IN THE HONOURABLE SUPREME COURT OF AMPHISSA

[SLP FILED UNDER ARTICLE 136 OF THE CONSTITUTION OF

AMPHISSA]
[P NO. /2022]

STATE OF PALLAKA ……PETITIONER

VERSUS

MICHAEL .................................................................................... RESPONDENT

ON SUBMISSION TO THE SUPREME COURT OF AMPHISSA

 MEMORIAL ON BEHALF OF THE PETITIONERS

TABLE OF CONTENTS

INDEX OF AUTHORITIES........................................................................................................II
□ LEGISLATION.......................................................................................................................................... II
□ CASES REFERRED.................................................................................................................................. II
□ BOOKS REFERRED............................................................................................................................... III
□ LAW LEXICON AND DICTIONARIES.............................................................................................. III
□ LEGAL DATABASES............................................................................................................................ IV

LIST OF ABBREVIATIONS ......................................................................................................

V
STATEMENT OF JURISDICTION .............................................................................................1
STATEMENT OF FACTS ...........................................................................................................2
ISSUES RAISED ..........................................................................................................................4
WHETHER THE SPECIAL LEAVE PETITION MAINTAINABLE? ...................................4
WHETHER SUFFICIENT GROUND OF LEGAL INSANITY EXISTS SO AS TO
EXONERATE THE ACCUSED FROM LIABILITY OF MURDER? ....................................4
WHETHER THE BURDEN OF PROOF OF LEGAL INSANITY ON THE PART OF
DEFENCE IS AT PAR WITH BURDEN OF PROOF ON PART OF
PROSECUTION? .......4
SUMMARY OF ARGUMENTS ..................................................................................................5
ARGUMENTS ADVANCED ......................................................................................................6
PRAYER .....................................................................................................................................16

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 MEMORIAL ON BEHALF OF THE PETITIONERS

INDEX OF AUTHORITIES

• LEGISLATION

1. The Constitution of India, 1951.

2. Criminal Procedure Code, 1973.
3. The Indian Penal Code, 1860.
4. Indian Evidence Act, 1872.

• CASES REFERRED

1. Bapu Gajraj Singh vs State of Rajasthan, 2007 ALL SCR 1829; (2007) 8
SCC 66.
2. Barelal vs. State, AIR 1960 MP 102.
3. Bhikari v. State of Uttar Pradesh, 1965 SCR (3) 194.
4. Bhikari vs. State of U.P., AIR 1966 SC 1.
5. Bhilari vs. State of UP, AIR 1966 SC 1.
6. C.C.E v. Standard Motor Products, AIR 1989 SC 1298.
7. Dahyabhai vs. State of Gujarat, AIR 1964 SC 1963.
8. Dale & Carrington Invt. Ltd. v. P.K. Prathapan, (2005) 1 SCC 212.
9. Harish Chandra vs. Rex, 1950 ALJ220.
10.Haryana State Industrial Corp. v. Cork Mfg. Co., (2007) 8 SCC 359.
11.In re Pappath Ammal, AIR 1959 Mad 239.
12. Janshed Hormusji Wadia v. Board of Trustees, Port of Mumbai, (2004) 3
SCC 214.
13. Justice K.S. Puttaswamy (Retd.), and Anr. v. Union of India and Ors, AIR
2015 SC 3081.
14.M.M.B. Catholics vs. Polo Avoas, AIR 1959 SC 31.
15.Pawan Kumar v. State of Haryana, (2003)11 SCC 241

16.R. v. M’Naughten, (1843) 8 E.R. 718; (1843) 10 Cl. & 200.

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 MEMORIAL ON BEHALF OF THE PETITIONERS
17. Ram Piari v. Bhagwant, AIR 1990 SC 1742.
18. Ramji Dayawala Sons ltd. Vs. Invest Import, AIR 1981 SC 2025.
19.Shrikant Anandrao Bhosale v. State of Maharashtra, (2002) 7 SCC 748.
20.Siddhapal Kamala Yadav vs. State of Maharastra, AIR 2009 SC 97.
21. Sir Chunilal Mehta and Sons, Ltd. v. Century Spinning and Manufacturing
Co. Ltd., AIR 1962 SC 1314.
22. Sir Chunilal Mehta and Sons, Ltd. v. Century Spinning and Manufacturing
Co. Ltd., AIR 1962 SC 1314.
23. SK Nair v. State of Punjab, Appeal Criminal 378 of 1987.
24.State of Rajasthan vs. Shera Ram Vishnu Dutta, AIR 2012 SC 1.
25.State of UP vs. Ram Swarup, AIR 1974 SC 1570.
26.State vs. Chotte Lal, AIR 1959 MP 203.
27.State vs. Kartik Chandra, AIR 1951 Assam 79.
28.Sumati Dayal v. CIT, (1995) 214 ITR 801.
29.Surendra Mishra v. State of Jharkhand, AIR 2011 SC 627.

