1972 (8) TMI 144 - SC - Indian Laws

Supreme Court affirms murder conviction, rejects insanity defense.

SHERALLI WALI MOHAMMED Versus STATE OF MAHARASHTRA

The Supreme Court upheld the accused's conviction under Section 302 of the Indian Penal Code for causing the death of his wife and child. The Court ... - Issues:- Conviction under Section 302 of the Indian Penal Code- Appeal against High Court's judgment- Evidence of prosecution witnesses- Accused's plea of unsoundness of mind- Burden of proof on the prosecution- Evaluation of accused's mental state during the commission of the actsAnalysis:The judgment by the Supreme Court involved the case of an accused charged under Section 302 of the Indian Penal Code for causing the death of his wife and child. The accused was found guilty by the Sessions Judge and sentenced to life imprisonment. The accused appealed to the High Court, which upheld the conviction. The Supreme Court heard the appeal by special leave against the High Court's decision.The prosecution's case relied on witnesses who testified to finding the accused with bloodstained hands and clothes, holding a chopper, with the victims lying injured. The accused claimed he was elsewhere during the incident. Most prosecution witnesses turned hostile except for police constables and doctors. The trial court and High Court found the police witnesses' testimony credible, leading to the conclusion that the accused caused the injuries resulting in the deaths.The accused raised two main submissions before the Supreme Court: firstly, challenging the evidence linking him to the injuries, and secondly, claiming unsoundness of mind during the acts. The Court emphasized the burden of proof on the prosecution to establish the accused's mental state at the time of the offense. The judgment cited the need to prove incapacity due to unsoundness of mind under Section 84 of the IPC.Regarding the accused's mental state, witnesses mentioned the accused's history of temporary insanity, but the trial court did not find this evidence convincing. The defense did not produce doctors to support the insanity claim. Contrarily, witnesses testified to the accused's normal behavior, including his work performance on the day of the incident. The Court highlighted the presumption of sanity unless proven otherwise and dismissed the defense of insanity based solely on the nature of the crime or lack of motive.Ultimately, the Supreme Court upheld the lower courts' findings, emphasizing the lack of evidence supporting the accused's unsoundness of mind during the commission of the acts. The Court reiterated the importance of proving mental incapacity beyond a reasonable doubt. Consequently, the appeal was dismissed, affirming the accused's conviction under Section 302 of the IPC.