Project of – The Indian Penal Code (IPC) JUDICIAL INTERPRETATION OF UNSOUNDNESS OF MIND: AN ANALYSIS.

A PROJECT ON

“JUDICIAL INTERPRETATION OF UNSOUNDNESS OF MIND: AN

ANALYSIS.”

SUBMITTED TO: Dr. Avishek Raj

Faculty, The Indian Penal Code (IPC)

SUBMITTED BY
GAURAV YADAV
ENROLLMENT No.- 22FLICDDNO2018

ICFAI LAW SCHOOL,

THE ICFAI UNIVERSITY,DEHRADUN

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Project of – The Indian Penal Code (IPC) JUDICIAL INTERPRETATION OF UNSOUNDNESS OF MIND: AN ANALYSIS.”

Table Of Contents

ACKNOWLEDGEMENT… ................................................................................................................. 3

LIST OF ABBREVIATIONS… ........................................................................................................... 4

OBJECT AND METHODOLOGY ....................................................................................................... 5

INTRODUCTION ................................................................................................................................. 6

LEADING INDIAN CASES… .............................................................................................................11

CONCLUSION ..................................................................................................................................... 14

LIST OF THE CASES… ...................................................................................................................... 14

BIBLIOGRAPHY ................................................................................................................................. 15

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Acknowledgement

At the very outset, I would like to thank all those who were the ‘guiding lights’ behind this
project. First of all I would like to take this opportunity with esteem privilege to express my
heartfelt thanks and gratitude to my course teacher Dr. Avishek Raj, faculty for Indian Penal
Code, for having faith in me in awarding me this very significant project topic of such
importance. His consistent supervision, constant inspiration and invaluable guidance have
been of immense help in carrying out the project work with success. Next, I would like to
thank my colleagues for lending me a helping hand during the shaping up of the project. I
also take this opportunity to thank all those people who contribute in their own small ways
but fail to get a mention.

Name : Enrollment No.

GAURAV YADAV 22FLICDDNO2018

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Introduction:
Insanity as a defence in India remains a problem which is unsolved in criminal jurisprudence.
However, it presents some issues that deserves critical analysis. Hence, there are few studies on the
exploration of the clinical picture of patients in prison. In a 2011 forensic psychiatry study in which
5024 prisoners were evaluated in a semi-structured interview program that showed the analysis that
4002 (79.6%) people could be diagnosed with diagnosis by mental or substance use. The
philosophical basis for the exemption of crazy transgressors from criminal liability is perhaps the
limitation on the function of retributive and dissuasive theories of punishment that highlights and
depicts the provision of section 84 of the Indian Criminal Code which is based on Mc Naughten’s
Rule In England, 1843. Other research from India describes not very active picture of patients in
forensic psychiatry with the aid of supporters of the need to rationalize the strategy of referral,
diagnosis, treatment and certification.

A maxim in sec. 84:

There is a well-established maxim, “Actus Non Facit Reum Nisi Mens Sit Rea,” which, in the literal
sense means, an act does not make an offender liable without having a guilty mind. The Intention or
guilty mind (Mens Rea) of the offender is an important part during the commission of a crime. The
defence of insanity is a law that protects a person who is incapable of understanding the nature and
consequences of the act done by him.

The unsoundness of mind should be of such an extent that it makes the offender completely
incompetent in knowing the nature of the act and the consequences of the act whether it is wrong or
contrary to law. The fact that the person is or has been suffering from a mental illness or disorder is
not sufficient to prove that he is insane. Under Indian law, the insanity as a defence is incorporated
and mentioned in Section 84 of the Indian Penal Code, 1860, and is based upon the “Mc’Naughten’s
Rule.” The burden of proof is always on the defendant, and it has to be proved beyond a reasonable
doubt. The Law Commission of India in its 42nd report, made an effort to reanalyze Section 84, but
no modifications were made by such report.

Origin of Plea of Insanity:

Origin of the Rules on the Plea of Insanity law as a defense has been in existence from many centuries
in the world. But, it acquired a legal status from the last three centuries. The historical existence of the
law of insanity can be traced back to the 1700s.

Wild Beast Test:

The first case in England which dealt with the law of insanity was R v. Arnold (1724)1, in which
Edward Arnold attempted to murder and even wound Lord Onslow and was tried for the same by the
court. The evidence clearly depicted that the accused was suffering from a mental disorder.

