| Citation | AIR 1961 SCR (3) 583 |
| Date of Judgment | 25/01/1961 |
| Court | Supreme Court |
| Appellant | State of Madhya Pradesh |
| Respondent | Ahmamadullah |
| Bench | Justice N. Rajgopalal Ayyangar and Justice A.K.Sarkar. |
| Advocate | I.N.Shroff |
| Case No. | Criminal Appeal No. 120 of 1960 |
FACT OF CASE
The case of State of Madhya Pradesh v/s Ahmadullah was decided on January 25, 1961, by the Supreme Court of India.
- The deceased, Bismilla, was related to the accused-respondent, Ahmadullah, as the mother of his wife, Jinnat, whom he had divorced.
- Ahmadullah nurtured a grievance against his mother-in-law for matters not specified.
- Bismilla went to bed in her own house on the night of September 28, 1954.
The body of Bismilla was discovered by her husband the following morning on the cot where she was sleeping, lying in a pool of blood with the head missing.
• The deceased’s son promptly filed a First Information Report.
The respondent had harbored animosity for Bismilla, according to information given to the police.
The case was significant as it dealt with the application of Section 84 of the Indian Penal Code, which pertains to the act of a person of unsound mind. The accused was acquitted by the Sessions Judge and the High Court on the grounds of unsoundness of mind at the time of the crime. However, the Supreme Court allowed the appeal by the State of Madhya Pradesh, setting aside the order of acquittal and substituting a finding of guilt for murder under Section 302 of the Indian Penal Code.
ISSUE
The main issue in the case of State of Madhya Pradesh v/s Ahmadullah was the application of Section 84 of the Indian Penal Code, which pertains to the act of a person of unsound mind.. The accused, Ahmadullah, was acquitted by the Sessions Judge and the High Court on the grounds of unsoundness of mind at the time of the crime.
However, the Supreme Court allowed the appeal by the State of Madhya Pradesh, setting aside the order of acquittal and substituting a finding of guilt for murder under Section 302 of the Indian Penal Code.
When the conduct was performed is the critical moment to establish the unsoundness of mind as described in that clause. It is the application of this principle to the facts established by the evidence that was the ground of complaint by the appellant-State before the Supreme Court.
ARGUMENT
The arguments in the case of State of Madhya Pradesh v/s Ahmadullah revolved around the application of Section 84 of the Indian Penal Code, which pertains to the act of a person of unsound mind.
Arguments by the State of Madhya Pradesh (Appellant): The State of Madhya Pradesh appealed against the acquittal of Ahmadullah by the Sessions Judge and the High Court.
The State argued that the crucial point of time at which the unsoundness of mind, as defined in Section 84 of the Indian Penal Code, has to be established is when the act was committed. It was the application of this principle to the facts established by the evidence that was the ground of complaint by the appellant-State before the Supreme Court..
Arguments by Ahmadullah (Respondent): Ahmadullah, the respondent, invoked Section 84 of the Indian Penal Code, claiming that he was of unsound mind at the time of the commission of the crime. He argued that he was entitled to an acquittal under this section.
The onus of proving that the accused’s mental state at the essential moment was as specified in this section is on the accused. who claims the benefit of this exemption anyone seeks to utilize this exemption.
The Supreme Court allowed the appeal by the State of Madhya Pradesh, setting aside the order of acquittal and substituting a finding of guilt for murder under Section 302 of the Indian Penal Code.
JUDGEMENT
The judgement in the case of State of Madhya Pradesh v/s Ahmadullah was delivered by the Supreme Court of India on January 25, 1961.The Supreme Court allowed the appeal by the State of Madhya Pradesh, setting aside the order of acquittal passed by the Sessions Judge and the High Court.
The court substituted a finding of guilt for murder under Section 302 of the Indian Penal Code. However, considering that Ahmadullah had already been acquitted by the Sessions Judge and the High Court, the sentence of rigorous imprisonment for life was deemed appropriate. The State Government was directed to ensure that Ahmadullah receives treatment in an asylum until his illness is cured, if it still continues.
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