CONSENT UNDER IPC

The research proposal is submitted in partial fulfilment of course criminal law-1 for obtain
degree BBA LLB. (hons.) during academic session 2019-20.

Submitted By-
Madhavi Bohra
Roll no. 2023
Submitted to-
Dr. Father Peter Ladis,

Faculty of Criminal Law

BBA. LLB. (hons.) 2019-20.

September, 2019

Chanakya national law university, Mithapur Patna 800001.

Contents
1. Introduction- Meaning of consent ...................................................................................... 3
1.1 Objective of study- ...................................................................................................... 4
1.2 Hypothesis-.................................................................................................................. 4
1.3 Research questions- ..................................................................................................... 4
1.4 Research methodology- ............................................................................................... 4
1.5 Sources of data- ........................................................................................................... 4
1.6 Limitation of the study: ............................................................................................... 5
1.7 Scope of study: ............................................................................................................ 5
1.8 Literature review- ........................................................................................................ 5
2. Types of consent: ............................................................................................................... 6
3. Situations where consent is valid and invalid: ................................................................... 8
3.1 Fear of injury-.............................................................................................................. 8
3.2 Misconception of facts- ............................................................................................... 8
3.3 Honest misconception of both parties- ........................................................................ 9
3.4 Consent of persons- ................................................................................................... 10
 Section 82 and 83- ................................................................................................. 10
 Section 84- ............................................................................................................. 11
 Section 85 and section 86- ..................................................................................... 12
4. Benevolence act with or without consent- ....................................................................... 13
4.1 no criminal intention to cause death- ........................................................................ 13
4.2 Act done in good faith for benefit of child or insane person, by or by consent of
guardian: .............................................................................................................................. 14
4.3 benevolence act for benefit of the person- ................................................................ 15
4.4 communication made in good faith-.......................................................................... 15
5. Conclusion, criticism and suggestion- ............................................................................. 16
6. Hypothesis conclusion- .................................................................................................... 18
7. Bibliography- ................................................................................................................... 19
7.1 Books- ....................................................................................................................... 19
7.2 Websites- ................................................................................................................... 19

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 1. Introduction- Meaning of consent

Volenti non-fit injuria, an old roman law maxim, signifying that harm caused with consent
cannot be considered an injury, plays some role in criminal law. Consent of a victim, subject
to some limitations that are imposed in social interest, operates as an extenuating factor.
However, modern criminal law, generally does not absolve a person from criminal liability for
acts posing threat or causing to human life. Nevertheless, a doer is protected from criminal
liability if he, in good faith, causes or takes risk of causing injury, with or without consent, for
the benefit of the sufferer. Section 94 exempts a person from criminal liability for acts
committed, with specified exceptions, under compulsion or duress. The word consent is not
defined under the general clauses act of IPC. But it is defined in indirect manner it means
consent is defined under Indian penal code in negative sense covers the sections from 87-92.
Sec. 87 to Sec. 92 explains about the provisions of Consent. When a person wilfully consents
an injury, he cannot blame the person, who inflicted the injury. Especially in case of medical
treatment, the doctor gives injection. It gives pain. We bear it.

Under criminal law, the mens rea has much importance in judicial system of every country
rather it is the basis of punishing or acquitting a person. If an offence is committed in the
presence of mens rea, the act is punishable and if absence of mens rea is found, the alleged
person is acquitted honourably. Upon this criterion the whole criminal law is based. Chapter
IV (General Exceptions) of I.P.C. is based on absence of mens rea. Consent means something
that is done deliberately and by free will. It is concurrence of will.1 It is deliberate exercise of
intelligence based on knowledge of significance and moral effect of the act.2 It consists of three
things- physical power, mental power, and free will.

1
Hari singh gaur, penal law of india. Vol. 1, 11th edition law publishers Allahabad 1998. P. 746. Retrieved- 11:00,
1st September
2
Tulsidas kanolkar v. state of goa 2003 8 SCC (590). Retrieved- 11:10, 1st September.

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 1.1 Objective of study-
 To know the defences of the consent.
 To study in which conditions the consent is said to be invalid.
 To study in depth how the consent is defined in negative sense under IPC.

1.2 Hypothesis-
The researcher believes that-
 Consent of a child is not always a valid consent.
 Consent of an insane person is not a valid consent.

