CASE NAME	Lakshmi v. State AIR 1959 All 534
CITATION	959 CRILJ 1033, AIR 1959 ALLAHABAD 534, 1959 ALL. L. J. 287, ILR (1959) 2 ALL 216, 1959 ALLCRIR 238
COURT	Allahabad High Court
BENCH	Hon’ble Justice N.U. Beg and Justice V.D Bhargava
PETITIONER	Lakshmi
RESPONDENTS	State
DECIDED ON	Decided on 29 October 1958

INTRODUCTION

A mentally ill individual is unable to control their will or behave appropriately. These people cannot be legally held accountable for their behavior because they lack the mental capacity to comprehend the consequences of their actions or appropriately judge them.
When someone is incapable of comprehending why they are being punished or that they are being punished at all, punishment is pointless. The defense under Section 84 of the Code is predicated on the idea that an act must be undertaken with “guilty” intention in order for it to be considered criminal. If the act’s perpetrator did not know the nature of the act, its wrongfulness, or its illegality, then the act does not qualify as a crime.

A person who is mentally ill is considered incapable of having the requisite mens rea to commit a crime, so mental illness provides a complete defense against any criminal prosecution. A person with mental impairment who commits a crime is released from criminal accountability under Section 841 of the Indian Penal Code, 1860. Until the opposite is demonstrated, the established legal view holds that every individual is believed to be sane and to possess a sufficient degree of reason to be liable for his act. 

If the accused wants to use this exemption under section 105 of the Indian Evidence Act of 1872, they have the burden of proving that their mental state was as indicated by section 84 at the critical moment. The defense must demonstrate that the offender was so mentally ill at the time of the offense that he was unable to understand the nature of the deed he was committing. The accused only needs to use the preponderance of the evidence to support his case probabilistically. Sec. 22 of the new criminal code BNS shows the defense of unsoundness of mind.

FACTS OF THE CASE

It has been determined that the appellant, Lakshmi, killed his stepbrother Chhedi Lal on June 10, 1954, at approximately 8 p.m. in the village of Baheri, police station Girwan, district Eanda. The appellant had a heroin and booze addiction. He used to approach his relatives and make requests for money. It is alleged that he had battered his wife and mother in the month of Jeth before the tragedy. The deceased and other people stopped him from doing so at that point. The deceased had tied the appellant after he refused to obey him. The appellant had broken free from the chains and fled. 

According to the story, Chhedi Lal answered the call of nature and returned home at around eight o’clock in the evening. He was seated on the chabutra at his door. At that point, the appellant went to Chhedi Lal after grabbing a pharsa. Chhedi Lal cried out when he started attacking her with the pharsa. Upon hearing the alert, other people arrived at the location, including Durga, Chhakori, and Debi Dayal, the son of Chhedi Lal. The appellant took the pharsa with him when he ran away from the village upon the arrival of these people. In an hour or two, Chhedi Lal passed away. The doctor believed that the deceased’s injuries caused shock and bleeding, which ultimately led to death.

ISSUES RAISED

• Whether the murder of Chhedi Lal be exempted under the ground of unsoundness of mind?

ARGUMENTS FROM BOTH SIDES

Argument from appellant

• That Chhedi Lal’s murder by the appellant qualified as an exception under Section 84 of Chapter IV of the Indian Penal Code.
• The appellant relied on the case of Ashiruddin Ahmad v. The King to support his claim. According to the case’s facts, the accused had dreamed that he was told to sacrifice his own five-year-old son in paradise by someone. The accused killed his son by stabbing him in the throat the following morning after taking him to a mosque. He immediately went straight to his uncle, but before he could tell him the whole story, a chaukidar in the area led his uncle to a tank some distance away. A Bench of the Calcutta High Court determined that the case of insanity under Section 84, I.P.C. was made out based on these grounds.

Arguments from respondent

• The counsel from the side of the respondent argued that the defense of unsoundness of mind could not be made as there is no history of mental condition. 
• The argument that he was insane when the offense was committed is not supported by his actions either before or after the incident. His actions after the incident likewise provide no evidence to corroborate this claim. Additionally, the appellant’s past behavior in the Court of Enquiry 

JUDGMENT

The Court noted that there is evidence of motivation in this instance. As we have already said, the appellant’s behavior prior to and following the incident, as well as his conduct at the time of the occurrence, both refute the claim of insanity under Section 84 of the Indian Penal Code. Furthermore, there is no proof of inherited insanity in this particular case. Furthermore, there is no evidence to suggest that the accused ever experienced a mental breakdown following the offense. Furthermore, he has no expert testimony to support him. We don’t see how the aforementioned example benefits the appellant in the given circumstances. The Hon’ble High Court dismissed the appeal and upheld the appellant’s conviction.

CONCLUSION

“Incapable” is a crucial word in Section 84. The aforementioned perspective is erroneous because it fails to recognize that Section 84 stipulates that the accused, in order to be granted protection under the law, must be “incapable” of knowing whether the conduct they are accused of committing is right or wrong. What a person knows and is capable of knowing are two very different things. While the latter is the outcome of the former, the former is a potentiality. A person who possesses the former is not entitled to any legal protection, regardless of the outcome of his potential. Stated differently, an innate or natural disability is safeguarded rather than a false or incorrect belief that may arise from a distorted potentiality.  

A person may hold a variety of beliefs. His convictions won’t be able to keep him safe once it is discovered that he is capable of discriminating between right and wrong. He assumes the risk that if his potentialities cause him to come to the incorrect judgment, the law will hold him accountable for the action that came from him. 

A man cannot be heard to beg to be protected where such light is proven to be flickering because he was deceived by his own faulty intuition or by whatever fancy illusion that had been tormenting him and which he had mistaken for truth. The faculty of intuition is essentially the parent of our beliefs. However, our understanding of the nature of knowledge and its content originates from our ability to reason and think. 

“Legal insanity” is not the same as “medical insanity,” a case falling within the latter category need not necessarily fall within the former. If cognition and reason are found to be still alive and gleaming, it will not avail a man to say that at the crucial moment, he had been befogged by an overhanging cloud of intuition that had been casting its deep and dark shadows over them. Furthermore, a man experiencing genuine insanity is not the same as a murderer whose delusional delusions have struck. 

Although s.84 appears to have a plain formulation, s.84 jurisprudence is inconsistent. Courts have given different interpretations of what constitutes a successful s.84 defense. The necessary mental state, the pertinent time frame for that mental state, and the process for establishing that mental state differ significantly. Variations in each of those elements thus impose a distinct responsibility on the one attempting to utilize the s.84 defense.