• BOOKS REFERRED

1. Dr. J.N. Pandey, THE CONSTITUTIONAL LAW OF INDIA, (51st ed.,

2014).
2. Dr. S.C. Kashyap, CONSTITUTIONAL LAW OF INDIA, (1st ed., 2008).
3. M.P. Jain, INDIAN CONSTITUTIONAL LAW, (7th ed., 2015).
4. Ratanlal&Dhirajlal, THE INDIAN PENAL CODE, (34th ed., 2014)

• LAW LEXICON AND DICTIONARIES

1. Bryan A. Garner, BLACK’S LAW DICTIONARY, (2nd ed., 2004).

2. Justice R.P. Sethi, SUPREME COURT ON WORDS AND PHRASES,
(2nd ed., 2004).

3. Webster’s UNIVERSAL DICTIONARY, (1st ed., 1993).

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 MEMORIAL ON BEHALF OF THE PETITIONERS

• LEGAL DATABASES

1. www.indiancaselaws.org
2. www.indiankanoon.org
3. www.judic.nic.in
4. www.lexisnexis.com
5. www.scconline.co.in

IV
MEMORIAL ON BEHALF OF THE PETITIONERS
 LIST OF ABBREVIATIONS
And
& All India Reporter
AIR Another
Anr. Article
Art. Honourable
Hon’ble Others
Ors. Supreme Court Cases
S.C.C. Supreme Court
SC V. Versus

PIL Public Interest Litigation

Co. Company

Corp. cl. Corporation

No. Clause
Number
S.C.R.
Supreme Court Reports
J.
Justice
u/a
Under article
UKHL
United Kingdom House of Lords
LR
Law Review
Vol.
Volume
NCT
National Capital Territory
IPC §
Indian Penal Code
Section

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 MEMORIAL ON BEHALF OF THE PETITIONERS

STATEMENT OF JURISDICTION

The Hon’ble Supreme Court of Amphissa has the jurisdiction to hear the
instant matter under Article 136 of the Constitution of Indiana, which states
that Article 136 in the Constitution of Indiana 1949
136. Special leave to appeal by the Supreme Court

(1) Notwithstanding anything in this Chapter, the Supreme Court may, in its
discretion, grant special leave to appeal from any judgment, decree,
determination, sentence or order in any cause or matter passed or made by any
court or tribunal in the territory of India.

(2) Nothing in clause (1) shall apply to any judgment, determination,

sentence or order passed or made by any court or tribunal constituted by or under
any law relating to the Armed Forces.
 1

