What is the nature and scope of intoxication under Section 85 and Section 86 of Indian Penal Code?
The topic that I have selected falls under the category of defenses. In certain instances due to circumstances or other reasons that are beyond an individual’s control he indulges in criminal behavior. This also forms an integral part of the law because as it is imperative to punish the guilty, not even a single innocent man must be convicted. The defenses have been specially formulated so that they are able to meet every circumstance. Though a defense does not rescue an individual from liability totally, it does reduce the severity of his punishment for he can be convicted for culpable homicide not amounting to murder rather than murder. Intoxication is one such defense.
I will start with dealing with the origin of the concept, meaning the legal stand on the issue as it has been. As the basic doctrine has been laid down in the British cases, I will deal with the British aspect first. The project will be divided in two sections, one that will deal with the British perspective and the other that will deal with the Indian perspective. Intoxication is codified in section 85 and 86 of the Indian penal code.
I will be dealing with intoxication and its subsidiary aspects. Criminal law can be broadly segregated to a section dealing with offences and another one dealing with defenses. The offences committed constitute that section of criminal law in which the individual actively commits a crime. The very core aspect of this section is that the criminal must have the intention or mens rea to commit the crime. Criminal law, unlike its contemporary, civil law lays great emphasis on the intention of an individual.
Both the sections of my project will deal with the legal stand on the voluntary as well as the involuntary intoxication. I will deal minutely with both the grounds and after expounding the legal stand on both the sides will sum up with a critical analysis and comparison of the law in the two countries.
The British Perspective
Even though voluntary intoxication means that someone has consumed intoxicating substances with their own free will, he may still have a defense to the offence with which he is charged. The intent in case of a crime is very important and even though a person maybe voluntarily intoxicated, the very fact that he is unable to form the required intent works in his favor. The severity of the punishment is reduced due to this defense; for instance, an individual will be punished for the crime of manslaughter rather than the more serious crime of murder. A crime requiring specific intent may be reduced to one requiring basic intent. An intoxicant does not have any separate ‘class’ but it refers to any substance, which has an effect on the consciousness or the decision-making capacity of a person.
What amounts to a state of intoxication?
It was in DPP v Beard that the rule for what amounts to a state of intoxication was laid down. Lord Birkenhead: where a specific intent is a specific element in the offence, evidence of a state of drunkenness rendering the accused incapable of forming such an intent should be taken into consideration in order to determine whether he had in fact formed the necessary intent to constitute the particular crime. Where a specific intent is necessary, if a man is able to prove that he was so intoxicated that he was unable to form the intent, he cannot be convicted of that particular offence.
Basic Intent/ Specific Intent Dichotomy
The rule was laid down by lord Simon of Glaisdale. However he laid down a very complicated rule. To sum it up briefly and simply, the rule provides that some offences do not require a specific intent or motive. Even a basic intent of recklessness or negligence would be sufficient in some crimes. For instance, in case of manslaughter no specific intent is required.
The Rationale Behind the Defence of IntoxicationThe laws in the early nineteenth century concerning intoxication were very stringent. In fact, according to a statement made by Earl of Birkenhead, voluntary intoxication was considered an aggravation rather than a defence. If a person was consuming alcohol, knowing fully well that it would impair his ability to think clearly, then he will be situated in no better condition than a sober man in the judgment of his criminal conduct.
Thankfully, the rule has been mercifully relaxed and a person’s punishment, though cannot be eradicated completely, can be reduced in severity. Further illustrations can be provided with the help of case studies.
R v Lipman
Facts: Both the defendant as well as the victim was addicted to drugs, and on the eve of sixteenth September 1967, both took a quantity of a drug known as LSD. Early in the morning of eighteenth September, the defendant, who is a resident of U.S.A, booked out of his hotel and left the country. The next day, the landlord of the victim found her dead in her room. She had been struck on the head severely and the cause of death had been suffocation due to a sheet that had been crammed in her mouth. The defendant, when he was charged with his crime said that the drug had made him imagine that he was in the center of the Earth fighting snakes and in that state of mind he had killed the victim.
Judgment: the judgment in this case was that since for a charge of manslaughter, no specific intent is required, hence in this case self-induced intoxication will not serve as a defence. Acquittal is not possible, and a charge of manslaughter was inevitable.