1.3 Research questions-

 Whether a consent has negligible importance if given by person of unsound mind,
intoxicated person or a minor?
 Whether keeping knowledge of any thing, without expressing any intention amounts to
consent?
 It is also to be seen whether consent had importance in deciding criminal cases?

1.4 Research methodology-

The researcher will do doctrinal type of research in which he will go through the primary as
well secondary sources. The researcher through this methodology will be able to get an exact
picture of the problem in question. The doctrinal method helps in doing a comparative study
of the topic. This methodology helps in going through not only the work of one eminent person
but of many other too. This helps in getting the bird’s eye view of the subject.

To satisfy the need of the project, the researcher will go through section by section and clause
by clause of each section in question. Then, the researcher will cross checked the commentary
of those provisions. This methodology will be the most effective way in preparing the project.

The researcher has also focused on supreme court judgement which led to changes in
provisions regarding the grounds of consent.

1.5 Sources of data-

The researcher will collect data from both primary as well as secondary sources.
i. The primary source:

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1. Indian penal code.
ii. The secondary sources are:
1. Books and bare acts.

1.6 Limitation of the study:

Since the researcher is a student of law, he has access to a limited area. The researcher having
read the commentary on the IPC could understand the problem clearly but it would have been
clearer if he would have read commentary of more writers. The researcher has limited time for
the project. The historical need and background is also necessary for having a bird’s eye view
of the particular topic and it gets developed only by effective and extended reading over a long
period of time. But the required materials are not available in our library. The researcher has a
restricted access to the reports of the law commission where the reasons of their work I not
available. But still researcher with his hard work will manage to take out the best possible work.

1.7 Scope of study:

The researcher will begin by briefly dealing with definition of consent and defences of the
consent along with these legal maxims and other supplementary sections which assists these
sections will also be explained using case laws and illustrations in furtherance of the same and
then conclude with explaining the points where the demarcation lies.

1.8 Literature review-

Books-

o Ratanlal and dhirajlal Book- lucid and clear explanations of the sections and cases of
related topics.
o P S A Pillai Book- negatively defined consent, all conditions are explained where
consent is considered as valid or invalid.
o Indian penal code 1860, Bare act- definition and explanation of all the sections.

Websites-

o indiankanoon- judgements of the case with their citations.

o Advocatekhoj- briefly defined setion with their suitable examples.

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 2. Types of consent:

The consent is negatively defined under Indian penal code 1860. And under section 14 of Indian
contract act 1872. The definition of consent under the law of contract that it is an agreement of
two or more persons upon the same thing in the same sense means that the parties to the contract
should be ad idem, that is to say, must be of the same intention regarding the matter agreed
upon. On this basis it has been held that consent obtained by undue influence, fraud, coercion,
mistake or misrepresentation is not a valid consent in the law of contract. A similar provision
has been made under this section.

The essential ingredients of section 90 defines the types of invalid consent. thereby, we can
easily deduce the valid consent.

The section in its first paragraph states that a consent given by a person under fear of injury, or
under a misconception of fact, is not a valid consent provided the person doing the act knows
or has reason to believe that the consent was given in consequence of such fear or
misconception. This latter part is very important in the sense that mere giving of a consent
under fear of injury or misconception of fact is not enough. The consent becomes not a valid
consent only when the taker of the consent also knows or has reason to believe that the person
giving the consent is acting under such fear or misconception.

The second paragraph of the section deals with consent given by persons of unsound mind or
persons who are intoxicated. It says that consent given by a person who because of unsoundness
of mind or intoxication is not able to understand the nature and consequence of that to which
he gives his consent, is not a valid consent.

It is not necessary that intoxication must be without one’s knowledge or against one’s will as
is necessary in the defence of intoxication provided under section 85 of the Indian Penal Code.
It is important part that whether the taker of the consent knows or not that the giver of the
consent is a person of unsound mind or is an intoxicated person is not at all relevant.

The third paragraph of the section states that consent given by a person under twelve years of
age is not a valid consent unless there is any provision to the contrary in the context. This means
that the general law is that a child below twelve years of age is incapable of giving consent but
if there is specific provision to the contrary or the contrary appears from the context, then the
general law is superseded to that extent.

