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ASSESSING THE LEGAL CONSEQUENCE OF NON APPLICATION OF LEGAL INSANITY TO PSYCHOPATHS IN THE INDIAN CRIMINAL JUSTICE SYSTEM
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ASSESSING
THE LEGAL CONSEQUENCE OF NON APPLICATION OF LEGAL INSANITY TO PSYCHOPATHS IN
THE INDIAN CRIMINAL JUSTICE SYSTEM
AUTHORED BY
- SONISHA SRINIVASAN
ABSTRACT:
The legal system in India must
acknowledge interdisciplinary advancements, particularly in psychology, to
prevent stagnation and conventional limitations. Currently, the Indian Penal Code
(IPC) lacks specific provisions for psychopathy unlike the legal system of US
and UK, leaving a gap in the treatment of offenders exhibiting psychopathic
tendencies.
The IPC Section 84, influenced by the
McNaughten test, addresses legal insanity in a vague manner, overlooking
individuals who commit crimes due to a lack of empathy and morals despite
understanding the nature and consequence of their Act. Detecting psychopathy at
early stages remains a challenge for law enforcement, leading to a lacuna in
addressing these cases. Court rulings in cases like, Nithari murders and Raman
Raghav have demonstrated limited understanding of psychopathic behaviour,
emphasizing the need for comprehensive assessments. This paper claims for the establishment
of distinct standards to identify psychopathic behaviour and calls for treating
these offenders separately from those who are legally guilty by virtue of being
ordinary humans devoid of mental illness vis a vis expanding applicability of
legal insanity defence.
This paper analyses the legal
consequences of not granting them legal insanity status. It does so by
assessing how Indian courts treat and punish offenders with psychopathic
tendencies and examining the reasoning behind such decisions. Additionally, it
analyses whether this reasoning of courts and punishments achieves the
objectives of punishment relying on theories of crime with a special focus on
psychoanalytic theory. Criminal responsibility of psychopaths will be analysed
by various philosophical theories and insanity defence tests.
Separate treatment is justified
constitutionally as well via Article 14 and 21.
Developing standards for identifying
and handling psychopathy and exploring the consequences of granting legal
insanity status will foster a more informed and fair legal framework in India.
Key words: legal insanity ,
psychoanalytic theory, insanity defence , psychopathic, criminal responsibility
INTRODUCTION:
Legal insanity in India needs
enormous research . Psychopathic tendencies are often unsuccessful in taking
insanity defence but by way of expanding the scope of Section 84, it is
possible. Moreover the requirement of a separate provisions is of utmost
importance since treatment of psychopaths and general offender in the same
manner violating fundamental rights of the Constitution. By putting legal
defence on a higher pedestal than medical defence, the grassroot level of
criminal law jurisprudence is affected. Psychopathy remains an unexplored area
in Indian judiciary which needs huge research. There is a need to come up with
standardised tools to work on since existing assessment tools like PCL-R has
been considered in efficient.
RESEARCH OBJECTIVES:
The objectives of this research paper
are :
1. To understand the extent to which
legal insanity defence under Section 84 IPC can be expanded in scope.
2. To evaluate the consequences applying
insanity defence to people with psychopathic tendencies.
3. To prove the requirement of a
separate provision leading with psychopaths in India
4. To establish a standard modus
operandi to determine psychopaths in India
5. To evaluate the consequences of
punishing psychopaths in India and provide recommendations to their separate
treatment.
RESEARCH QUESTIONS:
1) What is the extent to which Legal
insanity defence under Section 84 of IPC can be expanded in scope to include
psychopaths?
2) What are the justifications and
requirements for separate treatment for psychopaths?
3) What are the ways of establishing a
modus operandi to determine psychopaths in India and treating them?
HYPOTHESIS:
H1: Legal insanity under Section 84
cannot be expanded to include psychopaths.
H2: Punishing psychopaths the same
way as punishing any ordinary criminal who has a guilty mind is violative of
Article 14 and 21 and requires separate treatment
LITERATURE REVIEW:
1) Advocate Babila ,Psychopathy in
Indian Judiciary, 10 JETIR (2023)
The paper talks about educating and creating awareness
psychopathy as a disease and assess the chance of treating psychopaths instead
of punishing them. The paper clarifies that psychopathy and criminality are not
interchangeably used. It emphasises on brain anatomy, genetics and person’s
psychopathic traits. There is a perspective on the impact of biological
research on criminality and psychopathy. The Lombrosian theories which
skilfully discriminates categories of people is discarded in modern science. Diagnosis
of psychopathy using Psychopathy checklists and their consequences is provided.
