my friends for their love and support.

___________________

Shreya Bansal

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CONTENTS

ACKNOWLEDGEMENT .............................................................................................................. 2

TABLE OF CASES ........................................................................................................................ 4

INTRODUCTION .......................................................................................................................... 5

CASE DETAILS ............................................................................................................................. 7

PROCEDURAL HISTORY............................................................................................................ 7

FACTS OF THE CASE .................................................................................................................. 8

ISSUES INVOLVED...................................................................................................................... 9

1. Unsoundness of mind ........................................................................................................... 9

2. Burden Of Proof ................................................................................................................... 9

Arguments Advanced.................................................................................................................... 11

1. On Behalf of the Appelant ................................................................................................. 11

2. On behalf of the Respondent.............................................................................................. 11

JUDGEMENT / ORDER OF THE COURT ................................................................................ 12

RATIO DECIDENDI.................................................................................................................... 13

CRITICAL ANALYSIS ............................................................................................................... 16

TWO RELATED CASE LAWS ................................................................................................... 18

1. RADHEY SHAM v. STATE ............................................................................................. 18

2. SUDHAKARAN v. STATE OF KERALA .......................................................................... 19

BIBLIOGRAPHY ......................................................................................................................... 20

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TABLE OF CASES

1. Dahyabhai Chhaganbhai Thakker v. State of Gujarat (1964) 7 SCR 361…………….14

2. Queen v. M'Naghten; 8 ER 718, Vol. 8…………………………………………………….5

3. Radhey Sham V. State ( Delhi HC 2010) Cr. Appeal No. 871/2004…………………........18

4. Shrikant Anand Rao Bhosale V. State Of Maharshtra 2002 Cr. L.J. 4356 S.C..……….…6

5. Siddhapal Kamala Yadav v. State of Maharashtra 2009 CrLJ 372 (SC)…………………18

6. Sudhakaran V. State Of Kerala (2011) I Cr. L. J 292 (SC)……………………......…..…19

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INTRODUCTION

A person can be held liable for any act he commits, only if he does it with his wish and free will.
It is considered that motive is a must for a criminal act. A mere commission of act does not prove
a person guilty.
Plea of mental illness or unsoundness of mind is usually brought forward by defense in order to
save the accused from capital punishment.' The law presumes every individual at the age of
discretion, to be sane and to possess a sufficient degree of reason to be responsible for his
criminal acts, unless the contrary is proved to the satisfaction of the court.1
The physical act alone does not make a person guilty; as the presence of a guilty mind is equally
important. A mentally ill person is not punished for his crime, as he isdevoid of free will and
knowledge of the act he does.
An important precedent for the cases involving insanity is the M' Naghten2 Case Rules which
laid down the following guidelines:
Every person is presumed to be sane, until the contrary is established.
To establish the defense of insanity, it must be clearly proved that at the time of committing the
crime, the person was so insane as not to know the nature and quality of the act he was doing or
if he did know it, he did not know that what he was doing was wrong.
The test of wrongfulness of the act is in the power to distinguish between right and wrong, not in
the abstract or in general, but in regard to the particular act committed.3

The English law on insanity is based on the M'Naghten rules and the Indian Law that is codified
in the Indian Penal Code, 1860 S. 84, is also based on the M'Naghten rules.

Bringing India to a greater focus, the Section 84 of the Penal Code of India states that":

1
Knight, Bay; Medical Jurisprudence and Toxicology. 6th ed. Allahabad: The law Book Company p.vtLtd; 1990. p.
516-519.
2
Queen v. M'Naghten; 8 ER 718, Vol. 8.
In this case, the defendant I.e. M'Naghten under a delusion killed Edward Drummond under paranoid delusion
believing him to be the Prime Minister of the UK. On establishing him to be of unsound mind, the House of Lords
found him to be not guilty, leading to a great uproar in the country. The HL then came up with the rules which were
to then govern the decisions in such cases.
3
http://medind.nic.in/jal/t06/i4/jalt06i4p180.pdf accessed on 11/11/2016 at 10.54 pm.
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''Nothing is an offence which is done by a person who, at the time of doing it, by reason of
unsoundness of mind, is incapable of knowing the nature of the act, or that he is doing what is
either wrong or contrary to law.''
This is given as a defense because there is absence of mens rea on the part of the accused as he is
suffering from a defect of mind.

