BHIKARI vs STATE OF UTTAR PRADESH

The Supreme Court held that the burden of proving the intention of the accused, as an ingredient of the offence under Section 302 IPC, lies with the prosecution and does not shift. The Court clarified that while Section 84 IPC allows an accused to claim insanity, the prosecution is not required to prove the accused's sanity; rather, the accused must prove the exception under Section 105 of the Indian Evidence Act. The Court affirmed the principle that if reasonable doubt is created regarding the accused's mental state, he is entitled to acquittal, distinguishing this from the prosecution's obligation to establish sanity.