Limitations on the applicability of the current tools for testing in India is
also provided. The study shows the importance of treatment over punishment and
suggests further study on relationship between psychopathy and criminality
since it’s exposure is limited.
2) Dibyangana Nag, Legal lacunae in
addressing psychopaths in view of serial killers- an analysis, 5 IJLLR
The paper puts forth the lacuna in the Indian judiciary that
psychopath as a concept is not included. Non inclusivity of mental health
awareness and the vagueness of Section 84 is established. Inconsistency between
medical developments and legal authorities is putforth as an issue of the
system. Study of serial killers is analysed using the analysis of Nithari
killings and Raman Raghav case. The difference between general offenders and
psychopaths, the lacuna in existing provisions and the use of insanity defence
by serial killers is promptly discussed.
3) KM Sharma, Defence of insanity in
criminal law, 7 ILI (1965)
The unsolved problem in legal jurisprudence – criminal
liability and mental illness is discussed. The Indian law on insanity is
explained in detail including its historic developments. The basis of the law
is further explained with inputs from Mc Naughten Rules. Once various insanity
defence tests from American jurisprudence are promptly displayed, the
substantive law in Indian that is Section 84 of the IPC is broken down. Mental
insanity and legal insanity are anatomised and further some mental disorders
are judicially assessed. The modus operandi is via a survey of judicial review
of insanity defence from 1860 to 1965.
4) Charles Fischette ,Psychopathy and
responsibility, 90 VA. L. REV. 1423 (2004)
The paper gives an over view on the nature of psychopaths
clarifying that not all psychopaths are violent immoral killers. According to
the Hare psychopathy checklist, key psychopathic personalities are put down.
However, it is established that despite cognitive and emotional reality of
disorder in psychopaths, they do meet the legal and psychiatric standards of
sanity. Mc Naughten, Irresistible impulse, Model Penal code and Durham test is
analysed along with its applicability to psychopaths and it as found that
closest applicable test the Durham test. Further various arguments by different
philosophers are presented.
5) Priya Sepaha, Psychopaths: An Unrevealed Area in Indian
Judicial System, 4 NIRMA U. L.J. 1 (2014)
This article talks about the urgent need to classify mental
diseases. Psychopathy is portrayed as dangerous mental ailment which is an
unrevealed area in Indian judiciary. It mentions that UK and US have separate
statutes for psychopaths but India lacks the same. Many cases with respect to rape,
incest, sexual and violent crimes have been reported but no case with respect
to psychopaths have come in. The paper also concludes that taking a close look
at judicial cases , many cases like Nithari killings, the accused had
psychopathic tendencies and there are cases that fall under this category.
6) Grant T. Harris, Tracey A. Skilling,
and Marnie E. Rice, Construct of psychopathy, 28 CRIME. & Just. 197
(2001)
This research paper specifies that psychopaths comprise a
separate distinct natural class of individual. It mentions that psychopaths can
exhibit subtle neurological, physiological and cognitive differences compared
to other people, but it is not clear whether these differences constitute
defective brain function or execution of viable life strategy. The history of
psychopathic construct is expressed. Robert Hare studied the construct of
psychopathy in adult male offenders institutionalised and a psychopathic
checklist came out which is the current assessment tool. Cleckley originally
came up with the list and Hare operationalised it.
7) Archita Choudhary, Justice for Criminal
Psychopaths- Punishment or treatment, 4 JCIL
The paper claims to talk about and spread awareness on
psychopaths’ disease and make separate laws and policies for psychopaths. The
article has established the importance of treating rather than punishing. It
shows the statutes of US, UK where modus operandi to identify and treat
psychopaths separately. Inspiration from these concepts are taken up on Sunday. Insights into the
mind of serial killers after and before the commission is also done.
8) Heywood, Equality, Social Justice
, Welfare
The paper deals with three forms of equality . Formal
equality, equality of outcome and equality of opportunities places am important
role.
CHAPTER 1: UNDERSTANDING NATURE OF
PSYCHOPATHS AND THE APPLICABLITY OF INSANITY DEFENSE TESTS
Nature of psychopaths:
Many consider psychopathy as an anti
personality disorder. However, it is much more than that. Various literature is
available that construes the complete anatomy of psychopaths. Not every
psychopath criminal, though there is high probability of a psychopath turning
into a criminal. In India, the concept of psychopathy remains an unexplored
area but there is an urgent need for recognition and research.
