CC BY
19UDC: 347.44 (042)(575.1)
Usmonova Muniskhon
Lecturer of the Department of Civil Law, Tashkent State University of Law E-mail: asinum57@gmail.com
THE ROLE OF FORENSIC PSYCHIATRIC EXAMINATION IN INVALIDATING AN AGREEMENT ENTERED INTO BY A CITIZEN WHO DOES NOT UNDERSTAND THE SIGNIFICANCE OF HIS ACTIONS OR IS UNABLE TO CONTROL THEM
Ab&ract. This article deals with those who do not underhand the importance of their actions, which are relevant to the science and practice of modern civil law, and those who can not underhand and manage them, and the issues of their validity and invalidity, the appointment of forensic psychiatric examination and different approaches of scientitis in this regard are analyzed. It also outlines what to look for when determining whether a person understands the importance of their actions at the time of concluding a transaction, whether they can control or manage their actions, a liti of questions to be asked by an expert to cover the issue, and more. The article also examines the invalidity of civil law agreements and their types, as well as the problems that exiti in practice in this regard. In addition, it briefly discusses the invalidity of civil law agreements, the relationship between absolutely invalid transactions and disputed transactions, the legal consequences of invalid transactions, the application of restitution when the agreement is invalid, the joint liability of the parties to the agreement.
Keywords: disputed agreements, invalidation of agreements concluded by persons who do not undertiand or manage the significance of their actions, persons who do not undertiand or manage the significance of their actions, forensic psychological examination, forensic psychiatric examination.
Усмонова Мунисхон
"Фу^аролик ^у^у^и" кафедраси у^итувчиси, Тошкент давлат юридик университети
УЗ ХДРАКАТЛАРИНИНГ ахамиятини тушунмайдиган ёки уларни
БОШЦАРОЛМАЙДИГАН ФУ^АРО ТОМОНИДАН ТУЗИЛГАН БИТИМНИ ХДЦЩИЙ ЭМАС ДЕБ ТОПИШДА СУД-ПСИХИАТРИЯ ЭКСПЕРТИЗАСИНИНГ АХДМИЯТИ
Аннотация. Мазкур мацолада замонавий цивилистика фани ва амалиёти учун долзарб ауамиятга эга булган уз уаракатларининг ауамиятини тушуна олмайдиган ёки уларни бошцара олмайдиган шахс-лар деганда кимлар тушунилиши лозимлиги ва улар томонидан тузилган битимларни уациций ёки уациций эмас деб топиш масалалари, асос ва оцибатлари, суд жараёнида суд-психиатрия экспертиза-сининг тайинланиши ва бу борадаги олимларнинг турли хил ёндашувлари таулил цилинади. Шунингдек, шахс битимни тузаётган пайтда уз уаракатларининг ауамиятини тушунганлиги ёки англаб етмаган-лиги, уз уаракатларини бошцара олганлиги ёхуд идора цила олмаганлиги каби масалаларни аницлашда цандай жиуатларга эътибор царатиш лозимлиги, бунда эксперт томонидан масалани ёритиш учун бериладиган саволлар руйхати ва бошца шунга доир масалалар ёритилган. Шу билан бир цаторда мацолада Фуцаролик ууцуцига оид битимларнинг уациций эмаслиги ва уларнинг турлари, бу хусусда
амалиётда мавжуд муаммолар щм урганилади. Мацолада фуцаролик-ууцуций битимларнинг щциций эмаслиги, мутлац щциций саналмайдиган битимлар ва низоли битимларнинг узаро нисбати, уациций саналмайдиган битимларнинг ууцуций оцибатлари, битим уациций эмас деб топилганда реституция-нинг цулланилиши, битим тузувчиларнинг битим уациций эмас деб топилганда солидар жавобгарлиги масалаларига %ам цисцача тухталиб утилган.
Калит сузлар: низоли битимлар, уз щракатларининг ащмиятини тушуна олмайдиган ёки уларни бошцара олмайдиган шахслар томонидан тузилган битимларни уациций эмас деб топиш, суд-психологик экспертизаси, суд-психиатрик экспертизаси.
