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Rupesh Manger (Thapa) vs. The State of Sikkim

Criminal Appeal · 2023 INSC 826Decided 13 Sept 2023
Criminal Appeal Nos. 2069-2070 of 2022
J.B. Pardiwala · Prashant Kumar Mishra · A.S. Bopanna instead of Justice Pardiwala

Background

The appellant was accused of murdering his 81-year-old grandfather with a sharp weapon at their home in Sikkim. The Trial Court acquitted him after accepting his defence of insanity under Section 84 IPC, based on medical evidence that he had a documented history of a major depressive disorder with psychotic features and had been hospitalized for psychiatric treatment. The State of Sikkim appealed, and the High Court reversed the acquittal and convicted him of murder, sentencing him to life imprisonment. The accused then appealed to the Supreme Court.

Decision Breakdown

The Supreme Court held that an appellate court can overturn an acquittal only if the trial court's view was "perverse" or impossible on the evidence, not merely because a different view is also possible. The Court found that the High Court had reversed the acquittal purely by re-appreciating the evidence, without ever recording a finding that the Trial Court's conclusion was perverse. Reviewing the medical records and the accused's bizarre conduct at the scene (including trying to comfort the victim's body and not fleeing), the Court held the Trial Court's view that he was legally insane at the time was a reasonably possible one. It restored the Trial Court's acquittal and ordered the appellant released.

Lesson Learnt

An appellate court cannot convict a person merely by taking a different view of the same evidence; it must show the trial court's acquittal was perverse or wholly unreasonable. Genuine mental illness that removes the capacity to understand the nature of one's actions is a complete defence to a criminal charge, provided it meets the "legal insanity" standard, not merely a medical diagnosis.

Official source (sci.gov.in)View Judgment (PDF)

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