Currently, the sole and fitting
instrument at hand is the PCL- R – the psychopathy checklist. It is a list of
traits and behaviour devised by Hare which contains 22 items. Initially it was
brought up by Cleckley and later operationalised by Hare. Psychopathy is
characterised by deceitfulness, lack of remorse which means they hardly feel
guilt and often portray themselves as victim to reduce their culpability, lack
of empathy, shallow effect where they do not merely repress but lack ability to
show normal feelings in the world, impulsivity with snap judgements and no
regard to future consequences and little behavioural control[1].
The PCL- R test suffers from huge inconsistencies, with the major one being it
was devised using a sample size of only adult males institutionalised which
technically does not represent the entire universe. However, until a more
efficient tool of measuring psychopathy and identifying a “psychopath”, the
best possible tool remains PCL- R
Insanity defence
Now that we have understood the way a
psychopath is identified in today’s society, the next important step is to
assess the insanity defence in India and check the extent to which whether psychopaths can use the defence.
Section 84 of the Indian Penal Code[2]
declares that anything done by a person with unsound mind is not an offence.
However what constitutes unsoundness of mind is something that has been widely
discussed but still keeping the provision vague. For an act to fall under the
defence of Section 84, the act must have a guilty intent.[3]
The justification for not attaching liability on an insane person is the fact
that insane person lacks guilty intention and rational thinking. The test of
insanity revolves around 2 factors- one is the unsoundness of mind was such
that person is incapable of knowing the nature of the Act and the person cant
understand whether the act is wrongful or not. This has been taken from the Mc
Naughten Rules which requires that inorder to take the defence of insanity, a
mental disease should have caused a defect of reason which makes a person
incapable of knowing whether the act a person has committed is right or wrong.
However applicability of this rule to psychopaths is not quite correct since
even if its proved that the psychopath suffers from a mental illness, it
doesn’t cause a defect of reason which makes him/her commit a crime. Other
tests which came up with jurisprudential development include irresistible
impulse which means a person cannot be held liable since a mental defect
doesn’t allow him/her to control behaviour. However, psychopaths can control
behaviour for self interest making irresistible impulse inapplicable. The Model
Penal Code provides that when a person, at the time of committing a crime, due
to mental disease or defect is unable to appreciate the criminality/
wrongfulness of the act or to conform the conduct to the requirements of law
should not be held liable. There is limited application of this to psychopaths
considering the lack of clarity on what MPC wants to track. Finally, the Durham
rule is the one that seems most plausibly applicable to psychopaths since it
states that a person should not be criminally liable if the criminal act is a
product of mental illness or mental defect. Durham himself was considered to be
a psychopath. [4]
Applicability of insanity defence
test:
We hence can conclude that out of the
above mentioned rules of insanity, Durham seems most applicable. However,
Section 84 is highly inspired by Mc Naughten rules where psychopathic
tendencies don’t essentially have a place. Psychopaths may not understand and
accept what they have done is wrong nut they have enough cognitive
understanding to meet the requirements of criminal law. This essentially
implies they meet the requirement of Section 84. They know the nature and
consequences of their act, however they don’t know why they are doing it,
essentially lacking mens rea. To the extent of guilty mind, there is a small
scope for insanity defence to include persons with psychopathic tendencies,
considering psychopaths lack mens rea. However this loophole can be further
operationalised only when unsoundness of mind is given clear meaning to include
acts lacking mens rea.
Assessing “insanity”
In the above section, we looked at
insanity from the view point of mens rea which is categorised as legal
insanity. However, courts look into legal insanity only. To put this into
perspective distinguishing it from medical insanity is essential. Medical
insanity is characterised by the fact that person is not sound, healthy, normal
and requires treatment. Motivation is also an important factor for medical
insanity. While legal insanity looks into whether person knows the
righteousness and wrongfulness of an offence, motivation is not an essential
factor. Additionally, legal insanity is considered by law only during the time
of crime commission, whereas medical insanity can pop up anytime and it is not
essential that it has to be during crime commission. The current position of
law gives legal insanity a priority over medical insanity. [5]
The scope of insanity under Section
84 can be increased by allowing medical insanity merge into legal insanity to
the extent of considering insanity as person who is not sound, healthy, normal
and requires treatment. Although psychopaths cannot come under unsound, they
definitely come under the category of not being normal and requiring treatment.