Усмонова Мунисхон
преподаватель кафедры «Гражданское право» Ташкентского государственного юридического университета
РОЛЬ СУДЕБНО-ПСИХИАТРИЧЕСКОЙ ЭКСПЕРТИЗЫ В ПРИЗНАНИИ
НЕДЕЙСТВИТЕЛЬНОЙ СДЕЛКИ, ЗАКЛЮЧЕННОЙ ГРАЖДАНИНОМ, КОТОРЫЙ НЕ ПОНИМАЕТ ЗНАЧИМОСТИ СВОИХ ДЕЙСТВИЙ ИЛИ НЕ МОЖЕТ ИХ КОНТРОЛИРОВАТЬ
Аннотация. В данной статье рассматриваются аспекты действий лица, которое не понимает важности этих действий и не может управлять ими. Эти вопросы имеют отношение к науке и практике современной цивилистики. Также рассматриваются вопросы их обоснованности или недействительности, оснований и последствий, назначения судебно-психиатрической экспертизы. Проанализированы различные подходы ученых в этом отношении. Указано, на что обращать внимание при определении того, понимает ли человек важность своих действий во время заключения сделки, может ли он контролировать свои действия или управлять ими, список вопросов, которые должен задать эксперт, чтобы охватить проблему, и др. В статье также исследуются недействительность гражданско-правовых договоров и их видов, а также проблемы, существующие на практике в этом отношении. Рассмотрены недействительность гражданско-правовых сделок, взаимосвязь между абсолютно недействительными сделками и спорными сделками, правовые последствия недействительных сделок, применение реституции при признании договора недействительным, солидарная ответственность сторон договора.
Ключевые слова: спорные транзакции, признание недействительными соглашений, заключенных лицами, которые не понимают значимости своих действий, и лицами, которые не могут контролировать своих действий, судебно-психологическая экспертиза, судебно-психиатрическая экспертиза.
One of the mo& important in&itutions of civil law is treaties. As the market economy and social relations develop, the types of transactions concluded by individuals and legal entities are also increasing day by day.Today, along with traditional media, the Internet, social networks play a major role in shaping public opinion and the emergence of new social relationships [1]. Equipment and technology are being improved, and various agreements are being signed that are not mentioned in the Civil Code of the Republic of Uzbeki&an but do not contradict the law. Examples of this are verbal or written agreements, such as online shopping, fa& food delivery.
Agreements are actions aimed at e&ablishing, changing or revoking the civil rights and duties of citizens and legal entities. In turn, transactions
concluded by individuals and legal entities may or may not be considered valid. Transactions may be declared invalid on the following grounds:
a) illegality of the content;
b) the right of natural persons and legal entities concluding the transaction;
c) inconsi&ency of will and expression of free will;
g) non-compliance with the form of the agreement
[2, p. 118].
The issues ofinvalidity ofcivil law agreements, the relationship between absolutely invalid transactions and disputed agreements, the legal consequences of invalid transactions, the application of re&itution when the agreement is invalid, the joint liability of the parties to the agreement are also relevant from the point of view of modern civilization. In addition, the
analysis of the conditions for the actual enumeration of transactions, the definition of criteria for the classification of disputed transactions, the need to develop a uniform approach to the settlement of disputes and their consequences in law enforcement practice shows the relevance of this topic.
Today, in practice, disputes are very common, as can be seen from the &ati&ics on the official website of the Supreme Court of the Republic of Uzbeki&an. The analysis of case materials shows that the proportion of cases related to the invalidity of transactions in civil cases has increased significantly in recent years.If we look at the &ati&ics on the activities of civil courts in the fir& nine months of 2020, during the reporting period, these courts considered 138,962 lawsuits in the fir& in&ance, 60,282 applications for court orders, a total of 199,244 civil cases (382,560 in nine months of2020). Decisions were made on 120,081 civil cases, and court rulings were issued on 18,881 cases. The number of lawsuits was 98,080, which is 13,420 or 12% less than in the same period la& year (111,500 in the fir& nine months of 2020). Of the claims ordered by the court, 9,390 or 15.6 percent were based on a written agreement and were claims by the debtor [3]. However, no specific information has been provided or classified on how many cases have been considered on the invalidity of the exact transactions.
