In a significant ruling addressing the intersection of mental health and criminal law, the Supreme Court of India on Tuesday ordered the release of a woman convicted of killing her two young daughters under what she believed was the influence of an “invisible power.”
A Bench comprising Justices BV Nagarathna and N Kotiswar Singh modified the woman’s conviction from murder under Section 302 of the Indian Penal Code (IPC) to culpable homicide not amounting to murder under Section 304 Part II IPC. The Court observed that the woman, who committed the act in 2015, had already served more than nine years and ten months in custody and ordered her immediate release.
The tragic incident took place in Bharadkala village, Chhattisgarh, where the woman fatally assaulted her daughters, aged three and five, with an iron crowbar. Her sister-in-law witnessed the incident and testified in court.
While acknowledging that the act itself was proven, the Court found the intention behind it unclear, especially considering the rural setting, the woman’s limited education, and her belief in supernatural influences. The judgment emphasized that many mental disorders in rural India remain undiagnosed due to lack of awareness, often leading to misinterpretation of symptoms as supernatural possession or influence.
“In such circumstances, a temporary lapse in judgment bordering on insanity cannot be entirely ruled out,” the Court noted, stressing the need for trial courts to rigorously investigate claims of psychological disturbance or bizarre behavior under Section 165 of the Indian Evidence Act.
The Bench pointed to the woman’s previously affectionate relationship with her children and lack of any financial or domestic conflict as further grounds for reconsidering intent. It concluded that the prosecution failed to prove the required mens rea beyond reasonable doubt.
The petitioner was represented by Advocate S. Mahendran. The State was represented by Advocates Prerna Dhall, Akansha Singh, Shivam Ganeshia, Ambuj Swaroop, and Prashant Singh.
