The Uttarakhand High Court set aside the convictions and death sentence of a man from a Tehri Garhwal village on three counts of murder, determining that the proceedings were undermined by a failure to apply statutory safeguards that the law expressly requires when the person facing trial has a mental illness.
Sitting together as a two-judge panel, Justices Ravindra Maithani and Siddhartha Sah upheld the convict's criminal appeal and turned down the death penalty confirmation, with the bench pointing to what it described as a wholesale failure to follow CrPC 329.
According to a statement made by the convicted man's father, three family members — his son's brother, mother, and sister-in-law — were killed with a sword in 2014, though this account represents the father's version of events. Charges brought under IPC sections 302, 316, and 201 were subsequently laid against him at trial. A guilty verdict on the murder count carried a death penalty, while the remaining two charges drew separate custodial terms and financial penalties.
Proceedings before the High Court brought to light that doubts about his mental state had been present at an earlier point in time. In the ruling's account of events, a medical examination conducted on 14 December 2014 — just days after the incident — cleared him physically, yet the attending doctor flagged the possibility of a mental health condition and directed him toward psychological assessment. Documentation from that period identified two psychiatric diagnoses — psychosis not otherwise specified, along with schizophrenia — within the entries of his medical file.
An appellate ruling held that the lower court was obliged to assess the defendant's fitness to mount a defence before proceeding further. Testimony gathered by the prosecution was collected across intervals when questions about his mental fitness had not yet been resolved.
Post-remand proceedings came under review by the High Court as well. A prior High Court ruling had already quashed the original conviction on grounds that mental health procedures were not properly observed, yet proceedings moved forward a second time even as medical documentation pointed to a diagnosis of schizophrenia and the accused was unable to respond to questions put under CrPC 313.
Under Section 84 of the Indian Penal Code — the provision covering acts committed by a person whose mental faculties were too impaired to form a culpable intent — the accused qualified for the insanity defence, with the court finding that his unsoundness of mind had rendered him unable, at the relevant moment, to appreciate either the character or the wrongfulness of what he did.
A judicial order placed him under the care of the State Mental Health Institute in Selaqui, Dehradun, where he is to remain until medical staff determine his treatment complete.