In court practice, there are many problems in finding invalid agreements made by a citizen who does not underhand the importance of his actions included in the disputed agreements or cannot manage them. The reason is that it is very difficult to prove in what condition the citizen entered into these agreements.
The following conditions mu& be met in order to invalidate transactions concluded by a citizen who does not underhand the significance of his actions or is unable to control them:
• at the time of concluding the transaction, the person mu& not be able to underhand the significance of his actions on a regular basis;
• the person mu& not be able to control his actions for a certain period of time at the time of concluding the transaction;
• the transaction mu^ have violated the rights or legally protected intere&s of the person;
• the rights and legally protected intere&s of third parties mu^ have been violated as a result of this agreement.
Although it can be treated as a transaction made by a citizen,since it is made by a person who is under some influence (e.g., hypnosis, psychotropic drugs) at the time of the transaction and unable to underhand or control their actions, the transaction is declared invalid by the court [4, p. 315]. In order to invalidate a transaction under Article 121 of the CC, a person muS not underhand the significance of his actions or be able to control them for a certain period of time. If this situation later becomes permanent, the citizen is declared incompetent or incapacitated by a court, and the agreements concluded by them are annulled in accordance with Articles 119-120 of the Civil Code.
Failure to underhand the importance of one's actions or to be able to control them can result from mood disorders, increased excitement, mood swings, physical injury or other illness, alcohol intoxication, and other causes. The task of proving the occurrence of such cases is assigned to a person who does not underhand the significance of his actions or is unable to control them, and the te&imony of witnesses is not sufficient to prove, to have supporting documents, if necessary, to appoint an expert [5, p.105]. By doing so, our laws do not seek to protect the rights and intere&s of those who are addicted to alcohol, but rather to warn that some of the citizens who have been under its influence for a certain period of time will be exploited.
Because transactions entered into without under&anding the significance of their actions or inability to control them con&itute conflicting transactions, a claim for invalidation of such transactions may be filed by the person who entered into such agreement or another person whose rights and legitimate intere&s were violated as a result of such agreement. For example, if one of the spouses has entered into an agreement to dispose of the joint property belonging to the couple, the spouse who did not participate in the agreement may file a lawsuit to annul the agreement. If a person who did not underhand the significance of his actions at the time of the transaction is subsequently declared incompetent, such a transaction may be declared invalid by a court in accordance with the claim made by the person's guardian.
Any transaction entered into by an individual without under&anding the significance of their actions or without being able to control their actions
may be declared invalid by the court on the grounds. In accordance with the principle of similarity of legislation (Article 5 CC), the provisions of Article 121 may also be applied to transactions concluded by legal entities. For example, a transaction entered into on behalf of a legal entity may be declared invalid by a court if the person authorized by the legal entity does not underhand or manage the significance of his actions as his body or representative.
It should be noted that the inability to underhand the importance of their actions or to be able to control them mu^ have occurred at the time of the transaction.
According to E.G. Shablova, there mu& be special grounds for the agreement not being valid. Given the exigence of such grounds, it is possible to group transactions that may be found to be invalid. One of them is the agreement concluded in case of violation of the requirements of the legal capacity of the parties. This includes transactions between citizens who have been declared incompetent due to mental illness, minors under the age of 14, minors between the ages of 14 and 18, or persons who have been declared incompetent or incapacitated by a court (RF CC 171, 172, 175, 176- sub^ances). This group also includes transactions concluded by persons with legal capacity, but at the time of the conclusion of the agreement, they may not underhand the significance of their actions or manage them (Article 177 of the Criminal Code of the Russian Federation). [6, p.66].
