S.84 IPC | Accused Must Prove “Legal Insanity”, Not Medical Insanity: Madhya Pradesh High Court

[21 July 2022] The Madhya Pradesh High Court, Gwalior Bench, recently elucidated the difference between the term ‘Legal Insanity’ and ‘Medical Insanity’ in the context of Section 84 of IPC.The Court opined that in order to bring a case within the ambit of Section 84 IPC, the accused has to prove that they were suffering from Legal Insanity.

The bench comprising of Justice G.S. Ahluwalia and Justice R.K. Shrivastava observed-

Even insanity is not exempted under Section 84 of IPC. Every person who is mentally ill is not ipso facto exempted from criminal responsibility. There is a distinction between legal insanity and medical insanity. In order to take benefit of Section 84 of IPC, the accused must prove legal insanity, and not medical insanity. Any person, who is suffering from any kind of mental weakness is called “medical insanity,” however “legal insanity” means, person suffering from mental illness should also have a loss of reasoning power. Furthermore, the legal insanity must be at the time of incident. In other words, it can be said that in order to attract legal insanity, a person should be incapable of knowing the nature of the act, or he is doing what is either wrong or either contrary to law. Thus, mere abnormality of mind or compulsive behavior is not sufficient to take benefit of Section 84 of IPC.