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The following ingredients are concluded from above interpretation of section 90-

 Fear of injury
 Misconception
 Fraud
 Consent of persons-
 Insane
 Child
 Intoxicated.

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 3. Situations where consent is valid and invalid:

3.1 Fear of injury-

According to section 44 of the Code the word ‘injury’ denotes any harm whatever illegally
caused to any person in body, mind, reputation or property. Consequently, consent given under
fear of injury is not limited to physical injury even though in most of the cases which come up
before the Courts the question of consent given under fear of physical injury is involved. In
Dasrath Paswan v. State the accused was quite upset mentally after having failed in the High
School examination for three years in a row. He told his wife, a literate woman of about
nineteen years, that he wanted to die. The wife asked him to kill her first and then kill himself.
The accused killed her and then before he could kill himself, he was arrested. The Supreme
Court held that the deceased wife had given her free consent to be killed by her husband and,
therefore, the accused was guilty of culpable homicide not amounting to murder only under
section 304, Part I and not of murder under section 302 of the Code. A lenient view was taken
and he was sentenced to five years’ rigorous imprisonment.

3.2 Misconception of facts-

In a case3. the deceased allowed himself to be bitten by a snake on the misconception created
in his mind by the accused that the accused had power to cure him and that the deceased would
not die. It was held that the deceased had consented to be bitten by a snake under a
misconception of fact and that the accused also knew or had reason to believe that the consent
had been given by the deceased under such misconception. Consequently, it was not a valid
consent under this section.

in a case 4the question was as to whether the accused had raped the complainant. The accused
was a frequent visitor to the house of the complainant. In course of time the accused and the
complainant prosecutrix felt attracted towards each other.

The accused gave the impression that he would soon marry her. Sexual relations developed
between them. When she became pregnant she insisted that the accused should marry her

3
Poonai Fattemah v. Emp. (12 W.R., Crim. Rul., 7), retrieved- 12:32 pm, 3rd September.
4
Jayanti Rani Panda v. State. 1984 CriLJ 1535. Retrieved- 12:36 pm, 3rd September.

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immediately whereas the accused advised abortion for which she was not prepared. It was held
that the accused was not guilty of rape as the prosecutrix had given her consent freely for the
series of sexual intercourses with him and section 90 could not be held to be applicable until it
could be established beyond reasonable doubt that right from the beginning of the sexual
contact between the two the accused had no intention to marry her.

In a case 5the accused and the prosecutrix were deeply in love. He promised to marry her on
later date. She was a nineteen year college girl and was aware of the fact that they belonged to
different castes and proposal of their marriage would be opposed by their families. Yet she
started cohabiting with him consciously.

The Supreme Court held that consent on her part could not be said to be under a misconception
of fact, i.e., promise to marry, but she also desired for it. Also, false promise is not a fact under
the Indian Penal Code. The accused was acquitted of the charge of rape.

In a case6, it was proved beyond doubt that the accused had sexual intercourse with the victim
on false promise of marriage. The Gauhati High Court held that submission of body by a
woman under fear or misconception of fact cannot be construed as consent and so conviction
of the accused under sections 376 and 417 of the Indian Penal Code was proper.

3.3 Honest misconception of both parties-

An honest misconception on the part of both the parties may not invalidate the consent. In a
case the private parts of the deceased were cut by the accused eunuchs as a result of which the
deceased died. It was proved that the accused eunuchs had performed similar acts in the past
and they never knew that the practice of emasculation was against the law. The accused were
held liable for culpable homicide not amounting to murder, and not murder, on the ground that
they had acted with free consent of the deceased who was a man of full age and had submitted
himself for the act voluntarily.

5
Uday v. State of Karnataka. AIR 2003 SC 1639. Retrieved- 12:38 pm, 3rd September.
6
Jakir Ali v. State of Assam. 2007 CriLJ 1615 retrieved- 12:40 pm, 3rd September.

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 3.4 Consent of persons-
Under section 82 and 83 children under age of 7 and 7-12 are considered and rule of doli
incapax, doli capax are applicable respectively. insane person are protected with certain
conditions defined under section 84. Intoxicated persons are protected with certain conditions
explained under section 85 and 86.

 Section 82 and 83-

Sections 82 and 83 exempt the wrongful act of the child from the criminal liability. “Doli
incapax” means “Incapacity of a child” and “Doli capax” means “capacity of child”.