E.A.Suxanov mentions that in his view, such an agreement is controversial because, at the time of its conclusion, the capable citizen cannot govern himself; that is, he cannot consciously form his own will. The inability of a capable citizen to underhand the meaning of his or her actions or to control them may be due to a variety of circum&ances proven during the dispute review: nervous shock, physical injury, profound alcohol and drug use, and so on. An example of a deal made by a citizen who does not underhand the meaning of his actions is a deal that sells very expensive things in vain while intoxicated [7, p.245].
The current Civil Code provides for a three-year limitation period for invalid transactions, and the Civil Code of the Russian Federation (Article 181, Part 1 of the RF CC) provides for an extended limitation period for invalid transactions in contrat to disputed transactions. In addition, special rules for the application of the &atute of limitations for invalid transactions are clearly defined in the legislation
of some countries (for example, Article 181, Part 2 of the Civil Code of the Russian Federation and Article 162 of the Civil Code of the Republic of Kazakh&an).
Article 3 of the French Criminal Code uses the term "capacity", which means legal capacity.At the same time, the term also means the ability to enter into a contract. Article 488 of the French Civil Code reflects the norm that an adult citizen is capable of all actions of civil life. In judicial practice and the legal literature, legal capacity (capacite d.exercice) and legal capacity (capacite de jouissanse) are di&inguished.
Based on foreign experience, it would be expedient to introduce an extended claim period for the CC again& the agreements' invalidity. Therefore, it is necessary to include in the CC Article 1281 "Terms of claims on unreali&ic transactions," and its content should be worded as follows:
"Claims for the application of consequences of invalidity of transactions which are not inherently valid may be brought within ten years from the date of their execution.
Claims to invalidate a disputed transaction and to apply the consequences of its invalidity may be brought within one year from the date of termination of the violence or intimidation that led to the conclusion of the transaction or from the date when the plaintiff knew or should have known about other circum&ances.
Today, the courts effectively use various methods and tools e&ablished by law to solve exiting problems in the civil, criminal, admini&rative and economic courts. As science, technology, and technology advance, situations that are difficult to identify in the course of ju&ice are becoming clear. One such problem is that a court invalidates an agreement entered into by a citizen who is in a situation where he does not underhand the significance of his actions or cannot control them. In this case, the citizen mu& prove that the temporal mentality is not able to act in accordance with the requirements ofthe psychological &ate. In this complicated situation, the importance of expertise is very high.
Recently, the number of cases in the courts related to the invalidity of transactions has increased significantly. Objections to the concluded agreements and their annulment by the court became almo& epidemic [8, p. 12].
Who is meant by a citizen who does not underhand the importance of his actions or who cannot control them? According to V.L. Kharseeva,
if at the time of the transaction the person is in a &ate of severe mental digress, overly intoxicated, unable to consciously control his behavior, arousal of &rong passion and excitement, for example, anger, the transaction is a dispute under Russian law [9, p. 113].
A.P. Sergeev says that a person who is unable to control his actions is temporarily deprived of the opportunity to consciously express his will, even though he is considered to be capable of acting. The causes of this condition can be severe intoxication under the influence of alcohol and drugs, illness, temporary disorders of the human psyche and affective &ates. Such cases are called "actual incapacity" by some authors [10, p. 58].
According to the analysis, the characteri&ics of a citizen who does not underhand the importance of their actions or can not control them include those who have the ability to behave but temporarily lose this ability, are in a &ate of intense &ress or are under the influence of alcohol, drugs and other psychotropic sub&ances or hypnosis, in a &ate of effect, and so on. If the exigence of the li&ed grounds is proved, the concluded agreement shall be declared invalid by the court. An examination is required to prove it. The legislation of the country regulates the issue of forensic examination of invalidity oftransactions by the following normative legal acts: the Law of the Republic of Uzbeki&an "On forensic examination", the Code of Civil Procedure of the Republic of Uzbeki&an,Resolution of the Plenum of the Supreme Economic Court of the Republic of Uzbeki&an"On some issues arising in judicial practice in the appointment, conduct and evaluation of expert opinions in civil cases", as well as "On some issues of application of civil law by economic courts to invalidate transactions" Resolution of the Plenum of the Supreme Court of the Republic of Uzbeki&an "On some issues arising in the implementation of the legislation governing transactions in judicial practice" and "On some issues of an application by courts of the law on evidence in civil cases" decisions and so on.
