Indian Case Title and Citation	Page No.
Ashiruddin Ahmed vs The King AIR 1949 Cal. 182	12
Dayabhai Chhaganbhai Thakker v. State of Gujrat AIR 1964 SCR (7) 361	14
Geron Ali v. Emperor AIR 1941 Cal. 129	13
Laksmi v. State AIR 1959 All. 534	13

Foreign Case Title and Citation	Page No.
Durham v. U.S 214 F 2d 862, 869 et req. (D.C. cir. 1954)	11
Hadfield Case 1800, 27 St.Tr.128	9
R v. M’Naghten (1843) 8 Eng Rep 718	10
R. v. Arnold (1724) 16 St. Tr. 695	9
Regina v. John M [2003] EWCA Crim 3452 Court of Appeal	17

CHAPTER 1: INTRODUCTION

Abstract

People suffering from mental illness are incapable of committing crimes because they lack the mental capacity to construct the appropriate mental element, which is a necessary component of every crime. Such individuals are protected from criminal culpability under the law if they are unable to understand the nature, wrongfulness, or illegality of the act. The foundation of the law of insanity in English criminal law sytem was laid down by the House of Lords in case which is popularly known as the M’Naghten case in 1843. In India section 84[1] of IPC deals with the defence of insanity which is also based on M’Naghten. There are also some distinction between section 84 and M’Naghten Rule. The purpose of this paper is to examine the numerous tests used by courts to determine liability of such individuals, as well as the procedures for their trial, detention, and release.

Keywords: Insanity, Defence, M’Naghten Rule.

Introduction

The question of insanity is one of the most complex in all of criminal law, and it has sparked countless debates and discussion. It's been the source of bitter rivalry between the medical and legal professions. The term “mental illness, disorder, defect” refers to a condition requiring medical treatment by psychiatrist or psychologist whereas word insanity is a legal term. Insanity is “unsoundness of mind, incapacity to reason or judge or by uncontrollable impulses. In law such a want of reason, memory, and intelligence as prevents a man from comprehending the nature and consequences of his acts or from distinguishing between right and wrong conduct”[2]. If we may deduce anything from a review of the history of insanity as a defence in previous law, insanity appears to be a question of fact not governed by rigid legal standards. Recent trends point to an increase in the acceptance of insanity as a fact rather than a legal issue.

Statement of Problem

Despite a number of indicator/sign provided by modern medical science and psychiatry in order to determine the state of mind of the accused pleading insanity, as well as some progressive statutory and judicial inroads made in overseas jurisdictions, including in the country of its origin, the Indian legislature and courts have been unable to bring any reforms in the law of insanity. As a result, the occurrence of mental derangement that does not come within the scope of section 84 of IPC has been only cited as a extenuating circumstance[3].

Review of Literature

Vageshwari Deswal “Insanity as a defence to criminal charge: An analysis”[4]-

This paper majorly focuses on the applicability of section 84 of Indian Penal Code. It talks about the incapability of accused person to know the nature of his action due to unsoundness of mind. It also differentiate between legal and medical insanity.

Dahiya S “Insanity as a defence under the Indian Penal Code: Different dimensions”[5](1970)

This article covers the overall aspect of Insanity as a defence from English and Indian Criminal Jurisprudence viewpoint. It talks about M’Naghten rule, Durham Rule, Model Penal Code Test and also covers the controversies over M’Naghten Rule.

Stanley Yeo “The Insanity Defence in the Criminal Laws of the Commonwealth of Nations[6]” (2008)

In this article, the M'Naghten regulations are compared to some of the principal variances found in the Commonwealth of Nations in this article and the comparison demonstrates how the M'Naghten formulation's underlying structure is generally in good shape.

Anoushka Singh “The Dodge or Defence of Insanity” (2020)[7]

This article focuses on the defence of Insanity in Indian Persepective. It talks about the negative and positive features of Indian Law.

Research Objectives

The goal of the research is:

To discuss the law relating to the insanity as a defence under the Indian and English Criminal Jurisprudence.
To understand the judicial interpretation on insanity as a defence.