Reasoning: the defendant cannot be charged with murder because he had no intention to cause any sort of grievous bodily harm, and without the necessary mens rea, he cannot be convicted of murder. On the other hand, in case of a charge of manslaughter, there is no specific intention required, so in the present case that charge can be easily made. All crimes do not require a particular motive and they provide punishment even in the case of negligence or reckless conduct. In this case the conduct was clearly reckless for the defendant was aware that it was a drug and that it would deprive him of his senses.
DPP. v Majewski
Facts: in this case, Robert Stephan Majewski appeals against his conviction on seventh November 1973 when under the influence of drugs he had made three attempts of assault causing bodily harm and threatened a constable who was on duty.
Judgment: in this case, the judges came to the conclusion that in a case of assault, no specific intention is required and the defendant is guilty as charged.
Reasoning: the reasoning that I have provided is of three judges.
Lord Elwyn Jones LC: According to Lord Elwyn Jones, voluntary intoxication has always been a factor prevalent in crimes such as assault but the rate of self-induced intoxication has escalated alarmingly. The courts, or rather the judges in Britain between crimes requiring basic intent and specific intent have introduced a dichotomy. Hence, what we actually have to decode is what is the mental element required in a case of assault.
He has quoted Lord Simon of Glaisdale5 - I take assault as an example of a crime of basic intent where the consequence is very closely connected with the act. The actus reus of assault is an act which causes another person to apprehend immediate and unlawful violence. The mens rea further corresponds. He further elucidated that what the prosecution in the present case had to prove was that the accused foresaw his act would cause some kind of apprehension to the defendant, or he was reckless with his act. In case of assault, not only the foresight, but the prevalence of the recklessness also constitutes the mens rea.
There is still heated debate as to what extent it is right to let a person goes free because he is on a ‘trip’ due to drugs. Under the early law of England as it prevailed in the nineteenth century, one could never use voluntary manslaughter as a defence. This view propagated that any person who consciously destroys his ability to think reasonably cannot use it as a defence, rather it is an aggravation. However, now this severity has been tempered, from 1819 onwards to as it stands today. In case of an offence requiring basic intent, it is not sufficient for a person to claim that he was intoxicated.
Lord Salmon: He admits that it seems rather arbitrary to excuse one form of intention, while another form in condemned. This however is the most reasonable rule because it is neither too strict nor too lax. Neither part of the rule can be removed without making the rule inconsistent as a whole. The rule will lose its integrity if this is done and will reach one of the extremes if this is done. As we are well aware it is very difficult to apply absolute logic in affairs that deal with human nature because human nature never follows absolute logic. If a person were to be redeemed from punishment merely because he was drunk, the effect on the morale of the society would have been disastrous. Hence when a person does what Lipman does he should not be allowed to go free, for the simple reason that this would make the common man regard the law with contempt. He should not be punished for the crime as a sober man would be, but he still deserves some form of punishment.
Lord Russell of Killowen: There are two extreme views that are prevalent. Some people believe that the law should regress back to what it had been in the early nineteenth century. At that time voluntary intoxication was considered an aggravation rather than a defence. There are others who take a contrary view and say that a man who is intoxicated cannot be considered guilty, because he is incapable of forming an intention. This will be considered technically correct, for a crime does require the element of mens rea, but it will never appeal to a man who has been beaten up by a drunken goon.
Is Voluntary Consumption Per Se Reckless All The Time?
R v Hardie
Facts: Shortly after nine fifteen at night on second January 1982, fire broke out in a wardrobe in the bedroom of the ground floor flat at 55 Bassingham Road, London Sw10. At that time, Mrs. Jeannette Hardie, with whom the appellant had been residing, occupied the flat. Shortly before the above stated date, second January, Mrs. Jeannette had requested the appellant to leave because their relationship had broken down. He did not wish to do so at all, but he reluctantly packed his baggage on the morning of second January. At lunchtime, the appellant discovered two bottles in a cabinet, one of which contained valium. The appellant claimed that he had never taken valium before, and he was very distressed around twelve in the afternoon and took it to calm his nerves. He had taken about four tablets after that and Mrs. Hardie had said that they would not harm him because they had expired. Thereafter he had gone to the bedroom and it was very evident that he must have started the fire because there was nobody else in that room. Te appellant claimed that it was due to the effect of the Valium and he did not remember anything.