In court practice today,while invalidating an agreement entered into by a citizen who does not underhand the significance of his actions or is unable to control them, it is sometimes necessary to conduct an expert examination of the case. However, in some cases, it is necessary to appoint an expert to identify
issues that do not require special knowledge or raise legal and other issues that are not within their competence. We can also observe that the types of examinations appointed and to be conducted by judges do not correspond to the circum&ances of the case, and that a ruling is issued for the wrong type of examination.
In cases where a court has appointed an expert, the judge mu& ask the expert the following que&ions: Did the person suffer from mental illness at the time of signing the agreement? If so, with what disease?
• In the presence of a mental disorder (illness), could this person be held accountable for his actions, i.e., his mental &ate?
• What is the nature of the current mental illness and how is it expected to develop in the future? Doesn't mental illness deprive the person under examination of the ability to be accountable for their actions or manage them?
• What medical precautions does this person need to take if they have a mental illness?
Depending on the nature of the case, other que&ions may be asked, such as the validity of previous findings, diagnoses of illness previously identified in psychiatric hospitals, the plaintiff's ability to present himself as ill, and so on. In practice, it is also common to ask que&ions incorrectly. For example, in the course of an expert examination appointed by a court as a result of a dispute over a will left by a citizen after his death, the court ruling raises the que&ion of his sanity before his death, not at the time of signing the will [11, p. 11]. In the diagnosis of cases of temporary impairment of mental activity, the expert determines the following: the nature of the situation, the circum&ances in which the condition occurred, the laws of manife&ation of the disease, and the specifics of the act.
Also, when assigning a form of expertise, which mu& be conducted to find out the invalidity of the transaction concluded by a citizen who does not underhand the significance of his actions or can not control themthere are also conflicts in the legislation. For example, the decision of the Plenum of the Supreme Court of the Republic of Uzbeki&an No. 17 of 22 December 2006 &ates that "in the event of a dispute over the invalidity of an agreement entered into by a citizen who does not underhand or control the significance of his actions, the courts
The decision of the Plenum of the Supreme Court of the Republic of Uzbeki&an No. 24 of December 12, 2008, &ates that a forensic psychiatric examination should be appointed in all cases when it is necessary to determine the mental &ate of a person at the time of committing a certain action.
In this regard, according to Yallaev,when there is a doubt about the mental &ate of one of the parties to the agreement and the need to resolve the issue of sanity (accountability and self-control), as well as his mental &ate, the correct under&anding of the circum&ances of the case and forensic psychiatric examination is required when there is doubt about the ability to give accurate infractions [11, p. 9].
In cases where it is necessary to determine the person's mental fate at the time of the commission of a particular action on the case, a forensic psychiatric examination is appointed. For example, in cases where a person is unable to underhand or control the significance ofhis actions at the time ofthe transaction, as well as in other cases where the law provides for the appointment of an expert, in particular, to declare a citizen incapacitated due to mental illness or mental retardation. An expert examination is appointed on the case of finding him fit for treatment as his health has significantly improved or recovered [12, p. 47]. This means that a forensic psychiatric examination, not a forensic psychological examination, should be ordered to invalidate a transaction in which a person is unable to underhand or control the significance of his or her actions as a result of di&urbances in the human psyche. In this regard, the decisions of the Plenum of the Supreme Court of the Republic of Uzbeki&an should be clarified.Because ifwe look at the practice of almo& many Commonwealth countries, in particular, Russia, Belarus, Latvia, Armenia, Kazakh&an, Kyrgyz&an, Azerbaijan, to determine the mental and volitional ability,we witness the appointment of a forensic psychiatric examination.