Hypothesis

A person's insanity does not make them inhuman. Defence of Insanity is an absolute defence in Indian legal system. Perpetrator may not deserve to be punished, but they do require medical attention. They must be placed in safe custody, handed to a relative or friend, or committed to an asylum instead of punishment.

Research Question

What are the legal standards and procedures for the assessment of insanity defence?

Research Methodology

The methodology adopted to complete the current study is doctrinal research approach in conjunction with relevant case law and literature in the form of reports, journals, commentaries, and cases to fulfil the study's goal.

The mode of citation followed is Oscola (Oxford University).

Limitation & Scope

The project concentrates on the Defence of Insanity in India and England and how the legislature and judiciary through statutes and case laws has interpreted it.

CHAPTER 2: ORIGIN OF TEST OF INSANITY

Wild Beast test:

In R. v. Arnold[8], the defendant was tried for injuring and trying to kill Lord Onslow, and the Wild Best Test was established. There was enough proof of the accused's mental instability to convict him. Tracy J. in this case said that, “He could not be guilty of any crime under any law whatever if he was under the visitation of God, and could not differentiate between good and evil, and did not know what he did, even though he committed the worst transgression”. Due to mental illness, a person might claim immunity from guilt if he was unable to differentiate between good and evil and had no idea what he was doing.

Insane Delusion Test:

This test was the second step in the insanity defence process. The House of Lords established it in the Hadfield Case[9]. The accused Hadfield charged in this case for attempting to murder King George III. Mr. Erskine's defence attorney was successful in showing that the accused was suffering from an insane delusion, a mental illness, and thus got a not guilty judgement. The defence argued that insanity should be determined by the fact that the accused was suffering from fixed mad delusions that were the direct cause of his offence.

M’Naghten Rule:

Daniel McNaghten's decision became a widely accepted rule for the plea of insanity defence because it established an assertive criteria for assessing insanity defence. According to the R v. M’Naghten[10]case, Daniel McNaghten (accused) was charged with the murder of Edmond Drummond who was private secretary of then Prime Minister. McNaghten was delusional enough to believe that Prime Minister Sir Robert Peel was the only source of his issues. He mistaken Drummond for Sir Robert and shot and murdered him as a result. During the trial, the defendant pled not guilty due to insanity. McNaghten was acquitted on the grounds of insanity by the court following a fair trial and the jury's report.

“The accused, in order to get relief from criminal responsibility on the grounds of insanity, must prove that, due to a defect of reason caused by a mental disease, he did not know the nature and quality of his act, and if he did know this, that he did not know that he was doing wrong,” according to the test. Following his acquittal, the public indignation drove the adoption of the M’Naghten Rules, a rigorous definition of legal insanity. The outrage and condemnation directed at the decision necessitated a debate in Parliament. As a result, it was decided to seek the advice of the House of Lords judges in order to clarify the law on the subject. As a result, on June 19th, 1843, the judges were asked to respond to the five questions posed to them.

The following conclusion can be drawn from the judges' responses —

Unless the contrary is proven to the satisfaction of the judges or the court, every individual is deemed to be sane and to possess sufficient degree of reason to be liable for his actions.
To prove insanity as a defence, it must be demonstrated that the accused was suffering from such a defect of reason as a result of a mental illness that he did not realize the kind and quality of the act he was committing was wrong.
The accused would be punished if he was aware that the act was one that he should not have done and that it was also against the law.
A medical witness who has not met the accused prior to the trial should not be questioned if the evidence leads him to believe the accused is insane.
Where a criminal conduct is undertaken by a person who is under the influence of an insane delusion about the surrounding facts, which conceals the true nature of the act he is committing, he will bear the same level of guilt as if the facts were as he understood them to be.

Irresistible impulse

M’Naghten rule faced so much criticism. As a result, this test was added to the M’Naghten rule. It act as a supplemental or additional rule. This test applied in those cases where the defendant was aware of his right and wrongs action, but still acted due to irresistible or uncontrollable impulse. This test was first incorporated by law in 1884, and by 1967, 18 of the 51 states in the United States had implemented M'Naghten's irresistible impulse combination test.

This test was also criticize by Royal Commission on Capital Punishment on the ground that it is very hard to made distinction between controllable and uncontrollable impulse and possibility of misusing this test is high.