This way they could make use of the defence of insanity under Section 84
itself.
CHAPTER 2: CURRENT POSITION OF
PSYCHOPATHS IN THE INDIAN JUDICIARY
In the Indian judiciary system, there
have been multiple instances where psychopaths were recognised by courts.
However, the treatment has been the same as any other general offender.
Lets look at a couple of cases.
1) Nithari killings[6]-
This gruesome case which shook the entire nation involved sexual assault,
murder, cannibalism and even necrophilia. The victims were women and children
who were killed and the accused Surendra Koli tried to have sex with their
corpses and even performed cannibalism. The court held that this was recognised
as rarest of rare crimes and that the appellant Surendra Koli was a serial
killer. Death sentence was justified considering aggravating and mitigating
circumstance thereby providing the same punishment as a general offender. Surendra
Koli showed clear psychopathic tendencies expressing no guilt , committing
murder for constantly long periods of time. He was even declared as a
psychopath , but the legal system chose to ignore the concept.
2) Raman Raghav[7]-
Raman Raghav was considered a psychopathic serial killer killing over 40
residents of Bombay hitting their heads with an iron rod. The modus operandi of
his killings were the same. He was diagnosed with chronic paranoid
schizophrenia. Psychodynamic theory of committing crimes where childhood
experiences and emotional attachments, psychoanalytic theory with unhealthy
expression of unconscious desire and strain theory of sociology where people
from the lower strata of the society have more tendency to commit crimes
converge to bring the causation for Raman Raghav to commit the crime.[8]
3) Auto Shankar- The person responsible
for the gruesome murders of Chennai was none other than womanizer, notorious
serial killer Auto Shankar. Inked with dual personality, the courts refused to
consider his appeal of death sentence. The causation was due to his childhood
traumas and dysfunctional parents. [9]
4) Charles Sobraj- Coming from a
troubled childhood, widely known as the bikini killer, Sobraj was responsible
for death of more than 20 backpackers. Whenever he committed crimes, he
maintained the legal position that he has not committed crimes since he wasn’t
held guilty for any.[10]
CHAPTER 3: NEED FOR SEPARATE
TREATMENT FOR PSYCHOPATHS AND ITS CONSTITUTIONAL JUSTIFICATION
Biological justification:
With legal advancements, a similar
level of research and development in biology and medicine will definitely lead
to better and efficient criminal justice system. A psychopath suffers from a
minor neurological disorder- cavum septum pellucidium where there is lack of
development of emotional part of the brain. There is structural and functional
impairment of the brain with 18% reduction in volume of amaygdala- emotional
part of the brain. We could argue for mental illness considering these
biological impairments. Another deeply contested debate is free will and
determinism where on one side it is argued that psychopaths take decision by
their own choices solely which is free will. On the other hand, in this paper,
it is argued that deterministic approach is taken. A clear evidence of this are
the reasoning for causations mentioned in the previous chapter. Many
psychopaths do commit crimes due to emotional attachments, childhood trauma,
dysfunctional home etc where their environment plays a role in determining their
act. Hence its not by free choice but by determinism that psychopaths commit a
crime.
Article 14[11]
justification:
The Indian Constitution
operationalises not only formal equality but also substantive equality. It
looks at equality among equals, not equal among unequals. The classification is
not discriminatory, only class legislation is forbidden under Article 14,
whereas reasonable classification is allowed. The twin test of Article 14 laid
down in State of West Bengal v Anwar Ali Sarkar[12]
were
a) Classification is to be based on
intelligible differentia which distinguishes persons or groups that are grouped
from others left out
b) The differentia must be based on
rational nexus/ relationship with the object sought to be achieved. [13]
There must be a yardstick to
differentiate the class included and class excluded. Incase of psychopaths, the
classification as a separate is based on intelligible differentia and the
yardstick to differentiate includes both the biological impairments as well as
psychological illness including lack of guilty mind. The object sought to be
achieved is not only deterrence but also rehabilitative system. It might be
true that not punishing psychopaths, many of whom have serial killer tendencies
could be dangerous to the society in general. Additionally it could also be
argued that public interest should be put on a higher pedestal and a conflict
with reasonable restriction of public order could be used. However, not
punishing does not mean letting them be free in the society, but providing
treatment both in medical/ biologically with specific neurological sense as
well as psychological sense.
