The Supreme Court of India overturned a murder conviction, citing the accused’s mental illness and the right to self-defense under Article 21. Explore the legal insights and landmark judgments that shaped this ruling.

Supreme Court Acquits Murder Convict on Grounds of Mental Illness Under Article 21

On May 24, 2025, the Supreme Court of India overturned the conviction of a man sentenced to life imprisonment for murder. The Court ruled that the accused, found to be mentally unstable, could not have exercised his constitutional right to defend himself under Article 21 of the Indian Constitution.

Right to Defense is Fundamental Under Article 21

A bench led by Justice Abhay S. Oka and Justice Ujjal Bhuyan emphasized that a mentally ill person, often referred to legally as a “lunatic,” cannot be prosecuted as they lack the capacity to defend themselves. The Court reaffirmed that the right to a fair trial and self-defense is an essential component of Article 21.

“The law lays down that no act done by a lunatic is an offence… Right to defend a charge for an offence is a fundamental right,” the Court noted.

Background: Murder Conviction Under IPC Sections 302, 352, and 201

The incident occurred on September 27, 2018. The accused attacked a man, Asam Gota, with an iron pipe in a field while Fagu Ram Karanga, a prosecution witness, was present. The appellant was charged under Sections 302, 352, and 201 of the Indian Penal Code (IPC). He was found guilty by the Trial Court, and the verdict was upheld by the High Court.

Defense Cites Mental Illness and Section 84 IPC

At the Supreme Court, the defense argued that the accused was mentally unstable at the time of the offense. His counsel cited judgments including:

Dahyabhai Chhaganbhai Thakkar v. State of Gujarat

Section 84 IPC

Rupesh Manger (Thapa) v. State of Sikkim

These rulings assert that the presence of reasonable doubt regarding the accused’s mental state is enough to warrant acquittal.

State’s Argument and Rebuttal

The prosecution insisted the accused was mentally fit, citing a medical report from December 7, 2023. However, the Court found this test irrelevant as it occurred five years after the crime. The State also argued the accused had not provided adequate proof of insanity during or immediately following the incident.

Court’s Analysis of Legal Insanity and Mens Rea

The Supreme Court emphasized the difference between medical insanity and legal insanity, referencing the ruling in Surendra Mishra v. State of Jharkhand. It reiterated that mens rea, or the guilty mind, must be questioned. If the accused was incapable of understanding the nature of the act, he must be acquitted.

Key Precedents Supporting the Verdict

The Court reinforced its stance with precedents such as:

Bapu Alias Gujraj Singh v. State of Rajasthan

Dahyabhai Chhaganbhai Thakkar v. State of Gujarat

These judgments stress that if there’s a history of insanity, it is the investigator’s duty to request a medical examination and provide the report in court.

Prosecution Witnesses Confirm Mental Instability

Several prosecution witnesses acknowledged the accused’s mental illness:

PW1 testified that the appellant had episodes of insanity.

PW2 described erratic behavior and quarrels with locals.

Other witnesses echoed concerns about his mental health.

Surprisingly, the prosecution did not re-examine these witnesses nor request a medical evaluation at the time of trial.

Final Judgment: Reasonable Doubt Warrants Acquittal

The Court found the medical examination five years post-incident irrelevant, and the witnesses’ testimonies compelling enough to raise more than reasonable doubt. It ruled in favor of the appellant, revoking the previous conviction.

Conclusion:

The Supreme Court’s ruling in this case underscores the importance of protecting constitutional rights—especially the right to self-defense for those with mental illness. The judgment strengthens the legal understanding of insanity as a valid defense and reaffirms Article 21 as a cornerstone of justice in India.