CHUNNI BAI versus STATE OF CHHATTISGARH

Citation: [2025] 4 S.C.R. 1816 · Decided: 28-04-2025 · Supreme Court of India · Bench: B.V. NAGARATHNA · Disposal: Case Partly allowed

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Judgment (excerpt)

[2025] 4 S.C.R. 1816 : 2025 INSC 577
Chunni Bai 
v. 
State of Chhattisgarh
(Criminal Appeal No. 2265 of 2025)
28 April 2025
[B.V. Nagarathna and  
Nongmeikapam Kotiswar Singh,* JJ.]
Issue for Consideration
Whether the accused at the time of commission of crime was 
incapable of making conscious and informed decision or was 
suffering from certain mental incapacity or unsoundness of mind; 
Whether a benefit of doubt may be extended to the accused as 
regards proof of intention and mens rea.
Headnotes†
Penal Code, 1860 – ss.84, 299, 300, 302, 304 Part II – Code of 
Criminal Procedure, 1973 – ss.161, 313 – Evidence Act, 1872 – 
ss.105, 165 – Appellant killed her minor daughters – Appellant 
denied her guilt in a statement recorded u/s.313 of CrPC and 
claimed that she had no knowledge of what had happened 
and how it happened and that she was under the influence 
of some invisible power – Trial Court convicted appellant for 
offence punishable u/s.302 of IPC – The High Court upheld 
the conviction of the appellant u/s.302 of the IPC – Appellant’s 
plea that the appellant was not in a proper mental condition 
at the time of commission of the offence:
Held: No infirmity in the finding given by the Trial Court as well 
as the High Court that the appellant had assaulted both of her 
daughters, which caused grievous injuries, thereby causing their 
death – In the peculiar facts and circumstances as revealed in the 
present case, and also keeping in mind that the incident happened 
in a rural setting and the appellant not being highly educated, the 
possibility of confusing her unstable mental condition or temporary 
lapse of judgmental power bordering on temporary insanity cannot 
be completely ruled out which the appellant attributed as coming 
under the influence of invisible power, for the purpose of giving a 
* Author
[2025] 4 S.C.R. 
1817
Chunni Bai v. State of Chhattisgarh
benefit of doubt about the non-existence of “intention” – Appellant 
had a cordial relationship with all the family members including 
her children, which clearly indicates absence of any ill feelings 
on the part of the appellant to provide any basis for any motive 
to commit the crime which will prove the presence of “intention” 
to commit the act – The statement of the father-in-law (PW-5) 
of the appellant recorded that 15 days prior to the incident, the 
appellant was babbling nonsense, saying that she is Mata, Budi 
Dai etc. – Further, it was also mentioned that the appellant was 
taken to the Psychiatrist at Government Hospital, Durg where 
she was given medicine and was advised to follow up – Under 
the circumstances, in view of the plea taken by the appellant, a 
reasonable doubt can be said to have arisen as regards existence 
of intention, thus of mens rea for causing death in the present 
case as – (i) During the commission of crime, the appellant was 
shouting that she is killing her children; (ii) Post the incident, 
the appellant, on being asked the reason behind her act, kept 
on crying and repeating that she has killed her children – This 
is corroborated by other prosecution witnesses as well; (iii) The 
appellant did not try to flee the scene of crime even after being 
left alone in the house by PW-1; (iv) Complete absence of motive 
behind the commission of crime in background of the fact that the 
appellant loved her children very much, as also acknowledged 
by the prosecution witness; (v) The nature of relation between 
the accused and the deceased i.e., of a mother and child; (vi) 
Absence of any strained domestic relationships or any such 
motivating factor – However, in the absence of any conclusive 
medical evidence with regards to the mental condition of the 
appellant, it may not be enough to extend the benefit of exception 
as encapsulated in s.84 IPC so as to acquit the appellant in the 
present case – Nevertheless, the circumstances are enough to 
cast a shadow of doubt about the existence of the intention of the 
appellant to commit the crime in the present case – Thus, in the 
present case “intention of causing death” cannot be said to have 
proved – Therefore, the conviction of the appellant converted to 
under Part II of s.304 IPC is from that of s.302 IPC. [Paras 16, 
36, 43, 53, 57, 58, 60]
Penal Code, 1860 – Murder and Culpable homicide not 
amounting to murder – Difference between – Discussed. 
[Paras 18-21]
1818
[2025] 4 S.C.R.
Supreme Court Reports
Evidence Act, 1872 – s.105 – Burden of Proof to prove existe

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