Public Prosecutor v G Krishnasamy Naidu: Murder, Diminished Responsibility & Delusional Disorder

In Public Prosecutor v G Krishnasamy Naidu, the High Court of Singapore heard the case of G Krishnasamy Naidu, who was charged with the murder of his wife, Chitrabathy d/o Narayanasamy. The incident occurred on May 17, 2004, at Sony Display Device (Singapore). The defense argued diminished responsibility under Exception 7 to Section 300 of the Penal Code, claiming that Naidu suffered from Delusional Disorder Jealous Type, substantially impairing his mental responsibility. The court, presided over by Justice Woo Bih Li, ultimately rejected the defense and convicted Naidu of murder.

1. Case Overview

1.1 Court

High Court

1.2 Outcome

Accused convicted on the charge of murder; defence of diminished responsibility rejected.

1.3 Case Type

Criminal

1.4 Judgment Type

Judgment reserved.

1.5 Jurisdiction

Singapore

1.6 Description

G Krishnasamy Naidu was charged with murder. The defense argued diminished responsibility due to Delusional Disorder Jealous Type. The court rejected the defense.

1.7 Decision Date

2. Parties and Outcomes

Party NameRoleTypeOutcomeOutcome TypeCounsels
Public ProsecutorProsecutionGovernment AgencyJudgment for ProsecutionWon
Ng Cheng Thiam of Deputy Public Prosecutors
Chong Kah Wei of Deputy Public Prosecutors
G Krishnasamy NaiduDefendantIndividualConvicted of MurderLost

3. Judges

Judge NameTitleDelivered Judgment
Woo Bih LiJudgeYes

4. Counsels

Counsel NameOrganization
Ng Cheng ThiamDeputy Public Prosecutors
Chong Kah WeiDeputy Public Prosecutors
Peter FernandoLeo Fernando
Jeeva JoethyJoethy & Co

4. Facts

  1. Accused stabbed his wife on 8 April 2004 and was released on bail.
  2. Accused was subject to a Domestic Exclusion Order.
  3. Accused suspected his wife of having an affair with Ashok.
  4. Accused called his wife and Ashok multiple times daily.
  5. Accused checked his wife's mobile phone for messages.
  6. Accused confronted his wife about the suspected affair.
  7. Accused planned and executed the killing of his wife on 17 May 2004.

5. Formal Citations

  1. Public Prosecutor v G Krishnasamy Naidu, CC 8/2005, [2006] SGHC 64

6. Timeline

DateEvent
Accused and Chitra married.
Chitra had an extra-marital affair with Murugan.
Accused started work as a taxi driver.
Chitra had an extra-marital affair with Jayaseelan.
Accused hit Chitra with a bamboo pole and fractured her right wrist.
Accused brought Chitra to a private clinic for her abortion.
Jayaseelan returned to India.
Chitra applied for a Personal Protection Order from the Family Court.
Family Court issued a PPO against the accused by consent.
Chitra had an extra-marital affair with Anan.
Chitra made a police report regarding the beating with the bamboo pole.
Accused pleaded guilty to reduced charge and was sentenced to three months’ imprisonment.
Accused was released from prison.
Chitra and Ashok got to know each other.
Ashok took Chitra to the Indian Association.
Chitra went out with Ashok to the Indian Association for the second time.
Accused called Chitra on her mobile phone to tell her that he would be fetching her after work.
Accused stabbed Chitra.
Accused was charged in court and was remanded for psychiatric assessment at the Institute of Mental Health.
Accused’s case was mentioned in court and he was released on bail.
A domestic exclusion order was made preventing him from returning to the matrimonial flat.
Accused attacked Chitra with a chopper and killed her.

7. Legal Issues

  1. Diminished Responsibility
    • Outcome: The court rejected the defense of diminished responsibility.
    • Category: Substantive
    • Sub-Issues:
      • Abnormality of mind
      • Substantial impairment of mental responsibility
      • Causal link between abnormality and act
    • Related Cases:
      • [2005] 1 SLR 356
      • [1960] 2 QB 396
      • [2005] 4 SLR 536
      • [1967] 1 QB 175
      • [1998] 2 SLR 22
  2. Delusional Disorder Jealous Type
    • Outcome: The court found that while the accused exhibited characteristics of morbid jealousy, it did not substantially impair his mental responsibility.
    • Category: Substantive
    • Sub-Issues:
      • Existence of delusion
      • Impact on mental state
      • Causation of actions

8. Remedies Sought

  1. Criminal Prosecution
  2. Punishment under Section 302 of the Penal Code

9. Cause of Actions

  • Murder

10. Practice Areas

  • Criminal Law
  • Forensic Psychiatry

11. Industries

  • No industries specified

12. Cited Cases

Case NameCourtAffirmedCitationJurisdictionSignificance
Zailani bin Ahmad v PPCourt of AppealYes[2005] 1 SLR 356SingaporeReaffirmed the three limbs that an accused person has to satisfy to establish diminished responsibility.
Regina v ByrneQueen's BenchYes[1960] 2 QB 396England and WalesDefined 'abnormality of mind' as a state of mind so different from that of ordinary human beings that the reasonable man would term it abnormal.
PP v JuminemHigh CourtYes[2005] 4 SLR 536SingaporeDiscussed the meaning of 'substantially impairs his mental responsibility' in the context of diminished responsibility.
Regina v LloydQueen's BenchYes[1967] 1 QB 175England and WalesExplained the meaning of 'substantial' in the context of 'substantially impaired mental responsibility'.
Chua Hwa Soon Jimmy v PPCourt of AppealYes[1998] 2 SLR 22SingaporeDiscussed the distinction between 'did not resist his impulse' and 'could not resist his impulse' in the context of diminished responsibility.

13. Applicable Rules

Rule Name
No applicable rules

14. Applicable Statutes

Statute NameJurisdiction
Section 302 of the Penal CodeSingapore
Section 300 Exception 7 Penal Code (Cap 224, 1985 Rev Ed)Singapore
Sections 300 (a) and (c) of the Penal Code (Cap 224, 1985 Rev Ed)Singapore

15. Key Terms and Keywords

15.1 Key Terms

  • Diminished responsibility
  • Delusional disorder
  • Morbid jealousy
  • Abnormality of mind
  • Substantial impairment
  • Infidelity
  • Personal Protection Order
  • Domestic Exclusion Order

15.2 Keywords

  • Murder
  • Diminished Responsibility
  • Delusional Disorder
  • Morbid Jealousy
  • Mental Illness
  • Singapore
  • Criminal Law

17. Areas of Law

Area NameRelevance Score
Diminished Responsibility90
Morbid Jealousy85
Criminal Law75
Mental Capacity60
Criminal Procedure30
Family Law25

16. Subjects

  • Criminal Law
  • Mental Health
  • Forensic Psychiatry