Devidas Loka Rathod Acquitted: Supreme Court Recognizes Insanity Defense in Murder Conviction

The Supreme Court of India, in a landmark judgment, acquitted Devidas Loka Rathod of charges under Section 302 (murder) and Section 324 (voluntarily causing hurt) of the Indian Penal Code (IPC), recognizing his defense of unsoundness of mind. This judgment overturns the decisions of the Additional Sessions Judge, Akola, and the Bombay High Court, which had rejected his plea of insanity. The case provides an in-depth legal analysis of the plea of insanity under Section 84 IPC and highlights procedural lapses in the prosecution’s approach.

Case Background

The case dates back to September 26, 2006, when the appellant, Devidas Loka Rathod, picked up a sickle and attacked multiple individuals, including Ulhas Rathor, Santosh Jadhav, and the deceased, Harish Chandra Chauhan. After committing the assaults, Rathod attempted to flee but was apprehended by villagers and handed over to the police. The prosecution contended that the appellant was fully conscious of his actions and committed the offenses deliberately.

Trial Court’s and High Court’s Findings

The Additional Sessions Judge, Akola, rejected the appellant’s defense of unsoundness of mind, citing insufficient evidence. The court relied on Dr. Sagar Srikant Chiddalwar’s testimony that the appellant was mentally fit to stand trial. The judge also noted that the appellant’s conduct, including fleeing after the crime and disposing of the weapon, demonstrated that he was aware of his actions.

The Bombay High Court upheld this verdict, refusing to interfere with the conviction.

Defense Arguments

Ms. Aparna Jha, representing the appellant, argued that the prosecution failed to establish the necessary mens rea (criminal intent) for a conviction under Section 302 IPC. She relied on precedents such as Dahyabhai Chhaganbhai Thakker vs. State of Gujarat (1964) and Elavarasan vs. State (2011) to emphasize that the burden of proving sanity rested on the prosecution.

The defense highlighted testimonies from Mankarna Chavan (DW1) and Gograbai Rathod (DW2), which suggested the appellant had a history of mental illness. They contended that the appellant’s poverty prevented his family from maintaining medical records to substantiate his treatment history.

Prosecution’s Stand

The prosecution, led by Shri Katneshwarkar, countered that the appellant failed to establish his insanity on a preponderance of probability. It argued that the appellant’s actions—repeated assaults, attempting to flee, and discarding the weapon—were inconsistent with insanity.

Supreme Court’s Observations

The Supreme Court noted that it usually does not interfere with concurrent findings of lower courts under Article 136 of the Constitution but made an exception in this case due to the significant lapses in evidence appreciation.

The Court reviewed police and medical records, particularly the testimony of Sub-Inspector Chandusingh Mohansingh Chavan (PW14), who confirmed that Rathod had a prior history of mental illness. The Court found that the prosecution had withheld crucial medical evidence and had failed to subject the accused to a psychiatric evaluation immediately after his arrest.

The Supreme Court referred to its earlier rulings in Bapu vs. State of Rajasthan (2007) and Surendra Mishra vs. State of Jharkhand (2011) to emphasize that when doubts exist regarding an accused’s mental condition, the benefit must be given to the accused.

Application of Section 84 IPC

Section 84 IPC provides that a person who commits an offense while being of unsound mind, incapable of understanding the nature of the act or distinguishing between right and wrong, is exempt from criminal liability.

The Supreme Court reaffirmed the principles laid out in Dahyabhai Chhaganbhai Thakker (1964), stating:

“There is a rebuttable presumption that the accused was not insane when he committed the crime. However, if the accused provides evidence that raises a reasonable doubt about his sanity, the benefit of the doubt must go to the accused.”

Key Medical Evidence

The Supreme Court meticulously analyzed Rathod’s medical records, which showed:

• Repeated psychiatric evaluations in prison.
• Prescription of antipsychotic medications like Haloperidol, Olanzapine, and Diazepam, indicating treatment for schizophrenia or severe psychotic disorders.
• Statements from his family that he needed to be restrained at times.

Final Judgment

The Supreme Court found that the prosecution had failed to discharge its burden of proving the appellant’s sanity. The trial court and the High Court had overlooked crucial medical evidence, and the trial judge erred by basing the appellant’s mental state solely on his demeanor during trial, ignoring past medical treatment.

The Court ruled:

“The appellant has been able to create sufficient doubt in our mind that he is entitled to the benefit of the exception under Section 84 IPC. The prosecution has not established its case beyond all reasonable doubt.”

Accordingly, the Supreme Court acquitted Devidas Loka Rathod and ordered his release, subject to any other pending cases against him.

Conclusion

This judgment is a critical affirmation of the insanity defense in India’s criminal justice system. It highlights the responsibility of investigating agencies and courts to ensure that mental health conditions are adequately examined before convicting an accused. The ruling reinforces that procedural lapses and the withholding of crucial evidence can lead to the miscarriage of justice.

Petitioner Name: Devidas Loka Rathod.
Respondent Name: State of Maharashtra.
Judgment By: Justice A.M. Khanwilkar, Justice Navin Sinha.
Place Of Incident: Akola, Maharashtra.
Judgment Date: 02-07-2018.

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