Applicability of McNaughton’s Rules in IPC
McNaughton’s Rules & IPC
1. Origin of McNaughton’s Rules
Origin: Daniel McNaughton’s case (1843, England).
McNaughton, under insane delusion, killed Edward Drummond thinking he was the British PM.
The House of Lords framed rules to determine criminal responsibility of insane persons.
Rule (Essence):
A person is not criminally liable if, at the time of the act, due to mental disease/defect of reason, he:
Did not know the nature and quality of the act, OR
Did not know that what he was doing was wrong or contrary to law.
2. Incorporation in IPC
Section 84 IPC directly embodies McNaughton’s Rules.
Section 84 IPC – 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 what he is doing is either wrong or contrary to law."
➡️ Thus, legal insanity (not medical insanity) is recognized.
3. Conditions for Defence under Section 84 (Based on McNaughton’s Rules)
Person must be of unsound mind.
Unsoundness must exist at the time of commission of act.
He must be incapable of knowing:
The nature of the act, OR
That the act is wrong or contrary to law.
👉 Mere history of insanity or odd behaviour is not sufficient – must prove unsoundness during the act.
4. Important Case Laws
McNaughton’s Case (1843, UK) – Laid foundation.
Dahyabhai Chhaganbhai Thakkar v. State of Gujarat (1964)
SC: Accused must prove preponderance of probabilities for insanity (not beyond reasonable doubt).
Prosecution still must prove offence beyond reasonable doubt.
Surendra Mishra v. State of Jharkhand (2011)
SC: Medical insanity ≠ Legal insanity.
Only unsoundness affecting knowledge of act/wrongness at the time gives benefit.
Hari Singh Gond v. State of M.P. (2008)
Merely being mentally ill ≠ enough.
Test is whether accused knew act was wrong or contrary to law.
5. Distinction: Medical vs. Legal Insanity
| Medical Insanity | Legal Insanity (Sec. 84 IPC) |
|---|---|
| Any mental illness diagnosed by doctors | Only that mental illness which destroys ability to understand nature/wrongness of act |
| Broader concept | Narrower concept |
| May or may not affect criminal responsibility | Directly affects criminal liability |
6. Burden of Proof
Accused must prove insanity under Sec. 105 Evidence Act (on balance of probabilities).
Prosecution must prove crime beyond reasonable doubt.
7. Summary
McNaughton’s Rules (UK) form the basis of Sec. 84 IPC.
Defence available only if:
Person was insane at the time of act, AND
Did not know nature of act OR that it was wrong/illegal.
Mere eccentricity or medical diagnosis is not enough.
✅ In short:
Section 84 IPC = Indian version of McNaughton’s Rules.
Defence is available only for legal insanity, not every mental illness.
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