Tracy, J. said:

“If he was under the visitation of God and could not distinguish between good and evil, and did not
know what he did, though he committed the greatest offence, yet he could not be guilty of any offence
against any law whatsoever.”

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As stated in the aforementioned case, a person can demand immunity if, due to his unsoundness of
mind, he was not able to distinguish between good and evil and did not know the nature and
consequences of the act committed by him. This test is known by the name of “Wild Beast Test.”

Insane Delusion Test:

The second test has its evolution in Hadfield’s case (1800). Hadfield was discharged from the army on
the ground of insanity and was tried for high treason in attempting to assassinate King George III. The
counsel of the accused, Lord Thomas Erskine, defended him and proved in front of the judge that
Hadfield only pretended to kill the king . He was excused the ground of insane delusion from which
the he was suffering.

Erskine stated that insanity has to be determined by the fact of fixed insane delusion and that such
delusion under which the defendant acted is an important reason for his crime. This test was known as
the “Insane Delusion Test.”

Finally, the third test was formulated in Bowler’s case (1812). In this case, Le Blanc, J. stated that the
jury has to decide when the accused committed the offence, whether he was capable of distinguishing
right from wrong. After the Bowler’s case, the courts have placed more emphasis on the capacity of
the accused in order to distinguish the right from the wrong, though the test was not that clear.

Mc’Naughten’s Rule:

There have been several tests from time to time, like the Wild Beast Test, Insane Delusion Test, etc.
But the most important is the “Right and Wrong Test” formulated in M’Naughten’s case.

The hearing of M’Naughten and his release was a topic of discussion in House of Lords, and as a
consequence, they called upon fifteen judges to decide on the question of criminal liability in the
cases where the accused is incapable of understanding the nature of the act and also answered the
questions advanced. Fourteen judges had the same answers. The view of the majority was given by
Tindal C.J., these answers to the questions are known as M’Naughten’s Rule. The following
principles were cited:

If the person knew what he was doing or was only under a partial delusion, then he is punishable.

There is an assumption that every man is prudent or sane and knows what he is doing and is
responsible for the same. To establish a defense based on insanity, it must be ascertained, at the time
of perpetrating the act, the accused was in such a state of mind as was unable to know the nature of
the act committed by him.A person who has sufficient medical knowledge, or is a medical man and is
familiar with the disease of insanity cannot be asked to give his opinion because it is for the jury to
determine, and decide upon the questions.

English Law on the Defence of Insanity:

English criminal law considers insanity a valid defence of crime. The fundamental definition of
insanity is based on the M’Naghten Rules. These rules are not about insanity medical definitions. In
M’Naghten’s case, the judges declared the following insanity principles:All are presumed to be sane
and to have enough reason, until proved contrary, to be responsible for their crimes.It must be clearly
demonstrated in order to establish the defence of insanity that at the time of the act, the accused was
working under such a defect of reason, from mental illness, asHe didn’t know the nature and the
qualities of the act he was doing, or He did not know what he was doing was wrong. The accused

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must, therefore, prove on the basis of the facts that he was suffering from a defect of reason caused by
mental illness in an effort to argue insanity, because either he was unaware of the nature and quality
of the act, or he had not realized that his actions were wrong.

Indian Law on the Defence of Insanity:

Insanity is provided in accordance with Section 84 of the Indian Penal Code as a defence under Indian
Law. However, the term “insanity” is not used under this provision. The Indian Penal Code uses the
sentence “mental soundness.” In accordance with the code, the defence of insanity, or that can also be
called defence of mental insanity, comes from M’Naghten’s rule.In Section 84 of the Indian Penal
Code, a person of an unsound mind shall act- Nothing is an offence committed by someone who is
currently unable to know the nature of the act or does what is wrong or contrary to legislation due to a
lack of a sound mind.Nevertheless, it should be noted that the framers of the IPC preferred to use the
expression “insanity mind” instead of the term “insanity.” Insanity’s scope is very limited, while the
mind’s insanity covers a large area.

For this defence, the following elements are to be established-

The accused was in a state of unsoundness of mind at the time of the act.

He was unable to know the nature of the act or do what was either wrong or contrary to the law. The
term ‘wrong’ is different from the term ‘contrary to the law.’

If anything is ‘wrong’, it is not necessary that it would also be ‘contrary to the law.’ The legal
conception of insanity differs significantly from medical conception. Not every form of insanity or
madness is recognized as a sufficient excuse by law.

