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Supreme Court of India 2023-09-13 allowed

RUPESH MANGER (THAPA) vs STATE OF SIKKIM

Bench: 2 — J.B. Pardiwala, Prashant Kumar Mishra

In Brief

Rupesh Manger (Thapa) was accused of murdering his 81-year-old grandfather with a sharp-edged weapon. The Trial Court acquitted him under Section 84 IPC (act of a person of unsound mind), finding he was incapable of knowing the nature of his act due to unsoundness of mind. The High Court reversed this, convicting him to life imprisonment. The Supreme Court restored the acquittal, holding that the standard for proving insanity is 'reasonable doubt', not beyond reasonable doubt. The medical evidence of prior psychiatric treatment, abnormal post-incident behaviour, and lack of awareness of his actions raised a reasonable doubt about his sanity. The appellate court erred in reversing the plausible acquittal merely by reappreciating evidence.

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Criminal Law Insanity Defence Mental Illness Murder Criminal Procedure Appellate Review Burden of Proof

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