This case of Shrikant Anand Rao Bhosale V. State Of Maharshtra4 deals with application of
Section 84 of the Indian Penal Code.
Section 84 lays down the legal test of responsibility in cases of alleged unsoundness of
mind. There is no definition of ‘unsoundness of mind’ in IPC. The courts have, however, mainly
treated this expression as equivalent to insanity. But the term ‘insanity’ itself has no precise
definition. It is a term used to describe varying degrees of mental disorder. So, every person, who
is mentally diseased, is not ipso facto exempted from criminal responsibility. A distinction is to
be made between legal insanity and medical insanity. A court is concerned with legal insanity,
and not with medical insanity.
Also, each case which deals with the defence of insanity under section 84 has to deal with
the question of the burden of proof of proving the same. The initial burden of proof lies on the
accused to prove that he is of unsound mind. This is covered under the provision of Section 105
of Indian Evidence Act. Thus every case has to be decided on the basis of all the questions of law
and also the facts and circumstances.

4
2002 Cr. L.J. 4356 S.C
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CASE DETAILS

PETITIONER:
Shrikant Anandrao Bhosale

RESPONDENT:
State of Maharashtra

Date of Judgment: 26/09/2002

Bench: Y.K.Sabharwal, H Sema

Equivalent Citations: 2002 Cr. L.J. 4356 S.C.

PROCEDURAL HISTORY

The appellant was found guilty by the Sessions Court of the offence under Section 302 of
the Indian Penal Code (IPC) and sentenced to undergo rigorous imprisonment for life. The
appeal against conviction and sentence having been dismissed by the High Court, appeal was
filed again in Supreme Court, on grant of leave .

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FACTS OF THE CASE

 The appellant was a Police Constable. He and Surekha were married in the year 1987.

 On the morning of 24th April, 1994, there was a quarrel between husband and wife.
While Surekha was washing clothes in the bathroom, the appellant hit her with grinding
stone on her head. The appellant was immediately taken by the police to the quarter
guard. Surekha was taken to the Hospital. She was found dead . After usual investigation,
the appellant was charged for the offence of murder of his wife.

 The weak motive of killing of wife being that she was opposing the idea of the appellant
resigning the job of a Police Constable.

 The appellant has a family history that his father was suffering from psychiatric illness.

 Cause of ailment not known - hereditary plays a part.

 Appellant was being treated for unsoundness of mind since 1992 Diagnosed as suffering
from paranoid schizophrenia.

 Within a short span, soon after the incident from 27th June to 5th December, 1994, he
had to be taken for treatment of ailment 25 times to hospital.

 Appellant was under regular treatment for the mental ailment.

 In support of his contention he relied on past psychiatric treatment and the testimony of
two medical doctors who prepared his medical record and stated that he suffered from
suspicious ideas, persecutory delusions, loss of sleep and was a paranoid schizophrenic.

 Insanity of the appellant, at the time of commission of the offence, is the main plea that
was urged before the court.

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ISSUES INVOLVED

1. Unsoundness of mind
Section 84 of Indian Penal Code states that unsoundness of mind is a defence to a criminal
liability. It has been accepted as a defence to a criminal charge on the theory that ‘one who is
insane has no mind and hence cannot have the necessary mens rea to commit a crime’.

Unsoundness of mind is commonly termed insanity and according to medical science, is a

disorder of the mind which impairs the mental faculties of a man. In other words, insanity is
another name for mental abnormality due to various factors and exists in various degrees.

To invoke the benefit of section 84, it must be proved that at the time of commission of the
offence, the accused was non compos mentis and that unsoundness of mind was of such a degree
and nature as to fulfill one of the tests laid down in the section. These are:-

 Firstly, the accused was incapable of knowing the nature of the act and,

 Secondly, that the accused was precluded by reason of unsoundness of mind from
understanding that what he was doing was either wrong or contrary to law.

2. Burden Of Proof

When a plea of insanity is set up by the accused, the burden of proof is on him to prove it. But a
man, who is insane will not be able to defend himself properly and effectively. It is, therefore,
the duty of the court to look after the defence of the accused in the light of the evidence on
record.
The Hon'ble Supreme Court has stated the legal position regarding the burden of proof in the
context of the plea of insanity in the following propositions:-

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i. The prosecution must prove beyond reasonable doubt that the accused had committed the
offence with the requisite mens rea; and the burden of proving that always rests upon the
prosecution from the beginning to the end of the trial;
ii. There is a rebuttal presumption that the accused was not insane, when he committed the
crime, in the sense laid down in Section 84; the accused may rebut it by placing before
the Court all the relevant evidence-oral, documentary or circumstantial, but the burden of
proof upon him is no higher than that which rests upon a party in civil proceedings, that
is, to prove his defence by a preponderance of probability;
iii. Even if the accused was not able to establish conclusively that he was insane at the time
he committed the offence, the evidence placed before the Court by the accused or by the
prosecution may raise a reasonable doubt in the mind of the Court as regards one or more
of the ingredients of the offence, including mens rea of the accused and in that case the
Court would be entitled to acquit the accused on the ground that the general burden
resting on the prosecution has not been discharged.

