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of <h1>Supreme Court affirms conviction emphasizing proof of legal insanity under Section 84 IPC</h1> <h3>SIDDHAPAL KAMALA YADAV Versus STATE OF MAHARASHTRA</h3> The Supreme Court upheld the conviction of the appellant under Section 302 IPC, dismissing the appeal and emphasizing the requirement for proving legal ... - Issues Involved:1. Conviction under Section 302 IPC.2. Defense of mental illness under Section 84 IPC.Issue-wise Detailed Analysis:1. Conviction under Section 302 IPC:The appellant was found guilty of the offence punishable under Section 302 of the Indian Penal Code (IPC) by the Additional Sessions Judge, Jalgaon, and sentenced to life imprisonment and a fine. The incident occurred on the night between 18th and 19th July 2002, at approximately 4:00 a.m. in Ward No. 14 of Civil Hospital, Jalgaon, where both the appellant and the deceased were lodged. The prosecution's case was supported by the depositions of ASI Ukhadu Tadvi (PW-2), nurse Suman Bhave (PW-3), and guard Bhagwat Sutar (PW-4), along with the complaint filed by ASI Tadvi. The deceased was found hanging from the cot with a head injury, and the appellant had freed himself from handcuffs and was caught by the guards. The trial culminated in the conviction of the appellant, which was upheld by the High Court.2. Defense of Mental Illness under Section 84 IPC:The appellant raised the defense of mental illness under Section 84 IPC, claiming that he was incapable of knowing the nature of the act due to unsoundness of mind. Section 84 IPC exonerates a person from liability if, at the time of the act, they are incapable of knowing the nature of the act or that it is wrong or contrary to law due to unsoundness of mind. The burden of proof lies on the accused to establish insanity, which is not as onerous as the prosecution's burden to prove the crime. The trial court and the High Court both rejected this defense, finding no substantial evidence to support the claim of insanity.The evidence presented by the doctors who attended the appellant, Dr. Satish Patil (PW-9) and Dr. Subhash Badgujar (PW-10), indicated that the appellant was not suffering from any psychiatric illness at the time of the incident. Dr. Satish Patil stated that he did not find any obvious psychiatric illness upon examining the appellant, and Dr. Subhash Badgujar confirmed that the appellant was not mentally ill from 18.7.2002 to 25.7.2002. Their testimonies suggested that the appellant was calm, quiet, and not showing signs of anger or shouting, indicating normal behavior.The court emphasized that the legal test of responsibility under Section 84 IPC requires proving that the accused was incapable of knowing the nature of the act or that it was wrong or contrary to law due to unsoundness of mind. The appellant failed to meet this burden of proof, and the evidence did not support the claim of insanity. Consequently, the trial court and the High Court correctly held that Section 84 IPC did not apply to the appellant's case.Conclusion:The Supreme Court dismissed the appeal, finding no merit in the appellant's claim of unsoundness of mind and upholding the conviction and sentence under Section 302 IPC. The judgment emphasized the distinction between legal insanity and medical insanity and the necessity for the accused to prove the former to avail the protection under Section 84 IPC.
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