Section 82. Act of a child under seven years of age: (rule of doli incapax)

Nothing is an offence which is done by under child 7 years of age. A child below the age of
seven years is called “doli incapax”. The words “doli incapax” means “incapability of the
child” to distinguish right or wrong. Hence the law grants absolute immunity to such an infant
from wrongful acts. According to the English Law a child below the age of ten years is
considered as doli incapax.

Section 83. Nothing is an offence which is done by a child above seven years of age and under
twelve, who has not attained sufficient maturity of understanding to judge of the nature and
consequences of his conduct on that occasion. Children are in this category are not totally
immune from liability but extend to limited immunity. (rule of doli incapax).

Object of these 2 sections-

The children are treated equally with the God, as they do not know right or wrong. Thus,
children are exempted from the criminal and civil liabilities. In civil, a minor’s contract ab
initio is void. In criminal, forgiving exemption to their criminal liability, children are made into
two groups:

(i) Under the age of seven years, and

(ii) Above seven years below twelve years. Section 82 provides complete exemption from the
criminal liability for the acts done by a child below the age of seven years.

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In a case 7Patna High Court upheld that if a child who is accused of an offence during the trial,
has attained the age of seven years or at the time of decision the child has attained the age of
seven years can be convicted if he has the understanding an knowledge of the offence
committed by him.

 Section 84-

Act of a person of unsound mind. Nothing is an offence which is done by a person who at that
time of performing 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.
A landmark judgement8 on ground of insanity provide certain guidelines which are as-
o That every man is presumed to be sane and to posses a sufficient degree of
reason to be responsible for his crimes, until the contrary be proved to the
satisfaction of the court.
o In order to establish defence on ground of insanity it must be clearly shown
that at the time of committing the act, the accused was labouring under such a
defect of reason from disease of mind, as not to know the nature and quality of
the act he was doing, or if he did know it, that he did not know that what he
was doing was wrong.
o If the accused was conscious that the act was one which he ought not to do and
if that act was at the same time contrary to the law of the land, he is
punishable.
o Whereas criminal act is done by a man under some insane delusion as to the
surrounding facts, which conceals him from the true nature of the act he is
doing, he will be under same degree of responsibility as he would have been
on the facts as imagined them to be.
o A medical witness who has not seen the accused before trial should not be
asked on evidence whether he thinks that the accused was insane.9

7
Krishna Bhagwan v. State of Bihar. AIR 1989 Pat 217. Retrieved- 1:24 pm, 3rd September.
8
9
R.C.Nigam, Law ofcrime in India, Vol. I, (1965) PP. 362-363. Retrieved- 1:30pm, 3rd September.

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Apart from England law cases in India are-
In a case10, the accused Ashiruddin was commanded by someone in paradise to sacrifice his
own son, aged 4 years. Next morning, he took his son to a Mosque and killed him and then
went straight to us uncle, but finding a chowkidar, took the uncle nearby a tank and told him
the story. The Supreme Court opined that the accused can claim the defence as even though he
knew the nature of the act, he did not know what was wrong.

 Section 85 and section 86-

Section 85: Act of a person incapable of judgment by reason of intoxication caused against his
will. Nothing is an offence which is done by a person who at the time of doing it, is, by reason
of intoxication, incapable of knowing the nature of the act, or that he is doing what is either
wrong, or contrary to law, provided that the thing which intoxicated him was administered
involuntarily without his will or knowledge.

Section 86: Offence requiring a particular intent or knowledge committed by one who is
intoxicated. This applies to cases where an act done is not an offence unless done with a
particular knowledge or intent, a person who does the act in state of intoxication, shall be liable
to be dealt with as if he had the same knowledge as he would have had if he had not been
intoxicated, unless the thing which intoxicated him was administered to him without his
knowledge or against his will.

In landmark case11, the accused was drunk and fought with the wife. He poured kerosene and
set her on fire and started extinguishing the fire. The court held that he intended to cause bodily
injury which was likely to cause death under section 299(20 and sentenced h under section 304,
Part I of code).

10
Ashiruddin Ahmed vs. State. 1949 CriLJ 255, retrieved- 1:35pm, 3rd September.
11
Babu Sadashiv Jadhav. (1984 Cri LJ 919 (2)). Retrieved- 1:41pm, 3rd September.