MEMORIAL ON BEHALF OF THE PETITIONERS

STATEMENT OF FACTS
a) That the Democratic Republic of Amphissa is a quasi-federal country comprising of 35 states
with strong central Government. The Laws of Amphissa are in Pari-materia with the Laws of
India.
Pallaka is among one of the developed states of Amphissa.
b) That Michael and Jenny are citizen of Amphissa, resident of Flemingo, a small town of Pallaka.
c) That Michael, aged 29, S/O- Late John, R/O- 54/3-New Ext. Apartment, Flemingo, and Jenny,
Aged 24 yrs, D/O- Defrado, R/O- Greater Ango Colony, Flemingo, were married on 25 th Feb,
2016 according to their religious rituals.
d) That their marital life was going smoothly, except on some occasions when they used to have
few verbal quarrels but reconciled soon after.
e) That the two had a daughter named Jennifer on 4 th September 2018, after which, Jenny observed
certain changes in the behaviour of Michael who, started behaving in a rude way and became
violent on every petty issue without any reason.
f) That Jenny took Michael to the doctor Alfered (DW1), a psychiatrist who advised Michael to
have control over anger and take certain medicines. The doctor diagnosed him to be suffering
from first stage of Bipolar Mood Disorder (Bipolar disorder, also known as manic-depressive
illness, is a brain disorder that causes unusual shifts in mood, energy, activity levels, and the
ability to carry out day-to-day tasks. There are four basic types of bipolar disorder; all of them
involve clear changes in mood, energy, and activity levels).
g) That the violent behaviour of Michael continued to exist. On slight issues Michael becomes
violent and he also started to fight with Jenny and he also use to beat him without any reason.
h) That on 5th December 2018 at 11am, loud noise of fighting, crying and shouting came from the
house of Michael. On hearing the cry, Daniel (PW3), neighbour of Michael went to their house
and found Jenny lying unconscious on the floor pooled in blood with various injuries on her
body. Daniel also saw Michael hiding a 7 inch Iron Axe in the garden.
i) That Daniel called the police and Jenny was taken to government hospital whereby she was
treated by Dr. Andrew (PW2). Michael was arrested by police on the same day and was kept in
police custody.
j) That on 6th December, 2018 Jenny regained her consciousness and her statement was recorded by
Jaison (PW1) SHO of Flemingo Police Station. She stated that:
k) On 5th December at 10 am Michael came home and started fighting with her in a violent way and
when she resisted Michael attacked him with axe kept in the garden.
l) That on 8th December Jenny died because of the injury in her lower abdomen which proved fatal.
Jennifer the daughter of Michael was sent to Government Child Care Centre.

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 MEMORIAL ON BEHALF OF THE PETITIONERS
m) That on the basis of the statement of Daniel and the dying declaration of Jenny, FIR was lodged
against Michael vide. 733/2018 in Flemingo police station. Michael was prosecuted under
Section 302 of IPC for the murder of Jenny. During interrogation Michael stated that he was
unconscious at the time when Jenny was attacked. He told to police that when he regained his
consciousness he found Jenny lying on the floor and axe in his hand. He told to the police that he
did not know from where the axe came and he also stated that he did not know how Jenny died.
Final Report was submitted on 3rd Feb.2019 in which Michael was charged for murder of Jenny
under Section 302 of IPC. The case (State of Pallaka vs. Michael) was tried by the Session Court
vide Session Trial No-57/2019.
n) That on 3rd September 2020 Michael was found guilty of intentional murder of Jenny and
convicted under Section 302 IPC and sentenced to 10 years Rigorous Imprisonment.
o) That the accused feeling aggrieved by the said judgment preferred an appeal before the High
Court of Pallaka on dated 9th October 2020 vide Criminal Appeal No. 875/2020. The High Court
relying on the version of the doctor treating the accused for Bipolar Mood Disorder found that
the accused at the time of committing crime was suffering from both legal and medical insanity
and accordingly the Court acquitted the accused from the charge of murder on dated 5 th
September 2021.
p) That the State of Pallaka has preferred an appeal before the Supreme Court of Amphissa against
the order of acquittal by the High Court of Pallaka.

MEMORIAL ON BEHALF OF THE PETITIONERS

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 ISSUES RAISED

WHETHER SUFFICIENT GROUND OF LEGAL INSANITY EXISTS SO AS TO

EXONERATE THE ACCUSED FROM LIABILITY OF MURDER.

WHETHER THE BURDEN OF PROOF OF LEGAL INSANITY ON THE PART OF

I. DEFENCE IS AT PAR WITH BURDEN OF PROOF ON PART OF PROSECUTION?

II.
THE PARTIES MAY RAISE ANY OTHER ISSUE ON THE GIVEN FACTS TO
ADVANCE ARGUMENTS UPON.
III.

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 MEMORIAL ON BEHALF OF THE PETITIONERS

SUMMARY OF ARGUMENTS
1. WHETHER SUFFICIENT GROUND OF LEGAL INSANITY EXISTS SO
AS TO EXONERATE THE ACCUSED FROM LIABILITY OF MURDER?

It is humbly submitted before the Hon’ble SC of Amphissa that there is no

sufficient ground to exonerate the accused from the liability of murder.

2. WHETHER THE BURDEN OF PROOF OF LEGAL INSANITY ON THE

PART OF DEFENCE IS AT PAR WITH BURDEN OF PROOF ON PART
OF PROSECUTION?