Durham Test or Product Test:

In case Durham v. U.S,[11] the United States District Court for the District of Columbia found defendant guilty of housebreaking. At the trial, the accused took defence that he was of insane at the time of the committing the crime. He had a long previous medical history and imprisonment. Even, he was expelled from Navy duty due to some psychiatric reasons.

The lower court found him guilty as it had not been established that at the time of commission of offence he’s not able to know the differences between right and wrong. And further, that he is subjected to an irresistible impulse by reason of deranged mind.

Defended on the 2 grounds appeal to US Courts of Appeals, District of Columbia Circuit.

Trial court didn’t correctly apply existing rules governing the burden of proof on the defence of insanity and
Existing criminal responsibility tests are outdated and should be replaced.

The Court, overruled that ‘existing test of “right and wrong” which is supplemented by the “irresistible impulse test” and also repudiate the rule of M’Naghten. While doing so, court stated that right and wrong test “does not take sufficient amount of psychic realities and scientific knowledge and it is based upon one symptom and so cannot validly be applied in all circumstances… the ‘irresistible impulse’ test gives no recognition to mental illness characterized by brooding and reflection”.

Durham Rule was established by Judge David L. Bazelon. According to this rule, if the illegal act was the result of a mental illness, the accused is not legally accountable.

CHAPTER 3:LAWS OF INSANITY IN INDIA

Section 84 of Indian Penal Code:

Act of a person of unsound mind.—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.

In India, in order to plead insanity as a defence it must be proven that the accused was unsound at the time of commission of crime. This section is only concerned with the insanity which existed during the time commission of crime.

This section under Indian law is derived from the M’Naghten Rule established by the English judiciary. It's also worth noting that, along with a few other tests, the McNaghten rules is an essential one for determining insanity.

Key principle of this section is “Actus non facit reum nisi mens sit rea” which means that “An act does not constitute guilt unless done with a guilty intention”. In order for an act to be considered a crime, both the purpose and the act must be present, however in the case of insane people, no blame is assigned to them since they lack free will. Section 84[12] includes two mental conditions arising from unsoundness of mind and accused has to prove:

that his unsoundness of mind was such that he was “incapable of knowing the nature of the act,” or
that he did not know what he was doing was wrong or against the law.

In case of Ashiruddin Ahmed vs The King[13]

The accused, Ashiruddin Ahmed sacrificed his five-year-old kid. He had a dream where god said that, “your sacrifice (korbani) was of no use; you will have to sacrifice your own son,”.

He took his kid to a mosque the next morning and sacrificed him by stabbing him in the throat with a knife. After this he proceeded directly to his uncle's house, but after spotting a gatekeeper nearby, he brought his uncle to a neighboring tank and confess him the story gently. A bench of the Calcutta High Court found that a case of insanity under Section 84 was made out based on these circumstances. In that instance, it was held that in order for the accused to profit from Section 84, he had to be able to prove one of the following three elements:

that he didn’t know the nature of the act charged
that he didn’t know that it was contrary to law
that he didn’t know that it was wrong

On the basis of the aforesaid circumstances, the bench determined that the accused had proven the third criterion, namely, that the accused was unaware that the act was illegal. This was plainly based on the fact that the accused was convinced that his dream was genuine.

It said that the “accused was clearly of unsound mind and that acting under delusion of his dream he made this sacrifice believing it to be right.”

If this formulation of three solely independent tests is recognized as true, major implications will result for the following reasons:

An accused will be able to claim in every case that he had a dream enjoining him to commit a certain criminal conduct, and that, thinking that his dream was a command from a supernatural force, he felt compelled to carry out the instruction, and that he would be protected by section 84. The court will have no way of knowing whether or not the defendant's assertion is true. As a result, the defence of insanity is likely to be abused.
The court's conclusion that "wrong" and "contrary to law" are two separate tests contradicts its prior judgement in Geron Ali v. Emperor[14], in which "wrong" and "contrary to law" formed just one test. Mr. Justice Roxburg, who served on the division bench in both Geron Ali and Ashiruddin Ahmad, should be ashamed for failing to notice or clarify these clearly contradicting opinions. The Calcutta High Court should have issued a more reasoned and detailed judgement, especially as it was a deviation from its previous decision on the issue.
According to section 84[15], the accused must be “incapable” of understanding whether the conduct “being done” by him is right or wrong.

