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K. Sai Saketh, Svkm’s Narsee Monjee Institute of Management Studies, Bengaluru.
Facts: –
Dayabhai Chhaganbhai Thakkar, who will be referred to as the plaintiff going forward, was the son of Chhaganbhai and the spouse of the late Kalavati. She got married to the appellant in 1958. But their marital connection was suffering as a result of their lack of interest in one another. On the evening of April 9, 1959, the appellant and his spouse were resting in their bedroom, which had closed doors from the inside. Kalavati suddenly cried out that she was going to be killed around three or four in the morning.Upon hearing about this, the neighbors gathered in front of the specified room and had the accuser open the door. They discovered Kalavati was dead and had several wounds when the door was unlocked. The accused was brought in for a session hearing about the murder charge.A defense team presented evidence before Additional Sessions Judge Kaira that the accused was mentally ill at the time of the alleged incident and was unable to comprehend the nature of his actions.1
Procedural history
The experienced Additional Sessions Judge took into account all of the facts presented to him and came to the conclusion that the accused had not persuaded him that he was incapable of knowing the nature of the deed when he killed his wife. Furthermore, what he was doing was illegal or immoral. The learned Additional Sessions Judge dismissed his claim that he was insane, finding him guilty in accordance with section 302 of the Indian Penal Code and giving him a life term for his harsh incarceration. The High Court upheld the accused’s convictions after reviewing the case and concurring with that conclusion for specific grounds. This appeal was filed through a special leave petition against the High Court’s ruling.
Issue: –
- Why did the appellant murder his wife with 44 knives, inflicting horrific injuries on her body, and what was his motivation?
- Could you provide the accused past medical history?
3.What are the different assessments made in accordance with section 84 of the IPC (insanity)? Arguments Advanced:
Arguments by the Appellant
Even on the night of the incident, when the accused opened the door and emerged from the room with a blood-stained knife, the appellant alleged that the accused was insane two or three days before to the incident. The accused also began to speak irrelevantly, asking, “Why did you kill my mother?” You set my father’s house on fire—why? .Then the accused began to laugh incoherently as he sat there and began hurling mud and dust at the people who had assembled. To put it briefly, the accused killed the deceased while he was experiencing a hallucination that he had killed his mother and set fire to his father’s home, not realizing what he was doing.
Arguments by the Respondents
Respondents contended that why had the accused’s father and wife traveled to Ahmedabad on the day of the occurrence if the accused had lost his mind two or three days prior to the incident? .If the accused had been insane for a day or two before to the occurrence, is it possible that both of his parents would have abandoned him? He added that he took the accused’s medications while in Ahmedabad looking for a groom for his daughter. But he refrained from naming the physician he saw or if he purchased any drugs. if the defendant’s insanity was fit. Is it likely that he and his wife shared a room for their sleep? Furthermore, they had not immediately described the accused’s condition when he arrived.
Judgement: – Following receipt of the certificate from the Medical Officer, which stated that the accused’s mental state was not mentioned, the Superintendent of Mental Hospital, Baroda, sent a report indicating that the accused could understand the court proceedings and presenting his
defense.When a legal insanity plea is established, the court must decide if the accused was not mentally competent enough to understand the act or that what he was doing was illegal or improper at the time the offense was committed. When the offense was committed is the critical moment for determining the accused’s mental state. It is only possible to determine if the accused was in a mental condition that qualified them for the protection of Section 84 of the Indian Penal Code by looking at the events that led up to, included, and concluded with the crime.After interrogation, the court determined the accused could understand the events in the case and defend himself. The accused’s petitioner claimed at the start of the trial that they could understand what was going on. The accused was mad for a brief while after the matter was brought before the Sessions Judge, according to his proceedings. As a result, the court finds no proof of insanity in the discovered papers. That fact, however, would not prove that the accused had been experiencing fits of insanity for four or five years before the occurrence, nor that he had experienced a severe enough fit of insanity at the time of his wife’s murder to warrant Section 84 of the Indian Penal Code’s protection.
In summary, the Court finds that the accused did not like his wife. Despite working in Ahmedabad for approximately ten months, he did not bring his wife with him. Instead, he wrote a letter to his father-in-law telling him to take his wife away to his house because he did not like her. The father-in-law promised to arrive on Chaitra Sudhi 1, but the accused expected him to arrive on April 9, 1959, and he allowed his wife to remain in his home until then. When his father-in-law failed to arrive on or before April 9, 1959, the accused killed his wife out of rage or frustration. The evidence does not even raise a reasonable doubt in our minds that the crime may have been committed during the accused’s period of insanity; it has not been proven that he was mad. Therefore, the Court rejects the appeal and concurs with the High Court’s decision, albeit for different reasons.
CONCLUSION
Both culpable homicide—which is the same as murder—and insanity are being included into this case. When concepts like the burden of proof and reasonable doubt are applied, such as whether an individual was mentally ill to the point where they were unable to understand the nature and consequences of their actions, it is vital and difficult for the courts to appropriately recognize all
the facts and pieces of evidence in such important cases. Although the accused—the petitioner— filed a plea of insanity in this instance, there was insufficient evidence to support the accused’s insanity. On the other hand, the evidence found at the murder scene and the accused’s reports demonstrated that he was competent both physically and intellectually at the time of the murder, and as a result, the appropriate conclusion was made.