The Counsel on behalf of the Petitioners humbly submits to the Hon’ble SC of

Amphissa that the burden of proof of legal insanity is at par for both the
Prosecution and the accused.

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 MEMORIAL ON BEHALF OF THE PETITIONERS

ARGUMENTS ADVANCED

1. WHETHER SUFFICIENT GROUND OF LEGAL INSANITY

EXISTS SO AS TO EXONERATE THE ACCUSED FROM
LIABILITY OF MURDER?

The Counsel on behalf of the Petitioners humbly submits before the Hon’ble SC
of Amphissa that sufficient ground of legal insanity does exist so as to exonerate
the accused from the liability of murder.

The Counsel humbly puts forth that Section 84 of the Indian Penal Code states
that

"Nothing is an offence which is done by a person who, at the time of doing it,
by reason 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.”15

In order to gain the protection of section 84 IPC, 1860, it must be shown that, at
the time of the commission of the act, the accused was unable to either recognize
the meaning of the act or whether the act was either morally incorrect or contrary
to the law, and it is most important to assess his state of mind before and after the
execution of the offence.

But there is no proof of part of the accused that he was insane at time of injuring
Jenny or that he was going through a mood disorder as he was diagnosed with
bipolar disorder which is a mere mood disorder and not complete insanity.

The Counsel humbly states that a number of tests have been given from time to
time for this purpose and the kind and degree of insanity available as a defence
against a crime. But the most notable among all is the R. v. M’Naughten’s case.16
In this case the law relating to insanity is to be found in the form of replies given
by the 15 judges of the House of Lords to the five questions put to them with a
view to clarifying the law on this subject. The two questions that arose were:

a) What are the proper questions to be submitted to the jury where a person,
alleged to be afflicted with insane delusions respecting one or more
particular subject or persons, is charged with the commission of a crime
and insanity is set up as a defence?

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 MEMORIAL ON BEHALF OF THE PETITIONERS

b) In what terms ought the questions to be left to the jury as to the prisoner’s
state of mind at the time when the act was committed?17 The answers to
these questions were:

Every man is presumed to be sane, and to possess a sufficient degree of reason to

be responsible for his crimes, until the contrary be proved to their satisfaction;
and that to establish a defence on the ground of insanity, it must be clearly proved
that, at the time of committing the act, the party accused was labouring under
such a defect of reason, from the disease of the mind, as not to know the nature
and the quality of the act he was doing; or if he did know it, that he did not know
he was doing what was wrong.

Section 84 of The Indian Penal Code embodies two different mental conditions to
claim exemption from criminal liability, namely:

i. The accused was incapable of knowing the nature of the act, owing to
the unsoundness of the mind, or
ii. The accused was precluded by reason of unsoundness of mind from
understanding that what he was doing was either wrong or was contrary
to law.

Since it is a well-established principle of criminal law that there are basically 2

elements which are necessary to be established in order to prove him guilty for an
offence which are namely Mens Rea (guilty mind) and Actus Reus (wrong or
unlawful Action). The legal maxim Actus Non-Facet Reum Nisi Mens sit Rea
which means that ‘The act and the intent must both conquer together in order to
constitute a crime.’

In the instant case the accused, Michael was diagnosed with bipolar disorder as
doctor Alfered (DW1), who was a psychiatrist who diagnosed him to be suffering
from first stage of Bipolar Mood Disorder (Bipolar disorder, also known as
manic-depressive illness, is a brain disorder that causes unusual shifts in mood,
energy, activity levels but there is no proof that at the time of murder he was
going through mood disorder because bipolar disorder is a disorder of mood and
a person doesn’t go through the disorder of mood every time.