Judgment: The judge directed the jury in effect that as the Valium was voluntarily self-administered, it could not serve as a defence.
Reasoning: I will expound the reasoning of Judge Parker because he has pointed out some very important criticisms in this judgment. The authority on which the judgment was based was R v Caldwell, stated that intoxication, when it is self-induced can only serve as a defence when a charge is one of specific intent. In this case however, the charge also included recklessness. In this case Parker ponders whether the taking of Valium in the circumstances that it was can be termed as self-induced.
The court has dealt with two parallel cases; R v Majewski was a case of intoxication due to the consumption of alcohol under the influence of non-medically prescribed drugs while R v Caldwell was a case of plain and simple drunkenness. Both were considered voluntary intoxication. In this case, Judge Parker is not satisfied with the judgment because Valium is not a drug, which causes any kind of aggressive or reckless conduct under normal circumstances. Here, the appellant cannot fall in the same category as the others.
Involuntary IntoxicationAccording to DPP v Majewski, the case that I have already dealt with previously, even in case of a crime requiring basic intent, one can claim involuntary intoxication as a defence depending upon the facts of a particular case. In case of a situation of automation, the party would not be blamed at all. For instance, if some third party mixes LSD in one person’s food and that person causes harm under the influence of that LSD, the third person that has mixed the LSD is entirely to blame. If an individual has to escape from a crime which requires a specific intent it will be very easy because the principle has been clearly laid down in DPP v Majewski, but if he has to escape from a crime of basic intent he will have to rely on both DPP v Majewski as well as R v Hardie
Mistake Regarding Nature of Subsatnce ConsumedR v Allen
Facts: The accused was convicted of indecent assault. He defended himself by saying that he was so drunk at that time that he had been unable to comprehend what he had been doing. He had been given a drink by a friend in a public house, and had been later offered wine. He had not realized that the wine had high alcohol content, and the accused had consumed it without being aware of that fact. It was in that state of mind that the accused had committed assault.
Judgment: The judge in this case held that involuntary intoxication couldn’t serve as a defence in a crime of the nature that the accused had committed.
Reasoning: In this case, there is nothing to prove that the intoxication was involuntary; for the accused had consumed the alcohol with his friend, and it seemed that he had done so willingly enough. Moreover the argument that was given by the accused was that he was not aware of the alcohol content of the wine that he had drunk and it had a much higher content than he had expected. He cannot be absolved from liability on this basis.
Involuntary Consumption of Intoxicants Falling Short of IntoxicationR v Kingston
Facts: The facts are very simple. The respondent was in dispute over business matters with a couple named Foreman, who employed Penn to obtain damaging information which they could use against the respondent, who was a homosexual with Pedophiliac tendencies. As part of the plan Penn invited the youth to his room. According to the evidence that the youth gave, he remembered nothing between a time when he was sitting on the bed, still in Penn’s room, the following morning. It was the case for the prosecution, which the jury by their second verdict must have accepted, that the boy fell asleep due to a drug administration. The respondent committed gross sexual acts with the boy, and Penn took photographs as it had been planned.
Judgment: In this case the accused was charged as guilty because he was not intoxicated enough not to have formed the required intent, even though the intoxication is of an involuntary nature.
Reasoning: The first ground of defence that was adopted was that the accused lacked the required moral element, because the law provides that even though an act is intentional, the intent rises out of circumstances, which are beyond the control of the accused. When he is not to be blamed the necessary mens rea is not present. However, this is a lacuna in the law because it has been strongly condemned. The more sensible approach is that crime consists of an act or an omission.
In this case, such conduct was present; hence the argument of absence of moral fault cannot be considered. The second defence, which was adopted by the accused, was that since the intoxication was of an involuntary nature, he could not be considered guilty. However, this defence can also be done away with easily because as well because we are already well aware of the basic intent and specific intent dichotomy. If the Majewski case is considered, then the crux of the matter would be that if an individual is intoxicated to such an extent that he is unable to form the intent required for the crime then he will be acquitted. Alternatively, if he is fully capable of forming the required intent then he cannot even appeal that he was intoxication as a defence.
