Mere Causing Death Does Not Always Imply Murder: Supreme Court Converts Mother's Conviction to Culpable Homicide

"Absence of Motive and Mental Instability Raise Reasonable Doubt About Intention" — Supreme Court of India altering the legal understanding of culpability where mental instability and lack of motive are evident. The Court, comprising Justice B.R. Gavai and Justice Sandeep Mehta, converted the appellant’s conviction from murder under Section 302 IPC to culpable homicide not amounting to murder under Section 304 Part II IPC, highlighting that the existence of intention must be proved beyond reasonable doubt to sustain a conviction for murder. The Court ordered Chunni Bai’s release, noting she had already undergone almost ten years of incarceration.
 

The tragic events unfolded on June 5, 2015, in Village Bharadkala, District Bemetara, Chhattisgarh, where Chunni Bai assaulted her two minor daughters with an iron crowbar, resulting in their deaths. An FIR was promptly lodged, and following trial, she was convicted and sentenced to life imprisonment. The High Court upheld this conviction.
 

At trial and before the Supreme Court, Chunni Bai asserted that she was acting under the influence of an invisible spirit, reflecting a potential claim of unsoundness of mind under Section 84 IPC. Her sister-in-law, who witnessed the act, testified that the appellant had no prior animosity towards the children and that she loved them deeply.
 

The Supreme Court emphasized that in cases of domestic homicides, particularly where a parent is accused of killing their own children, motive assumes exceptional importance. Observing that the prosecution had failed to establish any rational motive for the crime, the Court held: "Complete absence of motive behind the commission of crime, in the background of the fact that the appellant loved her children very much, as acknowledged by prosecution witnesses, puts a question mark on the presence of 'intention' to commit the act."
 

The Court carefully distinguished between mere act of causing death and the mental element necessary for constituting murder under Section 300 IPC. Citing earlier authorities including State of A.P. v. Rayavarapu Punnayya and Rampal Singh v. State of U.P., the Bench noted: "Culpable homicide is the genus, and murder is its species. All murders are culpable homicides but not vice versa."
 

Importantly, the Court addressed the defence based on mental instability. While declining to extend full protection under Section 84 IPC, the Court acknowledged that the claim of "invisible possession" made by a rustic villager could not be brushed aside lightly. The Court lamented that: "The Trial Court failed to exercise its powers under Section 165 of the Evidence Act to probe the plea of mental instability, despite being faced with an accused of extremely modest social and educational background."
 

It was emphasized that proof of medical insanity is not the sole test under Section 84 IPC and that legal insanity focuses on the cognitive incapacity to understand the nature of the act. The Court observed: "There is a vital distinction between medical insanity and legal insanity. The mere fact that a person is conceited, odd, irascible, and his brain is not quite all right, or his mind is liable to get hot, cannot be sufficient to attract Section 84 IPC."
 

Nonetheless, the combination of emotional disturbance, absence of motive, and lack of prior ill-will created sufficient reasonable doubt regarding the accused's intention to cause death.
While accepting that Chunni Bai had caused the deaths, the Court concluded that the prosecution failed to establish beyond reasonable doubt the requisite intention necessary for murder. The Court held: "Though the accused may not be completely entitled to the defence of insanity under Section 84 IPC, a reasonable doubt is created in the mind of the Court regarding the presence of 'intention' to commit murder."
 

Accordingly, the conviction under Section 302 IPC was set aside and altered to Section 304 Part II IPC. Since the appellant had already undergone over 9 years and 10 months in custody, the Court ordered her immediate release.
 

This judgment reinforces a fundamental principle of criminal law that mere proof of homicidal death is insufficient to sustain a conviction for murder unless intention is proved beyond reasonable doubt. The Supreme Court’s ruling reaffirms the nuanced application of Sections 299 and 300 IPC, especially where mental instability, absence of motive, and emotional circumstances cloud the clarity of intent.
 

The Court’s firm reminder resonates: "In the criminal justice system, it is not enough to prove the act; the mental element must also be established before branding a homicide as murder."

Date of Decision: April 28, 2025