“High Court’s Reversal of Acquittal ‘Perverse,’ Emphasizes Importance of Section 84 IPC in Issues of Insanity”- SC
In a landmark judgment, the Supreme Court has castigated the High Court for reversing the acquittal of an appellant-accused who had initially been found not guilty by the Trial Court on the grounds of insanity under Section 84 of the Indian Penal Code (IPC).
The Supreme Court underscored the difference between legal and medical insanity, quoting from its previous decisions: “An accused who seeks exoneration from liability of an act under Section 84 of IPC has to prove legal insanity and not medical insanity.”
The Supreme Court painstakingly reviewed evidence provided by both the defense and the prosecution, including medical records and testimonies. The appellant-accused had been treated for acute and transient psychotic disorder and was under medication for psychiatric ailments. “The abnormal/insane behaviour of the appellant-accused at the time of the assault and immediately thereafter is worth notice,” the judgment read.
Drawing on legal precedents, the Supreme Court reemphasized the importance of the general burden of proof resting on the prosecution. “If the conclusion of the Trial Court is plausible, merely because another view is possible on reappreciation of evidence, the Appellate Court should not disturb the findings of acquittal,” the judgment highlighted.
Supreme Court also expressed dissatisfaction with the High Court’s reversal of the appellant-accused’s acquittal by stating, “the High Court had reversed the finding of acquittal and convicted the appellant mainly on reappreciation of evidence by holding that the Trial Court erred in extending the benefit of Section 84 of IPC, without even recording a finding that the Trial Court’s finding is perverse.”
Date of Decision: 13 September 2023
RUPESH MANGER (THAPA) VS STATE OF SIKKIM