If a new line of defence was to be recognized, it will add a lot of discrepancies to the existing law. The defence maybe eventually able to come to terms with the practical conditions, but that will take a long period of time and a lot of understanding as well as amendments. Though it is very necessary for the law to adapt itself to the social conditions, yet it is also necessary that it does not lose its realism and deprive the common man of justice.
The Dutch Courage RuleAs we are already well aware, alcohol has already been associated with crimes of the most heinous nature. Men consume alcohol not only to get an artificial high, but also to get what is popularly known as a ‘kick’, or to go on a ‘trip’ of their own. A lot of times men resort to alcohol due to depression, or when somebody has hurt his or her frail egos. When an individual is depressed or nervous he takes alcohol either to soothe his nerves, or he does so to escape from reality into a world of oblivion where he can escape from his pain or a problem that is causing him depression. In that state of mind he is far from reality and he imagines himself dealing with his problem very bravely and overcoming it. This kind of drinking puts an individual into a stupor. There is also a third category of drinkers that needs to be considered. Sometimes an individual takes to drink to provide him with courage. Drinking causes an individual to become aggressive and lose his sense of self-restraint. It deprives him of his sense of reason to such an extent that he may not even realize that what he is doing is against the law. He may plan or decide what he has to do before he starts drinking, and he may use the drink to provide him with the ‘Dutch courage’ to commit the deed.
Ac For Northern Ireland v Gallagher
Facts: The accused had a grievance against his wife. She had obtained a maintenance order against him and she had got him detained in a mental hospital. The husband decided to kill his wife, and hence having made up his mind, he purchased a knife and a bottle of whiskey to acquire the courage to commit the deed or to be able to put his conscience to rest after the deed had been committed. He committed the deed and consumed much of the whiskey, before or after the commission is yet to be ascertained.
Judgment: The accused was held to be guilty as charged because he had formed the intention before getting intoxicated.
Reasoning: In this case, two conflicting opinions have been expressed, one by the chief justice and the other one by the M’Naghten rules. The object of the Chief Justice was to emphasize on the state of mind of the accused before the consumption of the whiskey, which in this case clearly shows that he possessed the required mens rea for he had made up his mind to kill his wife. But according to the M’Naghten rules, the crucial time for the judging of the intent is the time of the commission of the act.
In this case a further complication is created due the accused being a psychopath. This does not mean that he can avail himself of the defence of insanity, but it can be possible that alcohol has the effect of triggering off the disease. The most important discerning feature of this case is that the accused had already made up his mind to kill his wife, even before he had even touched alcohol. This is far worse than the situation of a man who forms the necessary intent after getting drunk. A brief summary of the general law and its exceptions can be provided as follows:
The illustration of the general principle of how drunkenness produces a defect of reason is:
Drunkenness may impair a man’s senses to think clearly to such an extent that he will not even be aware of the consequences of his actions. He cannot use this as a defense because by now everyone is very well aware of the effect of alcohol and the fact that too much of alcohol is dangerous
2) He may lose his ability to distinguish between what is morally right or wrong.
There are two prevalent exceptions to the general rule:
If a man is charged with a crime that requires a specific intent then he can plead intoxication as a defence. But, though this defence will suffice in case of murder it will not extricate liability in case of a charge of manslaughter.
Is a man brings on a disease of the mind due to drinking, such as delirium; he can be excused from liability. Sometimes due to heavy drinking individual contracts some form of disease and even in this case he can be excused from liability.
In this case, none of the above stated exceptions can be applied because the accused had already formed his intention and merely used alcohol as a means to give him enough courage to commit the deed. Merely because the man is a psychopath, he cannot be excused from liability. The facts have made the situation in this case very clear. The man formed the intent to kill his wife when he was perfectly sober, and he cannot use alcohol as a pretext or defence. It was self induced and purposely consumed, especially to summon the necessary aggression and courage required to commit the deed.
The Indian Perspective
As is well known, the Indian Penal Code is the foundation for the criminal law in India, and Section 85 and 86 deal with intoxication.
