Insanity Defense Landmark Cases
🧠 Insanity Defense in Indian Law: Legal Basis
Section 84, IPC: “Nothing is an offence which is done by a person who, at the time of doing it, by reason of unsoundness of mind, was incapable of knowing the nature of the act, or that he was doing what was either wrong or contrary to law.”
This follows the M’Naghten Rule from English law, which requires:
Unsoundness of mind at the time of the act,
Inability to understand the nature or wrongfulness of the act.
Now, let’s look at landmark Indian cases that interpret and apply this defense.
🧑⚖️ Landmark Insanity Defense Cases (Detailed Explanation)
1. Dahyabhai Chhaganbhai Thakkar v. State of Gujarat (1964) SCR (1) 156
Facts:
The accused killed his wife with a sword and pleaded insanity.
Medical evidence showed he suffered from schizophrenia.
Judgment:
The Supreme Court held that burden of proving insanity lies on the accused, but only on a preponderance of probabilities, not beyond reasonable doubt.
Once reasonable doubt is raised, prosecution must prove the accused was sane.
It was held that insanity must exist at the time of the crime, not before or after.
Significance:
Clarified burden of proof and evidentiary standards in insanity pleas.
2. Surendra Mishra v. State of Jharkhand (2011) 11 SCC 495
Facts:
The accused killed his wife and daughter; defense claimed mental illness.
Judgment:
Court held that mere abnormal behavior or history of mental illness is not sufficient.
It must be proved that the accused was incapable of understanding the act at the exact time of the offence.
The Court denied the insanity plea.
Significance:
Reiterated that medical evidence alone is not enough—mental condition at the time of the act is key.
3. State of Rajasthan v. Shera Ram (2012) 1 SCC 602
Facts:
The accused killed his wife and children.
Defense argued that he was suffering from schizophrenia.
Judgment:
Supreme Court acknowledged that past history of mental illness is relevant.
If past mental illness is severe and recurring, and no motive is established, benefit of doubt may go to the accused.
He was given the benefit of Section 84.
Significance:
One of the few cases where insanity defense succeeded.
Balanced view between legal test and medical history.
4. Ratan Lal v. State of Madhya Pradesh (1970) 3 SCC 533
Facts:
The accused had a history of mental instability and committed a violent act.
Judgment:
The Court refused the plea because the mental condition at the exact time of crime was not proven.
Said that even though he had been mentally ill in the past, he was sane during the commission.
Significance:
Important case reinforcing the temporal requirement: the insanity must exist at the moment of the offence.
5. Shrikant Anandrao Bhosale v. State of Maharashtra (2002) 7 SCC 748
Facts:
Accused, a government employee, killed his wife and pleaded schizophrenia.
Judgment:
Supreme Court accepted the insanity defense.
Relied on consistent medical records, behavior patterns, and lack of motive.
Held that the accused was under delusion and incapable of understanding the act.
Significance:
Reinforced that consistent medical history + no motive can help establish insanity.
Focused on complete mental disconnection from reality.
6. Bapu v. State of Rajasthan (2007) 8 SCC 66
Facts:
The accused killed a woman and claimed mental instability.
Judgment:
The court held that mere eccentric or erratic behavior is not enough.
No credible medical evidence of mental illness at the time of the act.
Significance:
Reiterated the need for clear proof of unsoundness of mind at the time of the act.
🧾 Summary Table
| Case Name | Key Legal Principle | Outcome |
|---|---|---|
| Dahyabhai v. Gujarat | Burden of proof is on accused, but only on preponderance of probabilities | Defense allowed |
| Surendra Mishra v. Jharkhand | Medical history insufficient without proof of mental state at time | Defense denied |
| Shera Ram v. Rajasthan | Past severe illness + no motive → benefit of doubt | Defense allowed |
| Ratan Lal v. MP | Mental illness must be proven at the time of offence | Defense denied |
| Shrikant Bhosale v. Maharashtra | Schizophrenia + no motive + delusion = valid defense | Defense allowed |
| Bapu v. Rajasthan | Eccentricity ≠ legal insanity | Defense denied |
🧠 Key Takeaways:
Legal insanity ≠ medical insanity.
Law focuses on the accused’s mental state during the act, not general mental illness.
Proof must show:
Accused was suffering from unsoundness of mind at the exact time of the act,
And could not understand the nature or wrongfulness of the act.
Burden of proof:
Lies on the accused, but standard is lower than for prosecution (balance of probabilities).
Evidence that helps:
Past medical history,
Behavior before and after the act,
Absence of motive,
Witness testimony,
Expert psychiatric opinion.
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