The landmark judgement of Chunni Bai vs State of Chhattisgarh 2025 gained attention due to the shocking nature of the crime infanticide by a mother and the subsequent legal debate over mental health, criminal responsibility and rare invocation of "invisible influences" as a defence. The Supreme Court’s nuanced shift from murder to culpable homicide not amounting to murder highlighted evolving judicial sensitivity towards mental health in criminal jurisprudence. Discover more in-depth analyses of important Supreme Court decisions by exploring Recent Judgements of Supreme Court.

Chunni Bai vs State of Chhattisgarh 2025 Introduction

The landmark judgement Chunni Bai vs State of Chhattisgarh 2025 is a tragic and complex criminal case involving the brutal killing of two minor daughters by their mother in a rural village in Chhattisgarh. The case raised important questions regarding criminal intent, mental instability and the application of Section 302, Section 304 Part II and Section 84 of the Indian Penal Code.

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The case at hand centres around the brutal murder of two minor daughters by their mother, Chunni Bai, in the village of Bharadkala, Chhattisgarh, in 2015. The case examines the culpability of the mother under Section 302 of Indian Penal Code based on eyewitness testimony, medical evidence and forensic reports and culminates in the upholding of her conviction by both the Trial Court and the High Court. The following are the facts of Chunni Bai vs State of Chhattisgarh -

Incident and Accused

On 5th June, 2015 at around 9:00 AM, in Bharadkala village, District Bemetara, Chhattisgarh, Chunni Bai, the Appellant attacked her two minor daughters: Yogita Sahu (5 years) and Nisha Sahu (3 years) with an iron crowbar. The assault caused severe head injuries which resulted in their deaths.

Eyewitness Account

Sonam Sahu (PW-1), the sister-in-law of the Appellant and an eyewitness was present in the house during the incident. She heard the Appellant shouting that she was killing her daughters. When she entered the room, she saw the Appellant hitting the younger daughter with the iron crowbar. She intervened, took the weapon away and informed nearby family members and neighbors.

Filing of FIR and Police Investigation

Later the same day, Laxman Prasad Mishra (PW-3), a neighbor filed a complaint at Saja Police Station which resulted in the registration under Section 302 of Indian Penal Code. The police arrested the Appellant and recovered the bloodstained iron crowbar based on her memorandum statement. The FSL report confirmed the presence of human blood on the weapon.

Medical Evidence

Dr. G.S. Thakur (PW-18) conducted postmortem examinations of both children. He described multiple crushed injuries to the skull and opined that the cause of death was cardiorespiratory arrest due to brain injuries caused by a hard and blunt object. He confirmed that both deaths were homicidal in nature.

Trial Proceedings

During the trial, the prosecution examined 20 witnesses, including the eyewitness and the medical expert. The Appellant in her statement under Section 313 of Criminal Procedure Code, denied the allegations and claimed she had no recollection of the incident and was influenced by an invisible force. However, she did not present any defence witness.

Trial Court Judgment

The Court of Additional Sessions Judge, Bemetara held the Appellant guilty under Section 302 IPC. The Court relied on the consistent eyewitness testimony, corroborating evidence, postmortem reports and the FSL report. On 29th June, 2016, the Appellant was sentenced to life imprisonment with a fine of Rs. 1,000 and a default sentence of one month of additional rigorous imprisonment.

High Court Appeal and Appeal in Supreme Court

The Appellant challenged the conviction before the High Court of Chhattisgarh and argued that the prosecution failed to establish guilt beyond reasonable doubt and claimed mental unsoundness. However, the Division Bench dismissed the appeal on 21st November, 2023, and affirmed that the evidence proved the Appellant's guilt and upheld the trial court’s judgment.

Aggrieved by the decision of the High Court, the Appellant approached the Supreme Court and challenged the decision of the High Court.

Chunni Bai vs State of Chhattisgarh 2025 Legal Issues

The following issues were also addressed in Chunni Bai vs State of Chhattisgarh 2025:

• The main issue was whether the claim of the Appellant of being under an "invisible influence" qualifies as legal insanity under Section 84 IPC?
• The Supreme Court examined whether the Appellant possessed the mens rea required for conviction under Section 302 IPC?
• The Court examined whether the conviction should be altered from murder to culpable homicide not amounting to murder?
• Lastly, the Supreme Court in Chunni Bai vs State of Chhattisgarh examined whether the Appellant was entitled to immediate release after serving nearly 10 years in custody?

Section 302 of Indian Penal Code played an important role in Chunni Bai vs State of Chhattisgarh 2025. The following is the analysis of this provision:

Section 302 of Indian Penal Code: Punishment for Murder

Section 302 (Now Section 103 of Bharatiya Nyaya Sanhita 2023) deals with the punishment for murder. It states that whoever commits murder shall be punished with death or imprisonment for life and shall also be liable to fine.

Chunni Bai vs State of Chhattisgarh 2025 Judgment and Impact

On 28th April, 2025, the Supreme Court of India in Chunni Bai vs State of Chhattisgarh held that the Appellant did not qualify for relief under Section 84 IPC due to lack of clinical evidence proving unsoundness of mind, her behaviour during and after the incident raised a significant doubt about her mental state. 

The Supreme Court observed that her conduct was bizarre, unexplained and was not supported by any motive especially in cases involving grave offences like murder.

Supreme Court acknowledges Influence of Mental Instability

The 2-Judge Bench comprising Justices BV Nagarathna and NK Singh in Chunni Bai vs State of Chhattisgarh held that although the “invisible influence” remained speculative, peculiar and abnormal behaviour of the Appellant could not be ignored. The Court observed that the complete lack of motive given the sacred nature of a mother-child relationship and rural, uneducated background of the Appellant justified considering the possibility of temporary mental instability.

Application of Section 304 Part II IPC and Release Based on Time Already Served

The Supreme Court in Chunni Bai v State of Chhattisgarh held that the intention to kill was not established beyond reasonable doubt. Therefore, it altered the conviction from Section 302 IPC to Section 304 Part II IPC which addresses cases where death is caused without the intention to cause death.

The Court also noted that the Appellant had already undergone 9 years and 10 months in custody which is close to the maximum 10-year punishment under Section 304 Part II, the Supreme Court directed her release.

Guidance to Trial Courts

The Supreme Court in Chunni Bai vs State of Chhattisgarh highlighted that in homicide cases where an accused claims to be influenced by unexplained forces or exhibits inexplicable behaviour, the Trial Courts must actively probe into the mental condition of the accused. The Courts may invoke Section 165 of the Indian Evidence Act to seek truth even if the accused remains silent. The objective is to ensure that mens rea is established beyond reasonable doubt.

Conclusion

In Chunni Bai vs State of Chhattisgarh 2025 the Supreme Court on 28th April, 2025 set an important precedent by acknowledging the possibility of temporary mental instability despite lack of clinical evidence. By altering the conviction to Section 304 Part II of Indian Penal Code and ordering her release, the Supreme Court reinforced the importance of scrutinising mens rea and underscored the role of the judiciary in balancing justice with compassion.