When a psychopath expresses pervert,
sadistic pleasure , in the first instance it might seem impossible to treat
psychopaths and hence the best available option would be to discard them from
the society. However, further studies and digging into the root cause could
eliminate the impairments and let psychopaths lead normal lives.
Article 21[14]
justification:
Treating psychopaths the same way as
a general offender is an indirect violation of Article 21- right to life and
personal liberty except according to procedure established by law. Procedure
established by law includes procedural and substantive due process where the
modus operandi/ process is ensured to be just , fair and reasonable. Principles
of natural justice sought to be protected at every level. Psychopaths don’t
fall into the procedure established in any manner since technically treating
them in the same manner as an ordinary criminal is in itself violation of
justice and fairness since they are firstly not equals and treating unequals
equal is also a violation of Article
This calls for need to consider
psychopath as a separate individual class and not treat them in the same way as
ordinary adults.
CHAPTER 5: NEED FOR A SEPARATE
PROVISION SPECIFICALLY FOR PSYCHOPATHS
Separate treatment of psychopaths
cannot be left hanging. There is an urgent requirement of a provision dealing
specifically with psychopaths. Punishing psychopaths like other offenders is
futile since psychopaths don’t feel remorse or guilt for the crime they have
committed
US and UK have laws where psychopaths are not only identified but also have measures provided to them. In England and Wales, law agrees psychopathy is due to abnormalities different from mental illness and hence the most beneficial thing is to send them to rehab centres than prisons. Post World War, therapeutic communities were developed to treat psychopaths. Hederson Hospital is the oldest one engaged in treating patients with personality disorder. The intersection with therapeutic jurisprudence and a simultaneous development in this emerging area will aid the law to act as a therapy.
US and UK have laws where psychopaths are not only identified but also have measures provided to them. In England and Wales, law agrees psychopathy is due to abnormalities different from mental illness and hence the most beneficial thing is to send them to rehab centres than prisons. Post World War, therapeutic communities were developed to treat psychopaths. Hederson Hospital is the oldest one engaged in treating patients with personality disorder. The intersection with therapeutic jurisprudence and a simultaneous development in this emerging area will aid the law to act as a therapy.
In USA, different States have
different laws to manage psychopaths. California established the psychopathic
offender law in 1939. Many such statutes allow the state to hold custody of
psychopaths till a point he or she is completely cured of the mental illness.
State is allowed to pass indeterminate and lifetime sentencing too. [15]
Taking inspiration from model
provisions for other countries, it is high time India steps up in bringing
about provisions for offenders who are victims in their own head.
CONCLUSION :
Psychopathy thus remains an under
researched area from neurobiological and criminality perspectives which needs
great amount of research and developments.
Answering the research questions,
1) The extent of applying insanity
defence under Section 84 is to the extent of being able to include medical
insanity to the extent of its meaning as well as operationalising “unsoundness
of mind” to include acts lacking mens rea.
2) Constitutionally by way of Article 14
and 21, the need for separate treatment of psychopathic offenders is justified.
Neurobiologically impairment in the brain and emotional part of the brain
argues the case for separate treatment. Treating general offenders and
psychopathic offenders the same way is also a intervention into criminal law
jurisprudence where a person is liable only with both actus reus and mens rea.
In case of psychopaths, punishing them without mens rea violates the whole
criminal law jurisprudence set up.
3) It is important to establish modus
operandi to identify psychopaths by developing a tool for identification with further
study on coming up with tools similar to PCL- R tool, since the PCL- R tool is
inadequate and requires huge change. Taking inspiration for treatment from
countries like UK, US, Canada, specific statutes for psychopaths are to be
achieved. [16]
Hypothesis 1 is not entirely proved
since there are loopholes and ways available in the law to include psychopaths
under legal insanity under Section 84. Hypothesis 2 has been proved
successfully.
RECOMMEDATION:
1) Bring out separate provisions dealing
solely with psychopaths drawing inspiration from UK, US and Canada
2) Conduct enormous research in science-
neurobiology, criminology, criminality and psychopaths to establish the
relationship between criminal liability and psychopathic tendencies.
3) Explore areas under Section 84 to
include extents of medical insanity as legal insanity.
4) Strengthening the meaning of the word
“unsoundness of mind” to include mental impairments and acts done without
guilty mind.
5) Focusing the objective of managing
psychopaths as treatment rather than punishment with focus on therapeutic
jurisprudence.
