In a significant judgment, the Supreme Court of India has reduced the punishment of a mother, Chunni Bai, who was earlier convicted under Section 302 IPC for killing her two young daughters, aged 3 and 5 years. The Court altered the conviction to a lesser offence—culpable homicide not amounting to murder—under Section 304 Part II IPC, noting the absence of motive and possible mental instability.
Case Background
The incident occurred in 2015 in Chhattisgarh’s Bemetara district, where Chunni Bai fatally attacked her daughters with an iron crowbar. An eyewitness, her sister-in-law, heard her shouting that she was killing her daughters. The woman later admitted to the act but claimed to be under the influence of an "invisible power."
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The trial court sentenced her to life imprisonment in 2016, which was later upheld by the Chhattisgarh High Court. However, the Supreme Court, led by Justices B.V. Nagarathna and Nongmeikapam Kotiswar Singh, re-evaluated the case and observed that there was no evidence suggesting motive or prior mental illness, but the behavior and statements made by the appellant raised serious concerns.
“Nevertheless, in our view, 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,” the Court remarked.
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The judgment emphasized the absence of any discord in the family, and all witnesses confirmed that the appellant was a loving mother with no prior history of violence or animosity. The Court found no signs of premeditation or attempt to flee after the incident. It concluded that she might have been mentally unstable at the time, though no medical proof under Section 84 IPC was presented.
“If the accused at the time of commission of crime was incapable of making conscious and informed decision… it may put a question mark on the ‘intention’ of the accused in committing such a crime,” the bench added.
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Considering that Chunni Bai had already spent 9 years and 10 months in custody, and the maximum punishment under Section 304 Part II IPC is 10 years, the Court ordered her immediate release.
“In the complete absence of motive, a mother assaulting her children of tender ages to death… is contrary to lived human experiences,” observed the bench.
Case Details: CHUNNI BAI v. STATE OF CHHATTISGARH|(@ SPECIAL LEAVE PETITION (CRL.) No. 13119 of 2024)
