Shilpi Nama
On April 28, 2025 the Supreme Court of India has commuted the sentence of a mother previously convicted under Section 302 of the Indian Penal Code for the murder of her two young daughters, aged 3 and 5. The Court reclassified the conviction to a lesser charge of culpable homicide not amounting to murder under Section 304 Part II IPC, citing a lack of motive and potential mental instability.
The tragic event took place in 2015 in the Bemetara district of Chhattisgarh, where Chunni Bai fatally struck her daughters with an iron crowbar. An eyewitness, her sister-in-law, reported hearing her declare that she was killing her children. Although the woman later confessed to the act, she claimed to have been influenced by an ‘invisible power.’ The Trial Court sentenced her to life imprisonment in 2016, a decision that was upheld by the Chhattisgarh High Court.
The Supreme Court bench, led by Justices B.V. Nagarathna and Nongmeikapam Kotiswar Singh, re-evaluated the case and observed a lack of evidence demonstrating motive or previous mental health issues, while also voicing apprehensions about the appellant’s conduct and remarks.
The ruling highlighted the lack of family discord, with all witnesses affirming that the appellant was a caring mother with no history of violence or hostility. The Court found no indications of premeditation or an attempt to escape following the incident. It concluded that she may have been mentally unstable at the time, although no medical evidence under Section 84 IPC was provided.
The bench remarked, ‘If the accused at the time of commission of crime was incapable of making conscious and informed decision… it may put a question mark on the ‘intention’ of the accused in committing such a crime.’
Taking into account that Chunni Bai had already served 9 years and 10 months in custody, and considering that the maximum penalty under Section 304 Part II IPC is 10 years, the Court ordered her immediate release. ‘In the complete absence of motive, a mother assaulting her children of tender ages to death… is contrary to lived human experience.’
Case Name: Chunni Bai v. State of Chhattisgarh
Case Number: Special Leave Petition (CRL.) No. 13119 of 2024
Bench: Justice B.V. Nagarathna and Justice Nongmeikapam Kotiswar Singh
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