JAI LAL v. DELHI ADMINISTRATION AIR 1969SC 15 By: Adv. Rushil

    Relevant Section : Section 84 of the Indian Penal Code

    Facts-
    The appellant was a railway employee and often lost his temper and had altercations with other clerks in the office. In October 1960 he was found to be suffering from a mental illness as he exhibited symptom of acute schizophrenia and showed disorder of thought emotion and perception of external realities. He was treated for and was cured of this illness by July 1961 when he resumed his duties. On the morning of November 25, he went to office as usual but as he was late in attendance he was marked absent. He applied in writing for one day’s casual leave and returned home. No one noticed any symptoms of any mental disorder at that time. Just after 1 o’clock he entered his neighbour’s house and stabbed and killed a girl 1 ½ year old and later also stabbed and injured two other persons with a knife.

    He was thereafter arrested and interrogated on the same day when he gave normal and intelligent answers. After his arrest and upon a medical examination, the appellant was declared to be lunatic though not violent and the psychiatrist found that he had had a relapse of Schizophrenia. A plea of insanity was raised as a defence. But his subsequent behaviour was taken into consideration by the court as he hid the knife, locked himself in the house to prevent arrest and attempted to run away from the back door. He also tried to dispense the crowd by throwing brickbats from the roof.
    Held-
    To establish that the acts done were not offences under section 84 it must be proved clearly that at the time of the commission of the acts the appellant , by reason of unsoundness of mind, was incapable of knowing that the acts were either morally wrong or contrary to law.

    The outlook of accused suffering from such mental impairment at the time of the commission of the act is of paramount importance and frame of his mind before and after the crucial act is relevant. There is medical evidence, that between 12 October, 1960 and 12 January,1961, when he resumed his normal duties he was found to be normal. But it was theorized that at even at the moments of greatest excitement, he was able to differentiate between right and wrong. His intelligent answers to authorities indicated that there was nothing abnormal with his state of mind. The Supreme Court held that there was a wakefulness of guilt in his conduct. He was aware of the physicality of stabbing and that it would kill. He was convicted under section 302 was sentenced to life imprisonment. However, in the determination of question of insanity, at the time when the act was committed the chronicle of the state of mind of accused is necessary to adduce him guilty.