Section 85: Nothing is an offence which is done by a person who, at the time of doing it, is, by reason of intoxication, incapable of knowing the nature of the act, or that he is doing what is either wrong, or contrary to the law: provided that the thing that intoxicated him was administered to him without his will or against his knowledge.
To further elucidate, a person who is under the influence of intoxicating substances cannot be charged of a crime if he was:
Incapable of knowing the nature of the act.
That he was doing something in conflict with the laws of his country.
The important clause to be considered in this section of our penal code is that the intoxicating substance must be administered against the will of the individual
Voluntary drunkenness, under normal circumstances, cannot serve as an excuse for the commission of a crime13. However, drunkenness does not make the accused worse, because it does not worsen the nature of the crime committed. Drunkenness can be compared to a situation of madness for which the madman is to blame14. Though the accused is not able to exercise restraint, which he would have under the normal circumstances, he cannot be excused from his act.
In England as well, voluntary intoxication is not a very strong defence.
Nevertheless, voluntary drunkenness can protect an individual in two cases:
There are some crimes which demand the explicit requirement of a specific intent. In such cases, when the accused has had so much to drink that he is unable to form the necessary intent, then he cannot be blamed for the commission of the crime. The punishment of the accused can be reduced due to this defence from murder to culpable homicide not amounting to murder. We are all well aware of the effects of alcohol on the human mind. Since time immemorial, alcohol has been associated with crimes of the worst possible kind, and we are all familiar with the deranged state of an alcoholic. A case can be cited at this instance. In a case of wife burning, the accused had consumed alcohol, and after having a tiff with his wife, had set her on fire after pouring kerosene on her. She had resisted the flames, and had tried to run away, upon which he had grabbed her and set her aflame again. The way the law deals with any criminal situation depends on the facts of a particular case, and here the facts prove that the husband was not intoxicated enough to be unaware of what he was doing and the fact that he pulled the wife back and doused her with kerosene proves this. Hence in this case the accused was convicted for murder.15
In some instances the mind of the individual becomes diseased due to drinking, and the disease is to such an extent that he becomes incapable of taking responsibility for his own acts or even thinking clearly for that matter. The principle rests in the M’Naughton rules that were relied upon in such a case. A common example of a mental state caused due to excessive drinking is ‘delirium tremens’. If a man gets drunk due to the tricks or fraud of another person, he will be excused.
The Penal code has cited two English cases to elucidate the point. The first one is the famous case of DPP v Beard, in which the accused ravished a girl who was thirteen years of age. While raping her, he got so carried away that he placed his hand on her throat and the other one on her mouth resulting in death due to suffocation. The defence given was that the accused was that the accused was so drunk that he was unable to comprehend the severity of his act. The accused was convicted for murder, for the act due to which she died, suffocation, was very different and independent from the act of rape.
Section 86: In cases where an act done is not an offence unless done with a particular knowledge or intent, a person who does the act in a state of intoxication shall be liable to be dealt with as if he had the same knowledge as he would have had if he had not been intoxicated, unless the thing which intoxicated him was administered to him without his knowledge or against his will.
There is always certain guilty knowledge or intention, which forms part of the definition of many offences; this section deals specially to find solutions for such cases. A person who is intoxicated is considered to have the same level of knowledge as a person who is sober. Cases have to be differently judged because some focus on the intent of the individual while others focus on the knowledge that the individual possesses. It must be borne in mind that though an intoxicated person is credited with the same knowledge as a similar sane person, this presumption cannot be made for his intent.
Drunkenness does not make a very big difference to the knowledge with which a man is credited, and a very popular argument based on the above stated notion is that since a person will have knowledge of his deed, he also has the intention to commit it. However, this does not apply to a case where an individual is so drunk that he is unable to from the required intent. In case of R v Kingston, the case that I have already elucidated, the principle that we follow as well as was laid down that if an individual was able to form the required intent even though he was intoxicated, he will be convicted.
So far as the question of knowledge is concerned, the court must adopt the same stand as given to a normal human being, but the question of intent adds complications. Thus, in a case where the accused slit the abdomen of his friend, he was excluded from liability due to section 86 of the Indian Penal Code, simply because he was not able to form the necessary intent.
