Supreme Court Quashes Criminal Proceedings in Suicide Case, Citing Lack of Abetment
In a significant ruling, the Supreme Court of India has quashed criminal proceedings under Section 306 of the IPC against seven individuals accused in a suicide case, observing that mere insult or abusive language, without a direct or proximate act of instigation, cannot amount to abetment of suicide.
The judgment, delivered by a Bench comprising Justices Abhay S. Oka and Augustine George Masih in Criminal Appeals Nos. 4268-4269 of 2024, overturned a 2018 Madras High Court decision that had refused to quash the charges.
Background
The case stemmed from the tragic suicide of Dinesh, who had married Pushpakalashree (Accused No. 7) in September 2013. Following marital discord, on November 10, 2013, Pushpakalashree’s relatives (Accused Nos. 1 to 6) allegedly visited Dinesh’s home, insulted him—reportedly calling him impotent—and took Pushpakalashree back to her parental home. They also allegedly threatened to file a dowry case.
A month later, on December 9, 2013, Dinesh took his life. Initially treated as a case under Section 174 CrPC, it was later converted to a Section 306 IPC matter based on torn diary pages said to contain a suicide note. A chargesheet was filed, and trial proceedings were initiated as S.C. No. 9 of 2016.
Arguments Before the Court
The appellants argued that the suicide note lacked a date, had not been forensically verified as Dinesh’s handwriting, and referred only to a single incident a month prior—too distant to be considered direct provocation. Citing key judgments such as Mahendra Singh v. State of M.P. and S.S. Chheena v. Vijay Kumar Mahajan, they contended the legal essentials of abetment were missing.
The prosecution, however, maintained that the suicide note narrated a sequence of harassment and warranted a full trial.
Supreme Court's Observations
The Bench found that only four individuals were mentioned in the suicide note and that the core issue appeared to be the breakdown of the marriage. It emphasized that the only incident of alleged harassment was too remote in time to be considered instigation.
“There is no proximity of any harassment or instigation prior to the suicide... From the suicide note, no abetment can be said to have been established,” the Court stated.
Citing precedents like M. Arjunan v. State and Ude Singh v. State of Haryana, the Court reiterated that abetment under Section 306 IPC must involve a clear intention to instigate or aid the act of suicide.
Final Verdict
The Court concluded that continuing the criminal trial in the absence of essential ingredients of the offence would amount to an abuse of the judicial process.
“With the very element of abetment conspicuously absent… the continuation of the criminal proceedings initiated against the Appellants would amount to an abuse of the process of law,” the Bench ruled.
The appeals were allowed, the 2018 Madras High Court order was set aside, and the pending trial before the Assistant Sessions Judge, Kanchipuram, was quashed.