Distinction between Legal and Medical Insanity:

Section 84 of the Indian Penal Code sets out the legal responsibility test as distinguished from the
medical test. It can be observed that the absence of will arises not only from the absence of
understanding maturity but also from a morbid state of mind. This morbid mind condition, which
provides an exemption from criminal responsibility, differs from the medical and legal point of view.
According to the medical point of view, it is probably correct to say that every person, when
committing a criminal act, is insane and therefore needs an exemption from criminal responsibility;
while it is a legal point of view, a person must be held to be the same as long as he is able to
distinguish between right and wrong; as long as he knows that the act carried out is contrary to the
law.

It has been ruled by the SC that “mentally ill” people and psychopaths are unable to seek immunity
from a criminal case, as it is their responsibility to demonstrate insanity at the time the crime was
committed. So in practice, not every person who is mentally ill is exempt from criminal liability.
There has to be a distinction between legal insanity and medical insanity. “Arijit Pasayat and the
Bench of Justices, DK Jain, stated while upholding the life conviction of a man who cut off his wife’s
head. The mere abnormality of mind, partial delusion, irresistible impulse or compulsive behavior of a
psychopath does not provide protection from criminal prosecution as provided by the apex court held
Section 84 of the Indian Penal Code (IPC). The Bench stated that Section 84 of the IPC, which
provides immunity from criminal prosecution to persons of unsound mind, would not be available to
an accused, as the burden of proving insanity would lie with them, as provided in Section 105 of the
Indian Evidence.

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In the case of Hari Singh Gond v. State of Madhya Pradesh2, the Supreme Court observed that
Section 84 sets out the legal test of responsibility in cases of alleged mental insanity. There is no
definition of ‘mind soundness’ in IPC. However, the courts have mainly treated this expression as
equivalent to insanity. But the term ‘insanity’ itself does not have a precise definition. It is a term used
to describe various degrees of mental disorder. So, every mentally ill person is not ipso facto exempt
from criminal responsibility. A distinction must be made between legal insanity and medical insanity.
A court is concerned with legal insanity, not medical insanity.

In the case of Surendra Mishra v. State of Jharkhand3, It was pointed out that ‘every person
suffering from mental illness is not ipso facto exempt from criminal liability.’ Furthermore, in the
case of Shrikant Anandrao Bhosale v. State of Maharashtra, the Supreme Court, in determining the
offense under Section 84 of the IPC, held that’ it is the totality of the circumstances seen in the light
of the recorded evidence’ that would prove that the offense was committed.’ It was added: “The
unsoundness of the mind before and after the incident is a relevant fact.”

Unsoundness of mind must be at the time of the commission of the Act.

The first thing a court to be considered when defending insanity is whether the accused has
established that he was unsound at the time of committing the act. The word “insanity” is not used in
Section 84 of the penal code.

In Rattan Lal v. State of M.P4, it was well established by the court that the crucial point of time at
which the unsound mind should be established is the time when the crime is actually committed and
whether the accused was in such a state of mind as to be entitled to benefit from Section 84 can only
be determined from the circumstances that preceded, attended and followed the crime. In other words,
it is the behavior precedent, attendant and subsequent to the event that may be relevant in determining
the mental condition of the accused at the time of the commission of the offense but not those remote
in time.

In Kamala Bhuniya v. West Bengal State5, the accused was tried for her husband’s murder with an
axis. A suit was filed against the accused, she alleged to be insane at the time of the incident, the
investigating officer recorded at the initial stage about the accused’s mental insanity. The
prosecution’s duty was to arrange for the accused’s medical examination, it was held that there was no
motive for murder. The accused made no attempt to flee, nor made any attempt to remove the
incriminating weapon Failure on the part of the prosecution was to discharge his initial responsibility
for the presence of mens-rea in the accused at the time of the commission of the offence. The accused
was entitled to benefit from Section 84. And hence accused was proved insane at the time of the
commission of the offence and was held guilty of Culpable Homicide and not of Murder.

Incapacity to know the nature of the act:

The word “incapacity to know the nature of the act” embodied in Section 84 of the Indian Penal Code
refers to that state of mind when the accused was unable to appreciate the effects of his conduct. It

2
(2008) 16 SCC 109.
3
2011 (11) SCC 495.
4
1971 AIR 778 1971 SCR (3) 251 1970 SCC (3) 533.
5
2006 (1) CHN 439, 2006 CriLJ 998.
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would mean that the accused is insane in every possible sense of the word, and such insanity must
sweep away his ability to appreciate the physical effects of his acts.

