In the case of Gitanjali Pradhan v. State of Odisha, the appellant, Gitanjali Pradhan, was convicted under Section 302 of the Indian Penal Code (IPC) for the murder of a 25-day-old baby girl, Puja Pradhan, on April 5, 2007, in the village of Putina, Odisha. The baby’s body was discovered inside the appellant’s room with a cut-throat. The prosecution’s case relied heavily on an extra-judicial confession made by the appellant in front of witnesses, as well as forensic evidence, including a blood-stained sickle and the appellant’s saree, both containing the baby’s blood.
Point of Law:
The key legal point in this case was whether the appellant was of sound mind at the time of the incident and could be held criminally liable. During the trial, evidence was presented that the appellant was suffering from schizo-depression and had a history of mental illness. The trial court, however, rejected the defence’s plea of insanity under Section 84 of the IPC and convicted her, sentencing her to life imprisonment.
High Court Ruling:
On appeal, the Orissa High Court ruled that the appellant was entitled to the benefit of the insanity defence under Section 84 of the IPC, given her medical history, psychiatric evaluation, and absence of motive. The court observed that her behaviour before and after the crime indicated a lack of consciousness about the nature of her actions, leading to her acquittal on grounds of insanity. The court ordered her treatment in a medical facility until she was certified mentally fit.