Basudev v. State of Pepsu
A retired military officer was charged with the murder of a young boy of 15 or 16. Both of them and others of the same village attended a marriage party. All of them went to the house of the bride to attend the mid-day meal. Some had settled down in their seats and some had not. A military who was very drunk and intoxicated, asked the young boy to step aside a little so that he may occupy a convenient seat. But, when he did not move, the military officer whipped out a pistol and shot him in the abdomen. The injury proved fatal. The evidence showed that the accused sometimes staggered and sometimes was incoherent in his talk. But it was shown that he was capable of moving himself independently and was capable of talking coherently as well. The evidence proved that he came on his own to the house of the bride and that he made the choice of his own seat after injuring the deceased, he attempted to get away and was secured a short distance from the scene. When he was secured, he realized what he had done and asked for forgiveness. All these facts, according to the SC, go to prove that there was no proved incapacity on the accused to form the intention to cause bodily harm sufficient in the ordinary course of the nature to cause death. In view of his failure tom prove such incapacity, the law presumed that he intended the natural and probable consequences of his act. In other words, he intended to inflict bodily injuries on the deceased and the bodily injuries so intended to be inflicted, was sufficient in the ordinary course of nature to cause death. The accused was found guilty of murder.
Mavari Surya Sathya Narayan v. State of AP
The accused and the deceased were married for 11 years. He was an alcoholic and quarreled often with her. One day he came home drunk and asked her to sign on some blank papers. When she refused, he pulled her by her hair and dragged her into the room and attempted to set fire on her. The deceased put out the flames and tried to run away. The accused again pulled her, poured kerosene and set fire to her. The deceased died of the burns. The Andhra Pradesh High Court, relying on the SC decision in Basudev v. State of Pepsu, held that having regard to the facts, it couldn’t be said that the accused was in total loss of mental power and hence the provisions of s.85 will not apply.
Venkappa Kannappa Chowdhari v. State of Karnataka
The accused, quarrelsome by nature, was addicted to liquor. The son of the accused died in a motor accident. The accused wanted the compensation amount of 10000, which was in the name of the accused’s wife. On the day of the decision, he came home drunk and asked his wife to withdraw the fixed deposit amount. When his wife refused to comply, he beat her, took a tin of kerosene oil, sprinkled it on her and set her on fire. His wife screamed and the neighbors took her to the hospital. A dying declaration was recorded. The accused took the plea of incapacity due to intoxication u/s 85 IPC. His plea was rejected because he had voluntarily consumed alcohol. He was convicted and sentenced to life imprisonment.
After much research on the topic, it can be said that intoxication is not a very strong defence, and even if it serves to mitigate the severity of a punishment, it cannot exculpate a person from liability. This is essential because absolute and cold logic cannot be applied to human affairs, as they require certain flexibility in their dealing. A common man will not have much regard for the law if a drunken man batters him, and the man gets away with his conduct merely because he was too intoxicated to think clearly.
In India as well, the law that has been followed till date has its foundation in the British law. The first categorical difference is that in case of British law, the defence of intoxication is not codified under any specific section, while under the Indian law it has been clearly codified in sections eighty-five and eighty-six of the Indian Penal Code.
In Indian law, the clause that the drug has to be administered against the will of the individual is given much more importance than it is under the British law. Also, the dichotomy between specific intent and basic intent is given a lot of importance in case of British law. The severity of the punishment an individual can be given is reduced due to this.
In Indian law as well this exception is applicable, as well as an exception in case the individual’s mind is diseased. This portion of our law is very similar to the British law; as a matter of fact the cases that have been cited as authority are also British.
The second factor that can be considered in the case is that in the Indian criminal law, the difference has been made very clear between the intention and knowledge of an individual. Even in British law, the specific intent and the basic intent dichotomy has been elaborated, but they have not given an exclusive difference between the knowledge and intent.
The English law has evolved over a series of cases and it has come a long way from the rigid law that it was earlier. In the early nineteenth century, alcohol would never have been able to serve as a defence. Rather it would have had a reverse effect and this shows us how much the law has progressed in this aspect over a period of time.
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