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SC Acquits Four in Postal Employee’s Suicide Case, Says Suicide Note Alone Not Enough for Conviction
In a landmark ruling, the Supreme Court of India acquitted four individuals accused of abetting the suicide of postal employee Dashrathbhal Parmar, emphasizing that a suicide note alone is insufficient for conviction without clear evidence of direct incitement. The bench, comprising Justices Abhay S. Oka and Ujjal Bhuyan, set aside the Gujarat High Court’s 2013 ruling and the trial court’s 2011 conviction, underscoring that mere allegations of harassment without a proven intent to instigate suicide do not meet the criteria for abetment under Section 306 IPC.
Case Background
Parmar allegedly took his own life in April 2009 by consuming poison at his home in Mehsana, Gujarat. Nearly 20 days later, his wife lodged a complaint accusing a woman named Geetaben and her relatives of blackmailing him using secretly recorded intimate videos, which she claimed led to his suicide. The prosecution argued that he was extorted for money and jewelry, and a suicide note—found much later in his brother’s possession—blamed the accused. The trial court convicted them in 2011, and the High Court upheld the verdict in 2013, leading to the appeal before the Supreme Court.
SC’s Key Findings
1. Suicide Note’s Credibility in Doubt – The note surfaced only after 20 days and was never recovered by the police, raising serious authenticity concerns.
2. No Direct Evidence of Abetment – There was no recent provocation or coercion directly linked to the suicide.
3. Unverified Extortion Claims – No money, jewelry, or blackmail material was recovered from the accused.
4. Contradictory Witness Testimonies – Key witnesses, including the deceased’s brother, gave inconsistent statements and later denied knowledge of blackmail.
5. Lack of Proof Regarding Poison Procurement – The police failed to establish how the deceased obtained the poison.
6. No 'Proximate Instigation’ – The Court ruled that past disputes or strained relations do not amount to abetment unless there is clear and immediate provocation leading to suicide.
Verdict
Setting aside the conviction, the Supreme Court reaffirmed that criminal liability for abetment requires direct and active encouragement to commit suicide. Since the prosecution failed to establish this link beyond reasonable doubt, all four accused were acquitted.