Section 300 of the Indian Penal Code, 1860 states -

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 MEMORIAL ON BEHALF OF THE PETITIONERS

“Except in the cases hereinafter excepted, culpable homicide is murder,

if the act by which the death is caused is done with the intention of
causing death, or-18

Secondly.-If it is done with the intention of causing such bodily injury as

the offender knows to be likely to cause the death of the person to whom
the harm is caused, or-19

Thirdly.-If it is done with the intention of causing bodily injury to any

person and the bodily injury intended to be inflicted is sufficient in the
ordinary course of nature to cause death, or-
Fourthly.-If the person committing the act knows that it is so imminently
dangerous that it must, in all probability, cause death or such bodily injury
as is likely to cause death, and commits such act without any excuse for
incurring the risk of causing death or such injury as aforesaid.”20

As per this section the essentials of murder under section 300 are Intention of
causing death and knowledge that death would be caused and both this essentials
are fulfilled in the given case because Michael was in the right state of mind,
attacking and killing someone with a axe was sufficient intention and knowledge
that the accused would die and also after the murder was committed Michael was
trying to hide the weapon as deposed by Daniel (PW3),21 which shows his clear
understanding of the act committed and the consequences thereafter, which an
insane person does not possess.

The Hon’ble Supreme Court in Shrikant Anandrao Bhosale v. State of

Maharashtra,22 has held that the time when the unsoundness has to be proven is
the time when the crime is actually committed and the burden of proving this, lies
on the party which is claiming the benefit of Section 84.

Since in the given case, Michael has no proof that he was insane at the time of
murder so he cannot be exempted under the defence of section 84. This can also
be corroborated through the different statements made by the accused Michael at
two different point of time. At first, during interrogation, Michael stated that he
was unconscious at the time when Jenny was attacked as he found Jenny lying on
floor with blood all over when he regained consciousness. But, at the later stage,
Michael took the plea of insanity suffering from Bipolar Mood Disorder and
therefore, he could not understand the nature of his act and its consequences.23

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 MEMORIAL ON BEHALF OF THE PETITIONERS

The Counsel humbly states that in the case of Bhikari v. State of Uttar Pradesh,24
the accused was working in the field. A few months before the occurrence, he
had threatened to kill all the family members of the deceased. Further, on the date
of the event, though there were other people around, he carefully chose only the
children of the deceased’s family. All this indicated that his actions were
deliberately pre meditated and not acts of an insane man.

In the given case Michael had the knowledge that Jenny would die if attacked
with the axe and he had the intention for the same. Also the knowledge of hiding
the murder weapon and leaving no traces behind also shows that he had enough
knowledge and intention which insane person cannot have.25

Also, in the case of SK Nair v. State of Punjab,26 the accused tried to assault a
person with a dagger. The deceased caught hold of him and said that the matter
will be reported to the superiors. The accused retorted to the deceased with the
words ‘only if you were still alive’ and inflicted a blow with a khukri on the
deceased and killed him. The defence of the accused was that he suffered from
paranoia. A paranoid is not only a person of unsound mind, but also suffers from
special and peculiar ideas and visions, which are different from other persons of
unsound mind. A paranoid within moments may behave wildly and then be
normal again. The threat meted out by the accused to the deceased showed that at
the time of the commission of the crime, the accused did not lose his sense of
understanding. He was, therefore, convicted under s 302 and sentenced to life
imprisonment.27

In the instant case, Michael killed Jenny during an argument and he has also tried
to hurt Jenny earlier hence he had clear intention to kill her.

In Bapu Gajraj Singh vs State of Rajasthan,28 Hon’ble Supreme Court held that
mere abnormality of mind or partial delusion, irresistible impulse or compulsive
behaviour of a psychopath affords no protection under Section 84 IPC.

.
Also in the given case, there is no sufficient ground to prove that Michael was
insane and because of the mere fact of mood swings he cannot be protected
under section 84.

The Hon’ble Supreme Court in Surendra Mishra v. State of Jharkhand,29 held

that Section 84 IPC is only for legal insanity and not medical insanity and
therefore a person suffering from mental illness is not exempted from criminal
liability.

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 MEMORIAL ON BEHALF OF THE PETITIONERS
Therefore, under Section 84 of the Indian Penal Code, it is not only that the
person is suffering from mental illness but it is the circumstances based upon
evidences that are essential to prove that the person was also unable to
understand the nature of his act and committed a crime.

In the instant case, there is no sufficient ground that proves that Michael was
legally insane.

