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Supreme Court of India 2025-04-28 partly_allowed

CHUNNI BAI vs STATE OF CHHATTISGARH

Bench: 2 — B.V. Nagarathna, Nongmeikapam Kotiswar Singh

In Brief

A mother was convicted of murdering her two young daughters in rural Chhattisgarh with an iron crowbar. She claimed to be under an 'invisible influence' but provided no medical evidence of insanity. The Supreme Court found that while her claim of legal insanity (Section 84 IPC) could not be fully established, several factors raised serious doubt about her intention to kill: complete absence of motive, her loving relationship with her children, immediate remorse, failure to flee, and bizarre unexplained behaviour. The Court downgraded the conviction from murder (Section 302) to culpable homicide without intention to cause death (Section 304 Part II IPC) and ordered her release after 9 years 10 months in custody. The judgment emphasized that courts must actively probe mental stability in homicide cases using their powers under the Evidence Act.

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Criminal Law Murder and Culpable Homicide Mens Rea and Criminal Intent Insanity Defence Section 84 IPC Evidence Law Mental Health in Criminal Justice Infanticide Burden of Proof General Exceptions in IPC

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