Summary
In a rare and controversial decision, the Supreme Court converted a woman’s conviction from murder to a lesser offence of culpable homicide not amounting to murder. Despite killing her two minor daughters with a crowbar, the Court found no conclusive evidence of “intent to kill” and considered her claim of being under the influence of an “invisible power” as reasonable doubt. She was released after serving nearly 10 years in jail.
Facts of the Case
In 2015, in a village in Chhattisgarh, Chunni Bai killed her daughters—aged 5 and 3—by smashing their heads with an iron crowbar. Her sister-in-law, who lived in the same house, witnessed the attack and immediately alerted the family. The girls died from severe brain injuries caused by blunt force trauma. Despite overwhelming evidence and multiple eyewitnesses confirming her actions and confession, Chunni Bai claimed she was not in control and blamed an invisible force.
Legal Provisions Involved
- Section 302 IPC – Murder
- Section 304 Part II IPC – Culpable homicide not amounting to murder (without intent)
- Section 84 IPC – Act of a person of unsound mind
- Section 313 CrPC – Statement of the accused
- Section 105 Evidence Act – Burden of proof on accused to claim exception
- Section 165 Evidence Act – Court’s power to question witnesses and seek truth
Arguments of Petitioner and Respondent
- Petitioner (Chunni Bai): Denied intent and claimed she was possessed or controlled by an invisible power. She didn’t produce any medical proof of mental illness or insanity.
- Respondent (State of Chhattisgarh): Provided strong medical and eyewitness evidence proving that she deliberately killed her daughters using a blunt iron weapon. The postmortem confirmed the deaths were homicidal.
Court’s Observation
While acknowledging that the killings were committed by the accused, the Court emphasized:
- There was no motive, no prior animosity, and no attempt to escape.
- Witnesses confirmed she had a loving relationship with her children and showed signs of remorse immediately after the incident.
- Her statement about being under the influence of an invisible force, though unproven, could not be entirely dismissed, especially considering her rural background and lack of education.
- The Court ruled that her mental state created reasonable doubt about her “intention” to commit murder.
- Since “intention” is a key element of murder under Section 302 IPC, the Court held that the charge could not stand.
Conclusion of the Judgment
The Supreme Court set aside her conviction under Section 302 IPC and convicted her under Section 304 Part II IPC, which carries a lighter sentence. As she had already served over 9 years in jail—just under the 10-year maximum for the new charge—the Court ordered her immediate release.
Comments from the author of this website
This judgment starkly exposes the gender bias in our legal system.
Let’s ask a simple question
Question: If a father had picked up a crowbar and smashed his daughters’ heads, would he walk free after 10 years?
Answer: NO.
He’d be labeled a monster. There would be no empathy, no talk of “invisible forces,” and certainly no benefit of doubt.
Here’s the harsh reality:
- Courts assume love and emotional instability in women, but assume intent and cruelty in men.
- If a man cries after a crime, it’s “guilt.” If a woman cries, it’s “remorse.”
- A mother’s mental state is seen as complex and understandable. A father’s is seen as irrelevant.
- Men are expected to prove their innocence beyond doubt. Women are given benefit of doubt—even in the most brutal cases.
The woman in this case gave no medical proof. No diagnosis. No psychiatric history. Still, the Court built a theory of mental instability and lack of intent—just based on her words and rural background. When men claim stress, trauma, or mental disorder, courts often ignore it unless backed by expert evidence.
This isn’t about defending criminals—it’s about demanding equal standards.
If mental instability can reduce a woman’s sentence, it should apply to men too. If absence of motive matters for her, it should matter for him. Justice should not depend on gender.
Read Complete Judgement Here