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RELEVANT CASES TO SECTION 84 (IPC):

Sulaiman Pillai v. State of Kerala, 1995 Supp (3) SCC 695

Mohd. Anwar v. State (NCT of Delhi), (2020) 7 SCC 391

Mariappan v. State of Tamil Nadu, (2013) 12 SCC 270

Amrit Bhushan Gupta v. Union of India, (1977) 1 SCC 180

State of H.P. v. Gian Chand, (2001) 6 SCC 71

S.K. Nair v. State of Punjab, (1997) 1 SCC 141

Hari Singh Gond v. State of M.P., (2008) 16 SCC 109

Sidhapal Kamala Yadav v. State of Mahara ..., (2009) 1 SCC 124

Ravji v. State of Rajasthan, (1996) 2 SCC 175

Jagdish v. State of M.P., (2009) 9 SCC 495

Jai Lal vs Delhi Administration on 30 April, 1968

Sidhapal Kamala Yadav v. State of Maharashtra

Keshaorao Bhiosanji Navale v. State of Maharashtra (Bombay HC)

The courts play an important rule as they have to make sure that a sane person doesn’t
absolve himself by wrongfully using the defence in his favour. In many jurisdictions,
this defence has been abolished completely, e.g., Germany, Thailand, Argentina, etc.
Ashis Dey v. State, 2003 SCC OnLine Cal 424

Annadurai v. State, 2012 SCC OnLine Cal 7718

Syed Yousuf v. State of Maharashtra, 2004 SCC OnLine Bom 733

Pralhad Mukinda Kshirsagar v. State of Maharashtra

Laxmandas Mangaldas Manikpuri v. State of Maharshtra

Vyankatesh Maruti Arandekarnaik v. State of Maharashtra

Mahadev Sonu Pardhi v. State of Maharashtra

Shanti Devi v. State, 1967 SCC OnLine Del 56

Nana v. State of Maharashtra, 1999 SCC OnLine Bom 924


1: Ratan Lal VS State of Madhya Pradesh *

It is now well-settled that the crucial point of time at which unsoundness of mind should be
established is the time when the crime is actually committed and the burden of proving this
lies of on the accused.

2: D.G Thakker VS. State of Gujrat *

There is a presumption that the accused was not insane, when he committed the crime, in the
sense laid down by s.84 of the Indian Penal Code: the accused may rebut it by placing before
the court all the relevant evidence-oral, documentary or circumstantial.

3: Sheralli Wali Mohammed vs The State of Maharashtra *

The law presumes that every person of the age of discretion to be sane unless the contrary is
proved. It would be most dangerous to admit the defence of insanity upon arguments derived
merely from the character of the crime.

4: Bapu Vs State of Rajasthan *

Mere abnormality of mind or partial delusion, irresistible impulse or compulsive behaviour of


a psychopath affords no protection under section 84 of IPC. The mere fact that an accused is
conceited, odd irascible and his brain is not quite all right, or that the physical and mental
ailments from which he suffered had rendered his intellect weak and had affected his
emotions and will, or that he had committed certain unusual acts, in the past or that he was
liable to recurring fits of insanity at short intervals, or that he was subject to getting epileptic
fits but there was nothing abnormal in his behaviour, or that his behaviour was queer, cannot
be sufficient to attract the application of this section.

5: Surendra Mishra Vs. State of Jharkhand *

In our opinion, an accused who seeks exoneration from liability of an act under Section 84 of
the Indian Penal Code is to prove legal insanity and not medical insanity. Expression
"unsoundness of mind" has not been defined in the Indian Penal Code and it has mainly been
treated as equivalent to insanity. But the term insanity carries different meaning in different
contexts and describes varying degrees of mental disorder. Every person who is suffering
from mental disease is not ipso facto exempted from criminal liability.
6: S.K. Nair Vs. State of Punjab *

It can not be said that being a paranoid, the appellant must be presumed to have committed
the said offences being seized of sudden impulsive fits of passion due to which temporarily
he was completely incapable of understanding the consequences of the acts.

7: Jagdish Vs. State of M.P *

The benefit of section 84 of ipc is available to a person who at the time of when act was done
was incapable of knowing the nature of his act or that what he was doing wrong or contrary
of law. The implication of this provision is that the offender must be of unsound mind at the
time of commencement of act and his unsoundness of mind earlier or later are relevant only
to the extent that they, along with other evidences, may be circumstances in determining the
mental condition of an accused on the day of the incident.

8: State of M.P Vs. Nandu

There cannot be any sentence/punishment less than imprisonment for life, if an accused is
convicted for the offence punishable under Section 302 IPC. Any punishment less than the
imprisonment for life for the offence punishable under Section 302 would be contrary to
Section 302 IPC.

9: Elavarasan Vs. State *

Intention or the state of mind of a person is ordinarily inferred from circumstances of the
case. This implies that, if a person deliberately assaults to onether and cause injury to him,
then depending upon the weapon used and the body part on which it is struck, it would be
reasonable to assume that the accused had the intention to cause the kind of injury which he
inflicted.

10: Ravji Vs. State of Rajasthan *

It is the nature and gravity of the crime not the criminal which should be in consideration for
appropriate punishment in criminal trial. The court will be failing in its duty if appropriate
punishment is not awarded for a crime which has been committed not against only an
indivisual victim but also against the society.
11: Prem Singh vs State (Govt Of Nct Of Delhi)

To examine the guilt of the appellant, we must appreciate the evidence adduced by the
prosecution.

12:

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