In Brief
A trial court acquitted Uttam Nandram Somwanshi of murder, finding he was entitled to the benefit of Section 84 IPC (defence of unsoundness of mind due to schizophrenia). The High Court reversed the acquittal, finding insufficient evidence that he was mentally unsound at the time of the offence. The Supreme Court upheld the High Court, holding that while the accused had prior psychiatric treatment for schizophrenia (1992–1997), there was no concrete evidence demonstrating mental illness at the time of the alleged crime. The accused's planful conduct, normal appearance when first produced before the Magistrate, and post-incident actions (performing pooja, preparing tea) contradicted the defence claim. The one-year gap between the offence and any documented relapse further weakened the defence. The Court affirmed that to succeed, a Section 84 defence must prove unsoundness specifically at the time of the act, not merely the potential for relapse.
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