Chunni Bai v. State of Chhattisgarh

Criminal Appeal · 2025 INSC 577Decided 28 Apr 2025
Crl.A. No.-002265-002265 - 2025 (@ SLP (Crl.) No. 13119 of 2024)
Justice B.V. Nagarathna · Justice Nongmeikapam Kotiswar Singh

Background

In 2015, the appellant, Chunni Bai, was alleged to have struck her two young daughters (aged 5 and 3) with an iron crowbar, causing their deaths. Her sister-in-law witnessed the attack, and the appellant was seen crying and repeatedly saying she had killed her children. Both the Trial Court and the High Court of Chhattisgarh convicted her of murder under Section 302 IPC and sentenced her to life imprisonment, rejecting her plea that she was under the influence of "some invisible power" at the time.

Decision Breakdown

The Supreme Court found the act of killing proved beyond doubt but held that the courts below had failed to seriously examine whether the appellant possessed the requisite "intention" to commit murder, given the complete absence of any motive, her otherwise loving relationship with her children and husband, her failure to flee, and evidence that she may have suffered a temporary mental disturbance. Applying the principles distinguishing murder from culpable homicide not amounting to murder, the Court held that a reasonable doubt existed as to intention, and converted her conviction from Section 302 IPC (murder) to Part II of Section 304 IPC (culpable homicide not amounting to murder, without intention to cause death). Since she had already served over nine years and ten months in custody, more than the maximum sentence under Part II of Section 304, she was ordered released immediately.

Lesson Learnt

Courts must carefully examine the presence or absence of criminal intention, not just the act itself, especially where a claimed mental disturbance and a complete absence of motive raise reasonable doubt; a homicide can be downgraded from murder to a lesser offence when intention is not proved beyond reasonable doubt, even where the underlying facts of the killing itself are undisputed.

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