The plea of insanity holds water due to the fact that the previous insanity of the accused has been
ratified by expert opinion, admissible under sec 45 of the Indian Evidence Act.

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Arguments Advanced

1. On Behalf of the Appelant

 The counsel on the behalf of the appellant argued that the appellant was suffering
from insanity at the time of alleged killing of his wife and was, thus, entitled to
benefit of general exception contained in Section 84 IPC.

 Also, the learned counsel for the appellant to establish the plea of unsoundness of
mind, drew the attention of the court to the depositions of Dr. Arun and
Dr.Pramod who said that medical history of the appellant was conclusive in
nature to prove him as a person with an unsound mind

2. On behalf of the Respondent

 With equal vehemence and ability, Mr. Arun Pednekar argued that the appellant
killed his wife not because of insanity but on account of extreme anger, which is
different from insanity.

 The counsel for the State, relying upon prosecution witnesses, contended that the
appellant, earlier than the date of incident, used to quarrel with his wife; drink
excessive liquor and used to get excited and this evidence proves that he, by
nature, was a man of extreme anger. During fit of extreme anger, he killed his
wife.

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JUDGEMENT / ORDER OF THE COURT

Having regard to the nature of burden on the appellant, the view of judges was that appellant has
proved the existence of circumstances as required by Section 105 of the Evidence Act, so as to
get benefit of Section 84 IPC. They were unable to hold that the crime was committed as a result
of extreme fit of anger. There was a reasonable doubt that at the time of commission of the
crime, the appellant was incapable of knowing the nature of the act by reason of unsoundness of
mind and, thus, he was entitled to the benefit of Section 84 IPC. Hence, the conviction and
sentence of the appellant could not be sustained.

Hence, the appeal was allowed in this case, and the plea for defence under Section 84 was
granted to the appellant.

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RATIO DECIDENDI

The defence of insanity is recognized in India by virtue of Section 84 of the Indian Penal Code
which reads as under:-
“Sec.84: Nothing is an offence which is done by a person who at the time of doing it, by reason
of unsoundness of mind, is incapable of knowing the nature of the act, or that he is doing what is
either wrong or contrary to law.”

Under Section 45 of the Evidence Act an opinion of an expert on a matter of science, technical or
special knowledge is admissible evidence to guide the tier of the fact to understand the
scientifically recognized principles with reference whereto a question of fact has to be
determined. Thus, where a plea of insanity has been set up as a defence, the tier of the facts may
seek the assistance of an expert but the decision cannot be delegated to the expert and has to be
decided by the tier of the facts i.e. the Court.

“Section 84 lays down the legal test of responsibility in cases of alleged unsoundness of mind.
There is no definition of ‘unsoundness of mind’ in IPC. The courts have, however, mainly
treated this expression as equivalent to insanity. But the term ‘insanity’ itself has no precise
definition. It is a term used to describe varying degrees of mental disorder. So, every person, who
is mentally diseased, is not ipso facto exempted from criminal responsibility. A distinction is to
be made between legal insanity and medical insanity. A court is concerned with legal insanity,
and not with medical insanity.”

An accused who seeks exoneration from liability of an act under Section 84 of the Indian Penal
Code is to prove legal insanity and not medical insanity. Expression “unsoundness of mind” has
not been defined in the Indian Penal Code and it has mainly been treated as equivalent to
insanity. But the term insanity carries different meaning in different contexts and describes
varying degrees of mental disorder. Every person who is suffering from mental disease is not
ipso facto exempted from criminal liability. The mere fact that the accused is conceited, odd,
irascible and his brain is not quite all right, or that the physical and mental ailments from which
he suffered had rendered his intellect weak and affected his emotions or indulges in certain

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unusual acts, or had fits of insanity at short intervals or that he was subject to epileptic fits and
there was abnormal behavior or the behavior is queer are not sufficient to attract the application
of Section 84of the Indian Penal Code.