REFERENCES:
1) Charles Fischette ,Psychopathy and
responsibility, 90 VA. L. REV. 1423 (2004)
2) Indian
Penal Code, Section 84
3) KM
Sharma, Defence of insanity in criminal law, 7 ILI (1965)
4) Surendra
Koli v. State of U.P. (2011) 4 SCC 80
5) Poonam
Saxena, Inside the mind of Raman Raghav, Mumbai’s serial killer of 60s,HINDUSTAN
TIMES, (14 June 2016, 7:22 pm), https://www.hindustantimes.com/bollywood/inside-the-mind-of-raman-raghav-mumbai-s-serial-killer-of-the-60s/story-LaA01MtT0wrAM0ZprCoLYJ.html
6) Vaishnavi
Bhedodkar, Psychopathic serial killer- case study, https://www.slideshare.net/Vaishnavi1409/psychopathic-serial-killer-raman-raghav-case-study
7) Dhruvin
Bhusa, Auto Shankar : The gut wrenching Saga of India’s Ted Bundy of the
80’s, The News Minute (8 June 2021, 5:58pm), https://homegrown.co.in/homegrown-explore/auto-shankar-the-gut-wrenching-saga-of-indias-ted-bundy-of-the-80s
8) Vidushi
Sagar, ‘I tried to make him love me, but became his slave.’: The Allure of
bikini killer Charles Sobhraj Explained, News18 (December 22 2022, 16:49
IST), https://www.news18.com/news/explainers/nepal-court-charles-sobhraj-release-serial-bikini-killer-serpent-who-is-he-explained-6669727.html
9) INDIA
CONST. art 14
10) State
of West Bengal v Anwar Ali Sarkar, 1952 SCR 284
11) State
of Tamil Nadu v National South Indian River
12) INDIA
CONST. art 21
13) Archita
Choudhary, Justice for Criminal Psychopaths- Punishment or treatment, 4 JCIL
[1] Charles Fischette ,Psychopathy
and responsibility, 90 VA. L. REV. 1423 (2004)
[2]
Indian Penal Code, Section 84
[3] KM Sharma, Defence of insanity in
criminal law, 7 ILI (1965)
[4] Supra Note 3
[6] Surendra
Koli v. State of U.P. (2011) 4 SCC 80
[7]
Poonam Saxena, Inside the mind of Raman Raghav, Mumbai’s serial killer of
60s,HINDUSTAN TIMES, (14 June 2016, 7:22 pm), https://www.hindustantimes.com/bollywood/inside-the-mind-of-raman-raghav-mumbai-s-serial-killer-of-the-60s/story-LaA01MtT0wrAM0ZprCoLYJ.html
[8]
Vaishnavi Bhedodkar, Psychopathic serial killer- case study, https://www.slideshare.net/Vaishnavi1409/psychopathic-serial-killer-raman-raghav-case-study
[9]
Dhruvin Bhusa, Auto Shankar : The gut wrenching Saga of India’s Ted Bundy of
the 80’s, The News Minute (8 June 2021, 5:58pm), https://homegrown.co.in/homegrown-explore/auto-shankar-the-gut-wrenching-saga-of-indias-ted-bundy-of-the-80s
[10]
Vidushi Sagar, ‘I tried to make him love me, but became his slave.’: The
Allure of bikini killer Charles Sobhraj Explained, News18 (December 22
2022, 16:49 IST), https://www.news18.com/news/explainers/nepal-court-charles-sobhraj-release-serial-bikini-killer-serpent-who-is-he-explained-6669727.html
[11]
INDIA CONST. art 14
[12]
State of West Bengal v Anwar Ali Sarkar, 1952 SCR 284
[13]
State of Tamil Nadu v National South Indian River
[14]
INDIA CONST. art 21
[15]
Archita Choudhary, Justice for Criminal Psychopaths- Punishment or
treatment, 4 JCIL
[16]
Supra Note 15
Article Information
ASSESSING THE LEGAL CONSEQUENCE OF NON APPLICATION OF LEGAL INSANITY TO PSYCHOPATHS IN THE INDIAN CRIMINAL JUSTICE SYSTEM
Authors: SONISHA SRINIVASAN
- Journal IJLRA
- ISSN 2582-6433
- Published 2024/04/19
- Issue 7
About Journal
International Journal for Legal Research and Analysis
- Abbreviation IJLRA
- ISSN 2582-6433
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