Incapacity to know right or wrong:

In order to use the defence of insanity under the latter part of Section 84, namely “or to do what is
either wrong or contrary to the law,” it is not necessary that the accused should be completely
insane,his reason should not be completely insane, his reason should not be completely extinguished.
What is required, is to establish that although the accused knew the physical effects of his act, he was
unable to know that he was doing what was either “wrong” or “contrary to the law.” This part of
Section 84 has made a new contribution to criminal law by introducing the concept of partial insanity
as a defence against criminal insanity. However, as a practical matter, there would probably be very
few cases in which insanity is pleaded in defence of a crime in which the distinction between “moral”
and “legal” error would be necessary. In any crime, insanity can undoubtedly be pleaded as a defence,
yet it is rarely pleaded except in murder cases. Therefore, in a case, this fine distinction may not be
very useful for the decision. The Indian penal code has advisably used either “wrong or contrary to
the law” in Section 84, perhaps anticipating the controversy.

Irresistible impulse is a sort of insanity:

It is where the person is unable to control his actions even if he has the understanding that the act is
wrong. In some cases, the Irresistible Impulse Test was considered to be a variation of Mc’Naughten’s
rule; in others, it was recognized to be a separate test. Though the Irresistible Impulse Test was
deemed to be an essential corrective on Mc’Naughten’s selective perception, it still had some
criticisms of its own.

Under English Law:

In 1884, the irresistible impulse test was introduced by the legislation. By 1967, this test was
applicable in 18 states out of 51 states of the U.S.A. Irresistible impulse when, attributable to a
diseased mind, appears to have been identified as a legitimate excuse in some English
cases.Irresistible impulse as a defence was developed in the famous case of Lorena Bobbit (1993), on
June 23rd, 1993, the defendant took a knife from her kitchen and wounded her husband by cutting off
his penis while he was sleeping. Her lawyers contended that she had been suffering from domestic
violence, which was perpetrated by her husband during her marriage, and his husband even raped her
before she committed this act. Though she was well aware of the consequences, she was not able to
control her actions and demanded that she was subject to an irresistible impulse. The state of Virginia
was the first state which used this defence in its original form. It was held that she’s not guilty as she
was suffering from temporary insanity.

Under Indian Law:

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Usually, when there is adequate capacity to distinguish between right and wrong, the mere presence of
an irresistible impulse would not excuse liability. Irresistible impulse is not incorporated under
insanity because it does not fall within the ambit of Section 84 of the Indian Penal Code.

In the case of, Kannakunnummal Ammed Koya v. State of Kerala (1967)6, it was held that to claim
an exemption under section 84, the insanity has to be proved, at the time of the commission of an act,
mere losing of self-control due to excitement or irresistible impulse provides no defence under Indian
law even if this is proved in a court of law.

In another case, Ganesh v. Shrawan (19697), it was observed that the mere fact that the murder is
committed by the accused on an irresistible impulse, and there is no identifiable motive for the
commission of the act, can form no grounds for accepting the defence of insanity.

Durham Rule:

The Durham defence is also known as the “Durham rule,” or the “product test” was established in the
case of, Durham v. United States (1954), the defendant was guilty of breaking into a house and
demanded the plea of insanity in his defence. The existing tests, which were the Mc’Naughten Rule
and the irresistible impulse test, were declared to be obsolete by the Court of Appeal. But later on, it
was understood that both these tests could still be employed, and the Durham rule can be used in
addition to these tests.

This defence has two main components:

First, the defendant must possess a mental disease or infirmity. Although these words are not
explicitly explained in the Durham case, the language of the judicial view indicates an effort to rely
more on objective, psychological standards, rather than focusing on the defendant’s subjective
cognition.

The second element has to do with causation. If criminal behavior is “caused” by the mental disease
or defect, then the conduct should be exempted under the circumstances.

This test is currently accepted only in New Hampshire, considering it has been regarded too broad by
other jurisdictions.

Concept of Diminished Responsibility:

The Doctrine of Diminished Responsibility was introduced by the Homicide Act of 1957, as a defence
to murder. If this defence is established, it will entitle the offender to be found guilty of manslaughter
(culpable homicide) instead of murder.

Section 2 of the Act clearly states that:Where a person kills someone or is a party to killing, he will
not be guilty of murder if he was suffering from some abnormality of mind and is mentally incapable
of taking responsibility for his acts.