Next question which needed consideration was as to on whom the onus lied to prove
unsoundness of mind. In law, the presumption is that every person is sane to the extent that he
knows the natural consequences of his act. The burden of proof in the face of Section 105 of the
Evidence Act is on the accused. Though the burden is on the accused but he is not required to
prove the same beyond all reasonable doubt, but merely satisfy the preponderance of
probabilities. The onus has to be discharged by producing evidence as to the conduct of the
accused prior to the offence, his conduct at the time or immediately after the offence with
reference to his medical condition by production of medical evidence and other relevant factors.
Even if the accused establishes unsoundness of mind, Section 84 of the Indian Penal Code will
not come to its rescue, in case it is found that the accused knew that what he was doing was
wrong or that it was contrary to law. In order to ascertain that, it was imperative to take into
consideration the circumstances and the behavior preceding, attending and following the crime.
Behaviour of an accused pertaining to a desire for concealment of the weapon of offence
and conduct to avoid detection of crime go a long way to ascertain as to whether, he knew the
consequences of the act done by him.

It was necessary to notice the nature of the burden that was required to be discharged by the
accused to get benefit of Section 84 IPC. In Dahyabhai Chhaganbhai Thakker v. State of
Gujarat5 the Court had held that even if the accused was not able to establish conclusively that
he was insane at the time he committed the offence, the evidence placed before the Court may
raise a reasonable doubt in the mind of the Court as regards one or more of the ingredients of the
offence, including mens rea of the accused and in that case the court would be entitled to acquit
the accused on the ground that the general burden of proof resting on the prosecution was not
discharged.

5
(1964) 7 SCR 361
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In a case where the exception under Section 84 of the Indian Penal Code is claimed, the court
had to consider whether, at the time of commission of the offence, the accused, by reason of
unsoundness of mind, was incapable of knowing the nature of the act or that he was doing what
is either wrong or contrary to law. The entire conduct of the accused, from the time of the
commission of the offence up to the time the sessions proceedings commenced, was relevant for
the purpose of ascertaining as to whether plea raised was genuine, bona fide or an afterthought.
Hence all the facts and circumstances were required to be taken into account while deciding
upon the defence of insanity under section 84 of the code.

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CRITICAL ANALYSIS

In a case where the exception under Section 84 of the Indian Penal Code is claimed, the
court has to consider whether, at the time of commission of the offence, the accused, by reason
of unsoundness of mind, was incapable of knowing the nature of the act or that he is doing what
is either wrong or contrary to law. The entire conduct of the accused, from the time of the
commission of the offence up to the time the sessions proceedings commenced, is relevant for
the purpose of ascertaining as to whether plea raised was genuine, bona fide or an afterthought.
The issue of medico-legal insanity which is often introduced in courts and creates a lot of doubt
regarding the condition of the insane and his mindset during the commission of crime has to be
discussed in each and every case. There are three compartments of the mind - controlling
cognition, emotion and will. IPC Sec. 84 only exempts one whose cognitive faculties are
affected. The provision is regarded as too narrow, and makes no provision for a case where one’s
emotion and the will are so affected as to render the control of the cognitive faculties ineffectual.
The Courts must also adopt a broader view of the Insanity and introduce the concept of
diminished responsibility.
The present law on insanity does not make room for sudden provocations or disturbed mental
states and other such conditions.
For instance:
 For a person in Depressive state, suicidal thoughts are common occurrences. If such a
person attempts to commit suicide and seeks protection under the Section 84 of the IPC,
as depression is still seen an emotional state/he won't be pardoned under the current law.
 The same rationale of our law goes and will find a new mother, who's going through
rapid hormonal changes and emotional disturbance, guilty after she commits infanticide.
The punishment in this case is double, the mother has to go through the loss of her child
which she couldn’t have prevented owing to her extreme emotional state and the
punishment that law inflicts on her.
Also the burden of proof in each case has to be decided by the court in the light of provisions of
law. According to my view, Section 105 of the Evidence Act, has justified the plea for defence of
insanity. The burden of proof must lie on the accused who is demanding the relief under Section
84 of the Indian Penal Code. This not only helps in speedy recovery of the facts but also speeds

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up the decision making process of the courts. This burden on the accused ceases when he/she
proves the insanity beyond reasonable doubt. Now the burden of proof shifts on the prosecution
to prove that whether or not the accused is insane, he was aware of all the consequences of his
act at the time of commission of the offence.
The laws of other countries including that of UK from whom we have borrowed the M'Naghten
Verdict have completely changed their earlier interpretations of the Unsoundness of Mind.
 USA and UK along with other countries have allowed for the appeals of temporary
insanity as these are the cases where the person has neither a history of mental disease
nor shows any symptoms but while committing the act has lost control over his/her
mental faculties due to extreme emotional states.
 In crimes of passion, the liability has been reduced as these are the cases where the
accused has the knowledge of both the law and the nature of the act but loses control over
his mental faculties due to extreme emotional states.
 In the USA, the plea of Temporary Insanity was first used by U.S. CongressmanDaniel
Sickles of New York in 1859 after he had killed his wife's lover, Philip Barton Key. The
defense was later used commonly during the 1940s and 1950s.