2. WHETHER THE BURDEN OF PROOF OF LEGAL INSANITY

ON THE PART OF DEFENCE IS AT PAR WITH BURDEN OF
PROOF ON PART OF PROSECUTION?
It is humbly submitted by the Counsel on behalf of the Petitioners to the Hon’ble
SC that the burden of proof on the part of the prosecution is at par with the
burden of proof by the Respondent.
The Counsel on behalf of the Petitioner humbly submit that u/s 101 of the Indian

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 MEMORIAL ON BEHALF OF THE PETITIONERS

Evidence Act, 1872, the burden of proof lies on any person who desires any
Court to give judgment as to any legal right or liability dependent on the
existence of facts which he asserts. The person alleging those facts must prove
that those facts exist.30
The question of onus or burden of proof at the end of the case, when both the
parties have adduced their evidence is not of very great importance and the
Court has to come to a decision on consideration of all materials.31
A number of tests have been given from time to time for this purpose and the
kind and degree of insanity available as a defence against a crime. But the most
notable among all is the R. v. M’Naughten’s case.32 In this case the law relating
to insanity is to be found in the form of replies given by the 15 judges of the
House of Lords to the five questions put to them with a view to clarifying the law
on this subject. The two questions that arose were:
1. What are the proper questions to be submitted to the jury where a person,
alleged to be afflicted with insane delusions respecting one or more
particular subject or persons, is charged with the commission of a crime
and insanity is set up as a defence?
2. In what terms ought the questions to be left to the jury as to theprisoner’s
state of mind at the time when the act was committed? The answers to these
questions were:
Every man is presumed to be sane, and to possess a sufficient degree of reason to
be responsible for his crimes, until the contrary be proved to their satisfaction;
and that to establish a defence on the ground of insanity, it must be clearly proved
that, at the time of committing the act, the party accused was labouring under
such a defect of reason, from the disease of the mind, as not to know the nature
and the quality of the act he was doing; or if he did know it, that he did not know
he was doing what was wrong.33
The Counsel humbly puts forward that the burden of proof as determining factor
of the whole case can only arise if the tribunal finds the evidence pro and cons so
evenly that it cannot come to any conclusion.34 It was held that in the same case
that if the tribunal after hearing and weighing the evidences comes to a
determinate conclusion the onus has nothing to do with it, and need not be further
considered. The case is to be decided on merits without taking into consideration
as to on which of the party the burden of proof lay.35
The Section 105 of the Indian Evidence Act, 1872 states about the burden of
proving that case of accused comes within exceptions.
“When a person is accused of any offence, the burden of proving the
existence of circumstances bringing the case within any of the General

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 MEMORIAL ON BEHALF OF THE PETITIONERS
Exceptions in the Indian Penal Code, (45 of 1860), or within any special
exception or proviso contained in any other part of the same Code, or in
any law defining the offence, is upon him, and the Court shall presume the
absence of such circumstances.”
It is humbly submitted before the Hon’ble SC of Amphissa that if an accused
pleads insanity he has to prove that he was insane at the time of the occurrence.36
The Counsel also puts forth that a person alleged to be suffering from any mental
disorder cannot be exempted from criminal liability ipso facto. The onus is on the
accused to prove that he is suffering from mental disability or condition that he
would not be expected to be aware of consequence.37 If an accused takes the plea
of insanity, it lies upon him to prove that he was insane at the time of commission
of the offence.38
The onus of proof has to be discharged by producing the offence at the time or
immediately afterwards, also by evidence of his mental condition and other
factors.39

Therefore, it can be stated that the burden of proof is at par for both the
Prosecution and the Accused.

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 MEMORIAL ON BEHALF OF THE PETITIONERS

PRAYER

IN THE LIGHT OF THE ISSUES RAISED, ARGUMENTS ADVANCED AND

AUTHORITIES CITED, THE COUNSEL FOR PETITIONER HUMBLY
PRAYS THAT THE HON‟BLE HIGH COURT BE PLEASED TO DECLARE
THAT:

1. The special leave petition filed before the hon’ble court is

maintainable
2. The ground of lgal insanity is not so much as to exonerate the accused
from the liability of murder

3. The burden of proof on the part of defence is at part with the burden
of proof on the part of the prosecution

AND/OR
PASS ANY ORDER THAT THIS HON’BLE COURT MAY DEEM FIT IN
THE INTEREST OF JUSTICE, EQUITY AND GOOD CONSCIENCE.
AND FOR THIS ACT OF KINDNESS, THE COUNSELS
FOR THE PETITIONER AS IN DUTY BOUND
SHALL FOREVER PRAY.

COUNSEL FOR THE PETITIONERS

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