A person who would be liable under this section, whether as a principal or as an accessory, will be
convicted of manslaughter instead of being convicted of murder.

6
1967 CriLJ 494
7
26 February, 1969.
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Leading Indian Cases;

Ratan Lal v. State of Madhya Pradesh:

The appellant was caught setting fire to the grass in an open land of Nemichand, when he was asked
why he did it, he replied; ‘I burnt it, do whatever you want.’ The appellant was charged under Section
435 (mischief by fire with intent to cause damage) of the Indian Penal Code. According to the
psychiatrist, he was a lunatic in terms of the Indian Lunacy Act, 1912. The report explicitly stated that
the accused is Remains depressed,

The trial court held that the accused was not liable to be punished. An appeal was filed by the state,
and the High court reversed the findings of the trial and held the accused liable for the offence.
Afterward, the Supreme Court allowed the appeal, and the conviction was set aside based upon two
major factors: Medical evidence provided and, according to the behavior of the accused on the day of
the occurrence. These factors indicated that the accused was insane within the meaning of Section 84,
IPC.

Seralli Wali Mohammad v. State of Maharashtra8:

The offender was charged under Section 302 of the Indian Penal Code for causing the death of his
wife and daughter with a chopper. The Supreme Court rejected the plea of insanity because the mere
fact that there was no motive proved, or that he did not attempt to run, was not sufficient enough to
prove that he did not have the mens rea for committing the act.

Shrikant Anandrao Bhosale v. State of Maharashtra9:

In this case, the accused was a police constable. The wife was hit on the head with a grinding stone by
the accused, and she was immediately taken to the hospital but was found already dead. After
investigation, the appellant was charged for the offence of murder. Insanity was pleaded as a defence.
The appellant had a family history where his father also suffered from mental illness. The reason for
such an ailment was not known. The appellant was undergoing treatment for this mental disease. It
was observed that the motive for the murder was quite weak. After killing his wife, the accused did
not attempt to hide or run away.

Based on the above-stated facts, it was held that the accused was suffering from paranoid
schizophrenia, and he was incapable of comprehending the nature of the act committed by him.
Therefore he was not guilty of murder and will be given the benefit of section 84, IPC.

Jai Lal v. Delhi Admin10:

Here, the appellant killed a small girl with a knife and even stabbed two other people, was convicted
under Section 302 of the Indian Penal Code. It was pleaded by the accused that he was suffering from
insanity within the ambit of Section 84, IPC. It was observed that the accused, after being arrested
gave normal and intelligent statements to the investigating officers. Nothing abnormal was noticed in
his behavior. Considering all these findings, the Supreme Court held that the appellant was not insane
at the time of the commission of the act and was well-aware of the consequences of his acts. He was
held guilty for murder under Section 302, IPC.

8
AIR 1972 SC 2443, 1972 CriLJ 1523, (1973) 4 SCC 79, 1973 (5) UJ 204 SC
9
27 October, 1993.
10
1969 AIR 15 1969 SCR (1) 140 ACT
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Misuse of Insanity as a Defence:

In the present scenario, there are very high chances that the defence of insanity can be very well
abused as it is a very strong weapon to escape the charges of an offence. It is impossible to prove that
the person was incapable of understanding the nature of the act. Defence lawyers can use it to free the
culprits of intentional unlawful acts. Here the courts play an important rule as they have to make sure
that a sane person doesn’t absolve himself by wrongfully using the defence in his favour. In many
jurisdictions, this defence has been abolished completely, e.g., Germany, Thailand, Argentina, etc.

Role of psychiatrist:

A standard evaluation procedure is necessary for all patients who support the defence of insanity. It is
a pity that to date there are no standardized procedures in our country. Psychiatrists are often called to
conduct mental health assessments and treatments. In addition to treatment, courts can also request
various certifications. This includes:

Certify the presence or absence of psychiatric illness if the defendant requires a reason for insanity
(the mental state of the defendant when the alleged crime occurred);Evaluation of the suitability to be
judged in cases where the mental illness is incapable of the cognitive, emotional and behavioural
faculties of an individual that cause a serious impact on the ability to defend the case (the current
mental state of the accused and their competence during the award).The psychiatrist should consider
the admission admitted for a global evaluation of the accused. The psychiatrist has to educate the
court, clarify psychiatric problems and provide an honest and objective opinion based on concrete
data and sound reasoning. This NIMHANS Detailed Workup Proforma for Forensic Psychiatry
Patients-II is used in the Institute since many decades for semi-structured assessment of forensic
psychiatric cases. This proforma is modified periodically as per the clinical evaluation and legal
requirement.

