Bapu @ Gajraj Singh v. State of Rajasthan — Circumstantial evidence and insanity defence (s.84 IPC)

Part of the Forensic Docket on Legal Desire Forensics — a conviction confirmed through final appeal, kept here as a method-of-crime record.

The facts

The accused was found in a room bolted from inside, carrying a blood-stained sickle in one hand and his wife’s severed head in the other.

He was convicted under Section 302 of the Penal Code by the trial court.

He raised a defence of unsoundness of mind under Section 84 of the Penal Code, which the courts rejected, holding that the facts of the case did not attract that protection.

The Supreme Court explained the underlying principles and the test of responsibility applicable in cases of unsoundness of mind, invoking the maxim actus non facit reum nisi mens sit rea, and addressed the burden on an accused under Section 105 of the Evidence Act, 1872 to prove such a defence.

The conviction was upheld.

Status: conviction upheld through final appeal.

Why this belongs in the Forensic Docket: The physical scene here — a bolted room, a blood-stained weapon still in hand — left little room to dispute what happened; the real forensic contest was psychiatric, over whether the accused’s mind, not his hand, could be held responsible.

Case details

Read the full judgment (PDF), sourced from the Indian Supreme Court Judgments open dataset (AWS Open Data Registry, CC-BY-4.0).

Explore more in the Forensic Docket or browse the full Forensics hub.