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 4. Benevolence act with or without consent-

The Indian Penal Code, 1860 has recognized such defences in chapter four of the code under
the heading of ‘General Exception’. These defences are covered under sections 76 to section
106 of the code. the defences are available under sections 90 and 92 of the code. That is,
consent and goodwill or benevolence as defences.

Section 92 and 89 of the Indian Penal Code talk about benevolence and goodwill to be used as
defenses. Section 92 of the code states that:

Section 92 of the code deals with the cases that may be kept in the category of constructive
consent, which means cases, in which, because of the certain urgent circumstances, consent, is
completely dispensed with, but, as ordered by law, the person causing harm is liberated from
his liabilities. The main crux of section 92 lies in this. If the consent is unobtainable from a
person under section 88, or an incapable person cannot give his consent under section 89 and
it is impossible to gain consent from his lawfully appointed guardian then, the person desiring
to act with a good intention, in a bona fide manner, for the benefit of other person, may proceed
to do so without receiving consent from the person12.

4.1 no criminal intention to cause death-

section 88 defined- Act not intended to cause death, done by consent in good faith for person's
benefit Nothing which is not intended to cause death, is an offence by reason of any harm
which it may cause, or be intended by the doer to cause, or be known by the doer to be likely
to cause, to any person for whose benefit it is done in good faith, and who has given a consent,
whether express or implied, to suffer that harm, or to take the risk of that harm.

This Section deals with those cases in which the exigency of the case requires prompt
assistance, in which the formality of consent might delay the benefit till it is too late. The acts
authorised without consent are therefore only such acts as from their urgency call for immediate
relief, in which no one will think of pausing for consent before rendering assistance. Indeed, in
such cases the dictates of humanity prescribe a rule far higher than the one recognised by the
criminal law

12
www.legistify.com Retrieved- 3:00pm, 4th September.

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(i)His interference was necessary; (ii) that it was beneficial; and (iii) that it was made when
consent was unavailable.

Some illustrations are-

o A, a surgeon, knowing that a particular operation is likely to cause the death of Z, who
suffers under a painful complaint, but not intending to cause Z's death and intending in
good faith, Z's benefit performs that operation on Z, with Z's consent. A has committed
no offence.

4.2 Act done in good faith for benefit of child or insane person, by
or by consent of guardian:

Section 89 defines-Nothing which is done in good faith for the benefit of a person under twelve
years of age, or of unsound mind, by or by consent, either express or implied, of the guardian
or other person having lawful charge of that person, is an offence by reason of any harm which
it may cause, or be intended by the doer to cause or be known by the doer to be likely to cause
to that person:

Provisos-Provided-
First- That this exception shall not extend to the intentional causing of death, or to the
attempting to cause death;
Secondly- That this exception shall not extend to the doing of anything which the person
doing it knows to be likely to cause death, for any purpose other than the preventing of death
or grievous hurt, or the curing of any grievous disease or infirmity;
Thirdly- That this exception shall not extend to the voluntary causing of grievous hurt, or to
the attempting to cause grievous hurt, unless it be for the purpose of preventing death or
grievous hurt, or the curing of any grievous disease or infirmity;
Fourthly- That this exception shall not extend to the abetment of any offence, to the
committing of which offence it would not extend.13
A, in good faith, for his child's benefit without his child's consent, has his child cut for the
stone by a surgeon, knowing it to be likely that the operation will cause the child's death, but
not intending to cause the child's death. A is within the exception in as much as his object
was the cure of the child.

13
www.advocatekhoj.com Retrieved- 3:30pm, 4th September.

