In a significant ruling delivered on May 29, 2025, the Allahabad High Court overturned the conviction of a man who had been serving a life sentence for the murder of his wife and son. The court, after a thorough examination of the evidence, concluded that the accused was suffering from impaired mental health at the time of the crime, thus invoking the general exception under Section 84 of the Indian Penal Code (IPC). This decision brings to a close a legal battle that spanned over two decades, highlighting the complexities of cases involving mental illness and the law.
The case originated from an incident that occurred on the night of August 31 and September 1, 2002, in the Fakharpur Police Station area of Bahraich district. According to the First Information Report (FIR) filed by the accused's father, Prahlad Kumar Tewari, Rajesh @ Sajesh Tewari, had been suffering from mental illness for more than a year. It was alleged that Rajesh, using a sharp-edged weapon, murdered his wife and son, Durgesh, in the early hours of the morning. Initially, the FIR was registered under Section 304 IPC (culpable homicide not amounting to murder), but later, charges were framed under Section 302 IPC (murder).
In 2005, the Additional Sessions Judge/Fast Track Court No. 1, Bahraich, found Rajesh guilty under Section 302 IPC and sentenced him to life imprisonment, along with a fine of ₹20,000. Failure to pay the fine would result in an additional two years of simple imprisonment. This conviction led Rajesh to file an appeal in the Allahabad High Court, challenging the lower court's judgment.
The defense presented before the High Court centered on Rajesh's long history of neurological and psychiatric treatment. Medical prescriptions dating back to February 2002 from Jamuna Neuro Psychiatric Centre were submitted as evidence. The defense argued that Rajesh lacked the necessary mens rea (guilty mind) at the time of the incident due to his unsound mind and was therefore entitled to protection under Section 84 IPC, which exempts individuals of unsound mind from criminal liability.
The Division Bench of Justice Sangeeta Chandra and Justice Shree Prakash Singh, after reviewing the evidence and arguments, concluded that Rajesh's impaired mental condition was evident. The court noted that the prosecution witnesses' statements, along with the medical records, sufficiently established that Rajesh was suffering from a mental impairment at the time of the crime. Consequently, the High Court allowed the appeal, setting aside the conviction and acquitting Rajesh of all charges. The court stated, "The overall examination of the evidences including the statements of the prosecution witnesses, is enough to establish that the appellant was suffering with certain impaired mental condition and thus, the instant matter obviously, falls in a category of general exception.”
This verdict underscores the importance of considering mental health in legal proceedings. Section 84 IPC provides a crucial safeguard for individuals whose actions are driven by mental illness, recognizing that they should not be held criminally responsible for acts committed without a sound mind. The Allahabad High Court's decision emphasizes the need for a careful and comprehensive evaluation of evidence related to an accused's mental state, ensuring that justice is served while also protecting the rights of those with mental health conditions. The case serves as a reminder that mental illness can significantly impact a person's actions and culpability, and the legal system must account for these factors.