Beg, J., questioned the Calcutta approach in an Allahabad case, saying:

“the capacity to know a thing is quite different from what a person knows. The former is a potentiality, the latter is the result of it. If a person possesses the former, he cannot be protected in law, whatever might be the result of his potentiality. In other words, what is protected is an inherent or organic incapacity, and not a wrong or erroneous belief which might be the result of a perverted potentiality.”[16]

If it is discovered that someone accused lacked the ability to discriminate between good and wrong, his beliefs are unlikely to protect him. If his abilities lead him to erroneous conclusions, he accepts the risk that the law will hold him accountable for his actions. What the law protects is the case of a man who has lost his guiding light, which allows him to discriminate between good and wrong, legality and illegality. When such a light is discovered to be still flickering, a man cannot claim that he was guided by his own intuition or by any imagined illusion that had been tormenting him and that he considered to be fact.

After this case, in India the test of M’Naghten has been acclaimed by the High Courts as a right rule for cases involving the plea of Insanity.

Judicial Acceptance of M’Naghten in India:

Section 84 of IPC in substance is similar s the M’Naghten rules. But there are some little distinction between them in respect of answer 2 and 3 of judge in M’Naghten.

The phrases "nature and quality" of the conduct are defined in the M'Naghten regulations, although "quality" is not defined in section 84. The word "contrary to law," which appears in section 84, does not appear in the M'Naghten regulations.
The M'Naghten laws employ the term "disease of mind," but Section 84 of the Indian Penal Code uses the term "unsoundness of mind." This appears to embrace not just insanity or mental illness, but also deficiencies such as idiocy, imbecility, and even feeble mindedness. It is clear that Section 84 of the Indian Penal Code was written in response to the M'Naghten case replies. However, the I.P.C. framers selected the phrase "unsoundness of mind" over "insanity" because "insanity" has a very narrow meaning, but "unsoundness of mind" is a more broad term.[17]

As a result, we find that Section 84 of the I.P.C. is essentially the same as the rules established by the House of Lords in the M'Naghten case. Many of the M'Naghten Rules' criteria, such as the accused person's mental capacity, the inability to discriminate between good and evil, and the right and wrong test, have been recognized by the I.P.C. in considering cases under section 84. The above-mentioned examples abundantly illustrate that M'Naghten regulations form the foundation of section 84 of the I.P.C., which has comparable provisions to M'Naghten with slight differences.

In case of Dayabhai Chhaganbhai Thakker v. State of Gujrat[18]

The plaintiff, Dayabhai Chhaganbhai Thakkar, was the son of Chhaganbhai and the spouse of the dead Kalavati. In the year 1958, she married the appellant. However, the relation between the husband and wife was strained owing to their mutual conflicts.

The appellant and his wife were sleeping in their bedroom on the night of April 9, 1959, and the doors of that room were shut from the inside. Kalavati suddenly screamed that she was being slaughtered at 3 or 4 a.m.

When the neighbours heard this, they gathered in front of the accused's room and forced the accused to open the door. When the door was unlocked, they discovered Kalavati dead and with several injuries on her body. The accused was escorted to the session for a hearing on the accusation of murder. Before Additional Sessions Judge, it was presented that the accused was insane at the time of the claimed event.

Issues framed by the court:

The accused killed his wife in the dreadful way by stabbing 44 times. What was the motive behind this act of overkill?
Is previous history of mental condition of accused is relevant?

For the first question, court consider the marital condition between the husband and wife. Accused in his letter to her father, tells that he didn’t like her as she is not working properly.

And for the second question,

2-3 days prior to incident, the accused's father said that his son had been mad for two or three days before to the occurrence. Court wholly depend on the facts and circumstances of the case that, if accused was insane is it likely that wife would have slept with him in the same room. And his father didn’t tell about the medicine and which doctor they consulted.

On the day of incident, after stabbing when all went to the room, he started talking irrelevant and started throwing dust and mud at the person gathered. And after this he was confined in room. Where he talked normally with a person who met him.

Court rely on the medical certificate issued by the Medical Officer that the accused was capable of understanding the proceeding. court then held that he was sane at the time of committing the act.

