Madras High Court Acquits Man in Murder Case Citing Mental Illness

The Madurai Bench of the Madras High Court has acquitted a man who was earlier sentenced to life imprisonment for murder, after considering that he was of unsound mind at the time of the incident. The court held that the accused is entitled to the protection under Section 84 of the Indian Penal Code (IPC), which exempts acts done by persons of unsound mind from criminal liability.

A Division Bench comprising Justices N. Anand Venkatesh and P.B. Balaji observed that the manner in which the accused acted violently while killing the deceased clearly indicated that he did not know the nature of the act or its consequences. The court said that medical records showed the accused had been suffering from bipolar affective disorder mania with psychotic symptoms and was undergoing treatment at various hospitals, including the Institute of Mental Health (IMH), Chennai.

The accused had been sentenced to life imprisonment by the Principal District and Sessions Court in Tiruchi for a murder committed in 2016. However, the High Court noted that the trial court's judgment made no reference to the accused's mental health condition, despite being informed about it. The High Court termed this as 'totally insensitive' to mitigating and relevant factors.

Under Section 84 of IPC, an act committed by a person of unsound mind is not considered an offence if the person was incapable of knowing the nature of the act or that it was wrong or contrary to law. The High Court emphasised that the letter and spirit of this provision must be followed.

The court directed the Dean/Director of IMH, Chennai, to ensure proper care and treatment for the appellant. If the IMH finds that the appellant has recovered and is fit to rejoin his family, his family members may approach the competent authority for custody.

Additionally, the High Court issued a reminder to trial courts: whenever they are put on notice or become aware of any mental unsoundness of an accused, it is their duty to arrange for a medical examination and obtain a report from a competent mental health institute. The trial court must then assess the report and determine whether the accused is entitled to the benefit of Section 84, even if the defence has not specifically raised the plea of unsoundness of mind.