Madras High Court Acquits Mentally Ill Woman of Murder Charges Under Section 84 IPC

In a significant ruling, the Madurai Bench of the Madras High Court has acquitted Petchiyammal, who was earlier convicted for the murder of her eight-year-old nephew. The court set aside her life sentence, acknowledging her long-standing battle with paranoid schizophrenia. This landmark judgment emphasizes the importance of considering mental health in criminal proceedings.

The appellant, Petchiyammal, was convicted by the II Additional District Sessions Judge, Thoothukudi, for the murder of her nephew by setting him on fire. Her defense centered on her diagnosed mental condition, paranoid schizophrenia, questioning her ability to comprehend the nature of her act.

The chain of events are so complete, unerringly leading to the conclusion that the appellant had committed the offence,” stated the Hon’ble Justices M.S. Ramesh and M.N. Nirmal Kumar, recognizing the circumstantial evidence against the appellant. However, they also noted, “The only ground to be considered is whether the appellant was affected with mental disorder prior to occurrence, during the occurrence and after the occurrence.”

Highlighting the significance of mental health in the legal framework, the court observed, “This Court has considered the rival submissions and perused the materials available on record, as well as the medical records of the appellant,” emphasizing the comprehensive examination of the appellant’s mental state over the years.

Subsequently, the court invoked Section 84 of the IPC, which exempts individuals of unsound mind from criminal liability, leading to Petchiyammal’s acquittal. “We are satisfied that the appellant is a person who is entitled to the benefit of Section 84 of IPC,” the bench declared.

Additionally, the court ordered her safe custody and treatment at the Institute of Mental Health, Kilpauk, Chennai, ensuring her continuous medical care. “The appellant shall be given treatment... If her mental health condition improves, she shall be kept in any of the Welfare Home for Women,” the court directed, providing a path for her rehabilitation.

Date of Decision: 24.01.2024

Petchiyammal VS State