42nd Law Commission Report:

Three question were raised in this report after reviewing insanity law in India.

Should the section 84 relating to insanity defence be modified or expanded in other way?

The majority of responses to this question were vehemently opposed to any changes to the current Section 84 of the I.P.C.. The majority of these responses seemed to presume that the current provision is acceptable even in theory. They cited a number of practical issues that would likely occur if the section 84 rules were made more liberal or flexible. The choice would therefore have to rely on medical advice to a larger extent than it already does. There were serious worries about whether medical professionals of the required calibre would be accessible throughout India, particularly in the districts. There were also opinions that the current provision posed no practical difficulties, and that if the mental state of the accused warranted special consideration in a case not falling strictly within the terms of Section 84, it could be left to the president's and governor's prerogative powers of commutation and remission vested in them under Article 72 and 161 of the Indian Constitution.

Should the test be based on the offender's inability to recognize that his actions are wrong or on his ability to recognize that they are punishable?

In response to this question , the vast majority of responses indicated that nothing should be changed. Some people believe the exam should be based on knowing what is bad, while others believe it should be based on knowing what is punished by law.

Should the defence of insanity be viable in circumstances when the offender is aware of the wrongdoing, if not criminal nature of his behaviour, but is unable to stop due of his mental condition?

In the case of this issue , there was minimal support for expressly introducing the phrase "irresistible impulse" in section 84 of the I.P.C. Some people were of the notion that this wasn't strictly insane. The major criticism was that the clause would make the issue trial more difficult for judges than it is already.[19]

CHAPTER 4: DEFENCE OF INSANITY IN ENGLAND

Judicial acceptance of M’Naghten in England

This landmark case resolved the controversy between the requirement of insanity at the time of commission of crime. M’Naghten rule acts as a binding authority in criminal trials. This rule is fully accepted by the Criminal Justice system of England. For the plea of defence the accused has to prove that:

He is suffering from a disease of mind at the time of commission of crime. Here, defence is not talking about the disease of brain, it is concerned with disease of mind.
Accused must prove that due to disease of mind he was suffering from defect of reason. In other terms, he must prove that due to his disease of mind he is not able to appreciate that what he was doing and whether it is legal or not.

Current Law

The two test for the defence of insanity is:

Defendant was insane at the time of commission of an offence
Defendant was insane at the time of trial and not able to stand fit for trial.

Insane at the time of commission of Crime:

In order to invoke the defence of insanity, accused must prove that he was insane at the time of commission of crime which was mentioned in M’Naghten Rule.

Insane at the time of trial

In case Regina v. John M[20], the appellant was charged with offence of sexual nature with his 8-10 year grandchild. The defence raised the question of the appellant's competence to plead. The appellant had a substantial impairment of his short term memory due to long-term effects of excessive alcohol, but he was generally capable of understanding the allegations against him, according to medical testimony. After a jury determined that he was competent to plead, his case went to trial, and he was convicted guilty of the counts. He challenged the jury's finding of competence to plead, claiming that the trial judge had set the fitness level too low.

It was decided in this case that appellant is not unfit to plead insanity if any of the following thing was proved:

He understands the charges against him;
When he is able to decide whether to plead guilty or not;
When is able to exercise his right to challenge jurors;
When is able to instruct solicitors and counsel;
When he able to follow the course of the proceedings;
When he gives evidence in his own defence.

In this case, the appeal was dismissed.

CHAPTER 5: CONCLUSION AND SUGGESTION

The M’Naghten case established the principles that govern insanity in India. The M’Naghten rules, on the other hand, have grown outmoded and are no longer appropriate or appropriate in the present period. It is necessary to conduct a thorough examination of this statute and to make attempts to amend it. Many instances have been ruled on identical concerns in other nations, and appeals of overpowering impulse have been considered. The doctrine of diminished responsibility has recently been a hot topic in decision-making. We should compare these examples to the various rules of other nations pertaining to insanity and unsoundness of mind as a defence in criminal trials, and we should add newer provisions such as decreased responsibility for a free and fair trial in India's criminal justice system.

