Supreme Court Elucidates on Legal Insanity vs. Medical Insanity in Criminal Liability
In a recent judgment, the Supreme Court of India delved into the distinction between legal insanity and medical insanity in the context of criminal liability. The court emphasized that for an accused to be exonerated from the responsibility of an act under Section 84 of the Indian Penal Code (IPC), they must establish legal insanity rather than medical insanity.
The case in question involved Rupesh Manger (Thapa), who was accused of murdering his grandfather. The Trial Court had initially acquitted him, concluding that due to his unsound mind, he was likely unaware that his actions were either wrong or against the law. However, this acquittal was reversed by the Sikkim High Court, leading to his conviction.
Upon appeal, the Supreme Court, presided over by Justices JB Pardiwala and Prashant Kumar Mishra, scrutinized the medical evidence highlighting the accused’s mental illness and his abnormal behavior at the time of the incident. The apex court observed that the Trial Court’s view wasn’t perverse or baseless. The bench noted, “If the conclusion of the Trial Court is plausible one, merely because another view is possible on reappreciation of evidence, the Appellate Court should not disturb the findings of acquittal and substitute its own findings to convict the accused.”
The court further elaborated on the concept of insanity in the legal realm, stating, “Since the term insanity or unsoundness of mind has not been defined in the Penal Code, it carries different meanings in different contexts and describes varying degrees of mental disorder. A distinction is to be made between legal insanity and medical insanity. The court is concerned with legal insanity and not with medical insanity.”
This distinction is crucial as legal insanity pertains to the inability to understand the nature and quality of one’s actions or that such actions are wrong, while medical insanity refers to a broader spectrum of mental health conditions.
The Supreme Court also referred to a recent judgment, Prakash Nayi @ Sen vs. State of Goa, which touched upon the issue of insanity. In the end, the court upheld the Trial Court’s decision, acquitting Rupesh Manger (Thapa) of the charges.
Case Title: Rupesh Manger (Thapa) vs. State of Sikkim