Review of accompanying documents:

It is the duty of the psychiatrist to review all the accompanying legal documents and determine the
reference authority, the reason for the report, the date and time of the report and the time available to
issue the opinion. A careful history of all possible sources should be compiled, such as the accused,
the companion, the FIR, the post mortem report and the autopsy, the crime scene photographs, the
behaviour observation report, the member interview of the family and the psychiatrist in the past.

Assessment of history of presenting illness:

The defendant should be interviewed as soon as possible in time for the crime, even if in practice, this
is not always feasible. At the beginning of the evaluation, the accused must be informed of the
purpose of the evaluation and the lack of confidentiality. A complete survey should be made of the
history of the presentation of the disease, of the history, of the family history, of the personal history
and a premorbid personality. The psychiatrist should never forget to evaluate substance use in the past
and present.

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Assessment focusing on mental state at the time of the offence

The psychiatrist must make an effort to assess the mental state of the accused at the time of the
infraction. The psychiatrist must make an effort to assess the mental state of the accused at the time of
the offence. You should try to get a detailed description of the incident through open questions. It
would be prudent to ask the accused to provide a detailed report of their behaviour, their emotions,
their biological, professional and social functioning from 1 week before the crime and to be informed
up to 1 week after the crime. Psychiatrists should also examine the defendant’s behaviour before,
during and after the commission of the crime, which may provide clues about the patient’s complete
mental state.

Evaluation of mental status and cognitive functioning.

The mental state test should be done without important questions. The psychiatrist must ask open-
ended questions and must refrain from asking important questions. The inexperienced psychiatrist can
easily fall into the trap of the sick. Therefore, it is advisable to admit the patient and perform a serial
examination of the mental state and serial observations in the ward.

Diagnosis:

Considering the nature of the evaluation and the law assumes that everyone is healthy unless proven
otherwise, it is prudent to begin the evaluation in the same direction. The psychiatrist must initially
resist the definitive diagnosis. The diagnosis should be kept open or the temporary diagnosis should
be considered. After collecting information from all possible sources, depending on the series mental
state examination, the observation of the serial department, psychological tests and laboratory
investigations, the psychiatrist must make an objective and honest evaluation and give his or her
opinion on the diagnosis of the patient’s life and current mental state. You must also make a sincere
effort to oppose the defendant’s mental state during the commission of the crime.

Conclusion:
It is suggested that there should be a well-defined definition of the term ‘mental insanity’ to avoid the
various controversies and confusions that arise in understanding and differentiating between the
‘mental disease’ and the actual insanity of mind sought by the Code or the so-called ‘legal insanity’ in
order to make the defence available to the accused.Section 84 of the Code should be amended to
incorporate the partial defence of diminished responsibility for murdering insane persons. This change
shall be made on an equal footing with the defence of diminished responsibility as accepted under the
defence of insanity as specified by English criminal law.The scope of Section 84 should be expanded
to incorporate the defence of automatism under the defence of an unhealthy mind, just as it is
recognized by the English criminal law system.

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List of cases.

Hari Singh Gond v. State of Madhya Pradesh

Surendra Mishra v. State of Jharkhand
Rattan Lal v. State of M.P
Kamala Bhuniya v. West Bengal State
Kannakunnummal Ammed Koya v. State of Kerala (1967)
Ganesh v. Shrawan (1969)
Ratan Lal v. State of Madhya Pradesh
Seralli Wali Mohammad v. State of Maharashtra
Shrikant Anandrao Bhosale v. State of Maharashtra
Jai Lal v. Delhi Admin

Bibliography

BOOKS REFERRED:

1. Universal Bare Act The Indian Penal Code, 1860

2. INDIAN PENAL CODE by Prof. S.N. Misra
Articles Referred on various websites.

1. https://thelawbrigade.com/criminal-law/detailed-analysis-of-section-84-of-

indian-penal-code-1860/?amp.

2. https://www.legalserviceindia.com/legal/article-5965-an-analysis-of-ipc-section-

84.html.

3. https://blog-ipleaders-in.cdn.ampproject.org/v/s/blog.ipleaders.in/insanity-

defence-indian-penal-

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