Suggestion

In India, the plea of diminished responsibility should be introduced. According to which, if accused is suffering from some mental impairment, and not legally or medically insane, even in this situation, he will be protected under diminished responsibility plea and made be liable for culpable homicide not amounting to murder rather than murder.
The scope of Section 84 of I.P.C. and M’Naghten Rule should be broaden in order to consider the ‘medical insanity’ as a defence.
There is need of trained staff which is expert in psychiatry, psychology and penology. They should be impartial in order to prevent miscarriage of justice.
After the acquittal on the ground of insanity accused is sent to the mental hospital. It is suggested that, the hospital authorities should give human treatment to accused. Government should financially aid to make the hospital better place for accused.

BIBLIOGRAPHY

Books

Dr. Vibhute K I, Criminal Law (12th edn. Lexis Nexis 2015)

Dictionary

Black’s Law Dictionary (revised 4th edn. 1968)

Websites and Blogs

Dahiya and Seema, ‘Insanity as a Defence under Indian Penal Code Different Dimensions’ (Shodhganga@INFLIBNET, 31st March1970) <: http://hdl.handle.net/10603/132449> accessed 26th November 2021
Singh A, ‘The Dodge or Defence of Insanity’, (probono-india, 25th September 2020) accessed 26th November 2021

Online Journal

Vageshwari Deswal, ‘Insanity as a defence to criminal charge- An analysis’ (2019) II Delhi Journal of Contemporary Law accessed 26th November 2021
Yeo S, ‘The Insanity defence in the criminal laws of the commonwealth nations’ (2008) 241-216, Singapore Journal of Legal Studies <http://www.jstor.org/stable/24870263> accessed 26th November 2021

Law Commission Reports

Law Commission of India, Indian Penal Code (Law Com No 42, 1971)

[1] Indian Penal Code, 1860 (45 of 1860) s84.

[2] Black’s Law Dictionary (revised 4th edn. 1968).

[3] Dr. K I Vibhute, Criminal Law (12th edn. Lexis Nexis 2015).

[4] Vageshwari Deswal, ‘Insanity as a defence to criminal charge- An analysis’ (2019) II Delhi Journal of Contemporary Law < http://lc2.du.ac.in/DJCL2/6.%20Dr.%20Vageshwari.pdf > accessed 24th January 2023.

[5] Dahiya and Seema, ‘Insanity as a Defence under Indian Penal Code Different Dimensions’ (Shodhganga@INFLIBNET, 31st March1970) < : http://hdl.handle.net/10603/132449> accessed 24th January 2023.

[6] Stanley Yeo, ‘The Insanity defence in the criminal laws of the commonwealth nations’ (2008) 241-216, Singapore Journal of Legal Studies <http://www.jstor.org/stable/24870263> accessed 24th January 2023.

[7] Anoushka Singh, ‘The Dodge or Defence of Insanity’, (probono-india, 25th September 2020) accessed 24th January 2023.

[8] (1724) 16 St. Tr. 695

[9] Hadfield Case. 1800, 27 St.Tr.128

[10] (1843) 8 Eng Rep 718.

[11] Durham v. U.S 214 F 2d 862, 869 et req. (D.C. cir. 1954).

[12] Indian Penal Code, 1860 (45 of 1860) s84.

[13] AIR 1949 Cal. 182

[14] AIR 1941 Cal. 129

[15] Indian Penal Code, 1860 (45 of 1860) s84.

[16] Laksmi v. State, AIR 1959 All. 534

[17] Dahiya and Seema, ‘Insanity as a Defence under Indian Penal Code Different Dimensions’ (Shodhganga@INFLIBNET, 31st March1970) < : http://hdl.handle.net/10603/132449> accessed 24th January 2023.

[18] AIR 1964 SCR (7) 361

[19] Law Commission of India, Indian Penal Code (Law Com No 42, 1971) 4.30.

[20] [2003] EWCA Crim 3452 Court of Appeal

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INTERPRETATION OF LEGAL INSANITY IN CRIMINAL LAW: A CRITICAL ANALYSIS BY : SAURAV BHOLA

INTERPRETATION OF LEGAL INSANITY IN CRIMINAL LAW: A CRITICAL ANALYSIS BY : SAURAV BHOLA

CHAPTER 1: INTRODUCTION

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