In January 1843, at the parish of Saint Martin, Middlesex, Daniel M’Naghten took a pistol and shot Edward Drummond, who he believed to the British Prime Minister Robert Peel, wounding him fatally. Drummond died five days later and Mc’Naghten was charged with his murder. He pleaded not guilty by reason of insanity.
In this case, the accused felt that a gang of persons wanted to kill him and the then Prime Minister of England Sir Robert Peel was responsible for this entire situation. The accused was suffering from paranoid delusion. One day he shot Mr. Edward Drummond, the secretary of Prime Minister, thinking him to be Sir Robert Peel. He was arrested and charged with murder. He pleaded the defence of insanity.
At the time of trial, evidence was brought forward regarding the insanity of accused. Also the witnesses deposed that the accused was suffering from insanity.
So the Court accepted the defence and acquitted the accused.
At trial, evidence was given of the shooting of Drummond and witnesses were called on the behalf of the defendant, M’Naghten, to attest to the fact he was not in a sound state of mind at the time of committing the act.
The medical evidence brought forward stated that persons of otherwise sound mind, might be affected by paranoid delusions and that M’Naghten was so affected. A person labouring under such delusion, might usually possess a moral perception of right and wrong, but in relation to acts connected to their delusion may be carried beyond power of their own control leaving them with no such perception.
Accordingly M’Naghten was not capable of exercising control over his acts while he was under his delusion. Due to the nature of M’Naghten’s condition these delusions went on gradually until they reached a climax, ending with Drummond being shot. Evidence brought before the Court about the condition from which M’Naghten suffered stated that a man may go on for years quietly whilste under the delusion’s influence, but had the potential break out into extravagant and violent outburst.
Lord Chief Justice Tindal found M’Naghten not guilty.
Issue no. 1: What is law in respect of the alleged offences committed by the persons laboured with insane delusion in respect of one or more particulars subject or persons.
Issue no.2: If a person under an insane delusion as to existing facts commits an offence in consequence thereof, is thereby excused?
According to section 84 of the Indian Penal Code (1860), Act of a person of unsound mind.—Nothing is an offence which is done by a person who, at the time of doing it, by reason of unsoundness of mind, is incapable of knowing the nature of the act, or that he is doing what is either wrong or contrary to law.
A.1 In my opinion, that not withstanding the accused did the act complained with a view, under the influence of insane delusion of redressing or revenging some supposed grievance or injury, or of producing’ some public benefit, he neverthless punishable according to the nature of the crime committed, if he knew at the time of committing such crime that he was acting contrary to law, by which expression we understand your lordship to mean the law of the land.
A.2 The answer must depend on the nature of the delusion,for instance, if under the influence of his delusion he supposes another man to be in the act of attempting to take away his life, and he kills, that man as he supposes, in self defence, he would be exempted from punishment. If his delusion was that the deceased had inflicted a serious injury to his character and fortune and he killed him in revenge for such supposed injury, he would be liable to punishment.
The Indian Law on insanity is based on the rules laid down in the Mc Naughten case. However, The Mc Naughten rules are based on the entirely obsolete and misleading conception of nature of insanity, since insanity does not only affect the cognitive faculties but affects the whole personality of the person including both the will and the emotions. The present definition only looks at the cognitive and moral aspects of the defendant’s actions but ignores the irresistible impulse that may be forcing him to commit that act. The Law Commission of India in its 42nd report after considering the desirability of introducing the test of diminished responsibility under IPC, s. 84 gave its opinion in the negative due to the complicated medico-legal issue it would introduce in trial. In my view I would conclude that defence of insanity is too narrow and must be amended to suit the present demands.