Supreme Court: “Mental Anguish” Leads to Release of the Mother of the Twins, who Murdered them

The Supreme Court of India, through a Division Bench comprising Justices Ahsanuddin Amanullah and Ajay Rastogi, allowed an appeal against the High Court of Madras’ decision rejecting the premature release of an appellent, Manjula by the State of Tamil Nadu. The appellant, convicted of murdering her twin children and attempting suicide, was granted premature release after serving nearly 20 years in prison. However, the Court upheld her murder conviction, rejecting the argument that her actions fell under Exception 1 of Section 300 of the Indian Penal Code (IPC).

Decision and Analysis:

Case Background:

• The appellant had an affair with Suresh, a relationship described as illicit and abusive. Due to Suresh’s conduct, the appellant decided to commit suicide along with her twin children. While attempting the act, her niece intervened, but the twins were declared dead upon arrival at the hospital.
• Under Trial Court Judgment the appellant was convicted of murdering her children and attempting to commit suicide, under Sections 302 and 309 of the IPC, respectively, and was sentenced to life imprisonment.

Exception 1 of Section 300, IPC:

• The appellant argued that her actions were due to grave and sudden provocation, falling under Exception 1 of Section 300 of the IPC. She claimed the extreme step was taken in a state of mental distress, without an intention to kill her children, thus warranting a conviction under Section 304 (Culpable Homicide not amounting to Murder) instead of Section 302.
• The High Court acquitted the appellant under Section 309 for attempting to commit suicide but upheld the murder conviction, rejecting the application of Exception 1 to Section 300. The Court noted the appellant’s severe mental stress but did not find it sufficient to reduce the charge to culpable homicide.

Issue of Premature Release:

• Government Order and Recommendations: A Government Order dated February 1, 2018, issued by the Home (Prison-IV) Department, suggested premature release benefits for life convicts after a minimum of ten years of imprisonment. The appellant applied for premature release after serving almost 20 years.
• The State Level Committee recommended her release, but the State of Tamil Nadu rejected it, citing the brutal nature of the offense.
• The court upheld, “Appellant never tried to murder her sons with a view to continue her illicit relationship. On the contrary, she had tried to commit suicide herself along with her children not with a view to continue her illicit relationship with her paramour but rather, in disappointment and frustration over the quarrel picked up by her paramour. An institution to sermonise society on morality and ethics and we say no further on this score, bound as we are, by the brooding presence of the rule of law.”
• The Supreme Court found no justifiable grounds for the State’s rejection of the Committee’s recommendation.
• The Supreme Court ruled that the appellant was entitled to the benefit of premature release as per the Government Order.

Nagarathinam v. State [Judgment by Hon’ble Justice Ahsanuddin Amanullah ]