Thus in my opinion, the difference between Medical and Legal insanity should subsist but the
horizons and the reach of the latter should be stretched to cover all Human Possibilities and
Justifications of human behavior..

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TWO RELATED CASE LAWS

1. RADHEY SHAM v. STATE

( Delhi HC 2010) Cr. Appeal No. 871/2004

In the instant case, the accused murdered Raghubir Malhotra with an ice pick. The brother of the
deceased ran towards him after hearing the cries for help. On arrival he along with 2 others saw
the accused stabbing the victim and making several stab wounds.
The post mortem report showed that the wounds were made by two weapons and the ice pick
was only later grabbed to stab the victim.
The Counsel for the accused appealed for a medical examination on the grounds of his
unsoundness of mind. In the first examination, no mental defect or disease was found. However
on the re-examination it was found that the accused was suffering from undifferentiated
schizophrenia wherein its symptoms are not particularly recognizable. The doctors could have
only diagnosed it on studying the medical and psychological history of the patient which was
made available to them only after the 1st examination. It was also found that though he was never
violent or aggressive, he was deposed to mental illness as a result of which children used to
throw stones at him.
The court in application of the Section 84 of the IPC held that even though once the diagnosis of
the schizophrenia has come to light along with other testimonies of the witnesses, it would be
naive to allow the appeal only on that ground. It is also necessary to establish that the accused
suffered from it during the time of the commission of the act which in this instant case was not
possible. Looking at how grotesque the act was, it would again not be legally fit to allow the
appeal solely on that ground. However, the prosecution could also not affix a motive for murder
on the accused and keeping all these three elements in mind along with the M'Naghten rules and
the Siddhapal Kamala Yadav v. State of Maharashtra6case, the Court allowed the appeal of the
accused.

6
2009 CrLJ 372 (SC)
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2. SUDHAKARAN v. STATE OF KERALA

(2011) I Cr. L. J 292 (SC)

The accused was alleged to have committed murder of his wife. While he had brutally committed
murder of his wife with a chopper, he did not cause any hurt or discomfort to his child. Rather he
made up his mind to ensure that child be put into proper care and custody after murder. He made
sure that his 8 month old did not watch the gory act and tried handing the child over to his
neighbor.
In his defense he pleaded unsoundness of mind. He was suffering from paranoid schizophrenia.
It was held that burden is on accused to prove that by reason of unsoundness of mind, he was
incapable of knowing the nature of act committed by him.
In this case conduct of accused before and after incident was held sufficient to negate any notion
that he was mentally insane so as not to be possessed of necessary mens rea for committing
murder of his wife. However, the man after committing the act remarked to the neighbors who
had collected outside his house that "till today she had been cheating me". This gave him the
necessary motive. Which as the accused said that it was his delusion which made him act that
way.
However, according to the rules set down in M'Naghten's case, it did not negate that he did not
know whether the act was contrary to the law and was wrong.
The diagnostic reports of the appellant further showed that he suffered from paranoia which is a
mild form of schizophrenia. Only evidence placed on record shows that accused had been treated
in psychiatric hospital for 13 days some 15 years prior to incident.
Therefore, his conviction for murder was held to be proper.
The SC found the appeal for S 84 sans merit and dismissed it.

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BIBLIOGRAPHY

BOOKS:
 Gaur K.D, Fourth Edition,A Text Book on IPC.
 Misra, S.N., Indian Penal Code (Central Law Publications, Allahabad) 12th edn. 2016.
 Chandrachud YV. Ratanlal and Dhirajlal's The Indian Penal Code. 28thed. Agra: Wadhwa
& Company Law Publishers; 2001.
 Knight, Bay; Medical Jurisprudence and Toxicology. 6th ed. Allahabad: The law Book
Company p.vtLtd; 1990. (online copy from allbookslegal.co.uk)

WEB:
 www.westlaw.com
 www.legalperspectives.in
 www.indialawjournal.com
 http://crimes.indlaw.com/search/articles/?fffde2f4-ea4e-42ef-b94b-bdd9b94092d4
 http://indiankanoon.org/doc/1923024/
 http://indiankanoon.org/search/?formInput=section%2084%20of%20ipc%20%20%20%20
doctypes%3A%20judgments&pagenum=3

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