The season finale of Criminal Justice, A Family Matter aired this week on JioHotstar, providing a thrilling conclusion to the season's main murder case. The murder of nurse Roshni Saluja is investigated, with the suspicion first resting on her boyfriend, Dr. Raj Nagpal, and later on his wife, Anju. In a theatrical courtroom confession, Anju confesses to the murder of Roshni to save her daughter, only to find out later that she framed herself to protect Raj, the actual murderer, since she was terminally ill and wanted to ensure the future of her family. Though it wasn't explicitly demonstrated that Anju Nagpal was acquitted, somewhere her medical issue didn't reveal her stringent imprisonment that was initiated for such cognizable offenses. The finale makes the audience think about justice, sacrifice, and intricacies of truth.
This dramatic turn of events leads to an actual question: Are there instances in Indian courts where an individual who has committed a serious offense is acquitted or granted leniency due to their medical or mental state?
The Asha Shah case: When mental illness defines justice
The most prominent example is the case of Asha Shah before the Gujarat High Court in 2010. Asha Shah was found guilty of decapitating her mother-in-law and sentenced to a life term.
During her appeal process, it was confirmed via medical evidence that she had been suffering from chronic schizophrenia at the time she committed the offense. The court, under the guidance of Section 84 of the Indian Penal Code (IPC), acquitted her since she was unable to comprehend the nature of her act as a result of her mental illness. This case indicated how Indian law can accept extreme mental illnesses as a valid defense even for heinous crimes such as murder. But Asha Shah's case is not an exception. There have been many instances where, based on mental unsoundness, accused persons have been acquitted or sentences reduced by courts.
Section 84 IPC: The law on insanity
Section 84 of the Indian Penal Code reads
"No act done by a person who, at the time of doing it, because of unsoundness of mind, is incapable of knowing the nature of the act, or that he is doing what is either wrong or contrary to law."
For an accused to gain the benefit of Section 84, it needs to be established that
- They were of unsound mind when they committed the crime.
- Their state of mind made them unable to comprehend what they were doing or that it was illegal.
Other significant cases in which Section 84 IPC was invoked
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Rupesh Manger v. State of Sikkim (2023, Supreme Court)
Acquitted of murder after the court accepted medical proof of major depressive disorder with psychotic features, affecting his judgment.
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Dhananjay Pore & Shakuntala (Bombay High Court, 2022)
Found not guilty after evidence of paranoid schizophrenia and legal insanity at the time of the event.
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Rajendra Chaudhary (Nagpur Bench, Bombay High Court, 2022)
Found not guilty of murder because of schizophrenia and unsoundness of mind.
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Lalitha @ Latha v. State of Kerala (2021)
Conviction of murder set aside following evidence of continuous mental illness.
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Accused X v. State of Maharashtra (Supreme Court, 2019)
The death sentence was converted into life imprisonment owing to serious post-conviction mental illness.
What these cases Show
Indian courts, while continuing to uphold the gravity of criminal offenses, do acknowledge that grave mental illness has the potential to fundamentally influence an individual's criminal responsibility. Section 84 IPC allows a legal protection whereby people who truly cannot understand their actions because of mental unsoundness are not treated as criminals. This defense is only accepted, however, when strong medical and documentary evidence substantiates the plea.
In fact
The dramatic ethical crises that are examined in Criminal Justice's climax are whether Anju Nagpal was acquitted or not but indicate that the tale of criminal justice can indeed be a nonfiction tale. Indian courts and laws have, in actuality, faced the same dilemmas—sometimes overturning convictions or lowering sentences where mental illness has been persuasively demonstrated as having been a determining factor.