A forensic psychiatric examination is carried out mainly in the following types: outpatient examination, in-patient examination, during the trial, in absentia and po&-mortem examination. An outpatient examination is the mo& common type of forensic psychiatric examination in civil proceedings. Nearly 70 percent of all examinations are accounted for by the outpatient forensic psychiatric examinations that make the final decision. The outpatient forensic psychiatric examination has a number of advantages
and disadvantages. The main advantage is that the conclusion is obtained in a short time, quickly. The disadvantage is that in many cases, it does not address the nature (severity) and severity of mental disorders. Mo& often, such examinations are conducted in respect of persons who entered into a civil-legal relationship during alcohol intoxication. Po&-mortem examinations, on the other hand, are often conducted in civil cases involving disputes over pre-death wills and gift agreements.
Human voluntary behavior is generally regulated and controlled by the mind. Rights, obligations and responsibilities arise only when a person's actions are of a conscious nature. A person in a &ate of mental health can and mu& assess the situation in which his or her actions occur, underhand the requirements placed on him or her, and choose whether or not to sign the agreement. A person is considered sane if his mental &ate does not prevent him from making such a choice.
Temporary mental disorders are mental illnesses that la& for a certain period of time and end with complete recovery. These include reactive psychoses, alcoholic psychoses, and emergency (rare) conditions (pathological intoxication, pathological effect, pathological sleep conditions, etc.).
During the examination ofthe legal capacity of one of the parties to a bilateral agreement, it is important for the expert to determine whether there were mental disorders at the time of signing the agreement, how deeply this mental disorder is expressed, whether the person under&ands the significance of his actions [11, p. 35].
A forensic psychiatric examination shall be appointed in cases where it is necessary to determine the mental &ate of the person at the time of the commission of a particular action on the circum&ances of the case. For example, in cases where a person is unable to underhand or control the significance of his actions at the time of the transaction, as well as in other cases where the law provides for the appointment of an expert, in particular, to declare a citizen incapacitated due to mental illness or mental retardation] .An expert examination is appointed on the case of finding him fit for treatment as his health has significantly improved or recovered 11, p. 47].
Our normative legal acts related to the invalidity of transactions do not directly define the concept of a citizen (Article 121 Civil Code ) who does not
underhand the importance of his actions or is unable to control them. The concepts that form the basis of Articles 119-120, 122-125 of the Criminal Code are specifically addressed in the decisions of the Plenum of the Supreme Court of the Republic of Uzbeki&an, for example, mi&ake, deception, violence, intimidation, a malicious agreement between a representative of one party and the other party, a fraudulent agreement, an agreement for fraud, and so on.
Proposals to the decisions of the Plenum of the Supreme Court of the Republic of Uzbeki&an:
> «Replace the words «(psychological) examination» with the words «psychiatric examination» in paragraph 11 of the Resolution «On some issues arising in the implementation of the legislation governing the transactions in judicial practice»;
> The second part of paragraph 11 of the decision «On certain issues arising in the implementation of the law governing the transactions in judicial practice» should be interpreted as follows, and the second part should be considered as the third part: «The courts should be considered to have legal
capacity, but temporarily lo& legal capacity at the time of concluding the transaction. The causes of this condition may be: severe intoxication under the influence of alcohol and drugs, illness, temporary mental disorders and affective disorders»;
> «The decision of the economic courts on some issues of application of the norms of civil legislation on invalidation of transactions «should be supplemented with paragraph 121 and should be interpreted as follows: In the event that the authorized representative of the legal entity does not underhand the significance of his actions or is unable to manage them, the issue of invalidation of the agreement shall be considered in the civil court»;
> «The second part of paragraph 5 of the decision «On some issues arising in judicial practice in the appointment, conduct and evaluation of the expert opinion in civil cases» describes the forensic expert to have higher education as a forensic expert, in exceptional cases to have a secondary special education. It is not specified which cases should be assessed as exceptions. Exceptions should be made clear.
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