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 4.3 benevolence act for benefit of the person-
section 92 defined this clause- Nothing is an offence by reason of any harm which it may cause
to a person for whose benefit it is done in good faith, even without that person's consent, if the
circumstances are such that it is impossible for that person to signify consent, or if that person
is incapable of giving consent, and has no guardian or other person in lawful charge of him
from whom it is possible to obtain consent in time for the thing to be done with benefit:

First- That this exception shall not extend to the intentional causing of death, or the attempting
to cause death;

Secondly- That this exception shall not extend to the doing of anything which the person doing
it knows to be likely to cause death, for any purpose other than the preventing of death or
grievous hurt, or the curing of any grievous disease or infirmity;

Thirdly- That this exception shall not extend to the voluntary causing of hurt, or to the
attempting to cause hurt, for any purpose other than the preventing of death or hurt;

Fourthly- That this exception shall not extend to the abetment of any offence, to the committing
of which offence it would not extend.14

o Z is carried off by a tiger. A fires at the tiger knowing it to be likely that the shot may
kill Z, but not intending to kill Z, and in good faith intending Z’s benefit. A's ball gives
Z a mortal wound. A has committed on offence.
o A, a surgeon, sees a child suffer an accident which is likely to prove fatal unless an
operation be immediately performed. There is no time to apply to the child's guardian.
A performs the operation in spite of the entreaties of the child, intending, in Good faith,
the child's benefit. A has committed no offence.

4.4 communication made in good faith-

No communication made in good faith is an offence by reason of any harm to the person to
whom it is made, if it is made for the benefit of that person.

o A, a surgeon, in good faith, communicates to a patient his opinion that he cannot live.
The patient dies in consequence of the shock. A has committed no offence, though he
knew it to be likely that the communication might cause the patient's death.

14
www.advocatekhoj.com Retrieved-3:45pm, 4th September.

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 5. Conclusion, criticism and suggestion-

Consent has been defined negatively in Section 90 of I.P.C. as a consent is not such a consent
as is intended by any Section of this Code, if the consent is given by a person under fear of
injury or under a misconception of fact and if the person doing the act knows, or has reason to
believe that the consent was given in consequence of such fear or misconception

The above discussion highlights that the defences of consent and goodwill or benevolence can
be used in order to defend the accused in a criminal case. However, there exist certain
limitations to each and every facet of consent not being a true consent as given in the
aforementioned chapters. A child above seven years of age may or may not be held liable for
committing a crime, this depends upon the intelligence that his brain possesses. Only, voluntary
intoxication may be used as a defence and there are different ways in which a person is coerced
to consume in toxifying substance. Moreover, a person, incapable of giving his consent as a
result of unsound mind cannot be charged with a criminal liability until and unless he does not
have the mens rea to commit an act. All such limitations were studied in detail and we thus
may conclude that defences as mentioned in chapter IV of General Exceptions of the code, may
be used at significant times to rescue the accused off the charge of criminal liability.

The following amendments should be made-

Section 90 should be redefined in positive manner as “Definition of consent” - When two or

more persons agreed upon the same thing in the same sense, they will be presumed to have
consented to do an act or omission agreed provided that such consent should not have been
adversely affected by -

(I) Fear of injury or

(ii) Misconception of fact or

(iii) When due to insanity or intoxication or age oldness he was unable to understand the nature
and consequence of that to which he gave consent or

(iv) Infancy, when consent was given by a child under 12 years of age unless the contrary
appears from the context or

(v) Undue influence or

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(vi) Fraud, or

(vii) Mistake of fact.”

2. Age oldness should be recognised as adversely affecting factor to the valid Consent.

3. Undue' influence should be considered the adversely affecting factor invalidating a legal
consent.

4. Fraud should be treated as invalidating the legal consent as it cheats the mind of consenting
person.

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 6. Hypothesis conclusion-

1st hypothesis of this paper is consent of child is not always a valid consent. After the research
the researcher has concluded that rules- doli capax and doli incapax are applicable on the child
under 7 years age and between 7-12 years age respectively. And children are liable accordingly.
Therefore, the researcher believes that the 1st hypothesis is proved through research paper.

2nd hypothesis of this paper is consent of insane person is not a valid one. It is concluded that
the liability of inane person is decided according to his mind and his prior act, at the time of
committing act and after the commitment of the act. Therefore, the researcher believes that the
2nd hypothesis is partially proved through research paper.

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 7. Bibliography-
7.1 Books-
o Ratanlal & Dhirajlal, The Indian Penal Code, 31st Edition.
o Indian penal Code, 1860.
o PSA Pillai, Criminal Law, 12th Edition.

7.2 Websites-
o www.racoblegal.com
o www.advocatekhoj.com
o www.shodhganga.inflibnet.ac.in
o www.legistify.com
o www.indiankanoon.com

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