The Madhya Pradesh High Court has upheld the discharge of the chairman of a private medical college and its Head of Department in a case arising from the death of an MD student, holding that a dispute over fees and administrative decisions, by themselves, did not satisfy the legal requirements for a charge of abetment of suicide.
Justice Jai Kumar Pillai dismissed the State's criminal revision petition, finding no reason to interfere with the trial court's order that had discharged the accused under Section 306 read with Section 34 of the Indian Penal Code (IPC).
Background of the Case
The case originated after the death of an MD student of Index Medical College, Indore, in June 2018. According to the prosecution, the deceased left behind a suicide note alleging that excessive fee demands and alleged harassment by the college management and the Head of Department had driven her to take the extreme step.
An FIR was later registered against Suresh Bhadoriya and Dr. K.K. Khan under Section 306/34 IPC. The prosecution relied mainly on the suicide note and witness statements to argue that the accused had continuously harassed the student by demanding additional fees beyond the prescribed amount.
However, in November 2022, the Sessions Court discharged both accused, prompting the State to challenge that order before the High Court.
Arguments Before the High Court
The State contended that the trial court had ignored crucial material, particularly the suicide note, in which the deceased attributed responsibility for her death to the college chairman, the management, and the HOD. It also argued that the student had previously challenged the fee demand through a writ petition, showing that the alleged harassment had continued over a period of time.
The respondents, on the other hand, argued that administrative decisions relating to fees, leave, and academic management could not automatically amount to criminal abetment. They submitted that there was no evidence of intentional instigation or any direct act aimed at compelling the deceased to end her life.
Court's Observations
Justice Jai Kumar Pillai noted that the law on abetment of suicide is well settled and requires proof of a direct and proximate act coupled with the necessary criminal intent.
Referring to Supreme Court precedents, the Court observed,
"There must be proof of direct or indirect act(s) of incitement to the commission of suicide," adding that mere allegations of harassment are insufficient unless they are closely connected with the decision to end one's life.
The Court further examined the evidence considered by the trial court. It noted that the suicide note referred to multiple circumstances, while witness statements and call records suggested the deceased was also facing personal difficulties, including issues in her relationship. The Court also recorded that there were discrepancies regarding the recovery of the suicide note and shortcomings in the investigation.
The Bench observed that the dispute over fee enhancement was already the subject of a pending writ petition in which interim protection had been granted to the deceased and other students. It held that disagreements concerning fees, stipends or leave, without evidence of a direct and intentional act to drive a person to suicide, could not satisfy the legal ingredients of Section 306 IPC.
As the Court observed,
"Institutional friction regarding fee hikes, stipends, and leaves, entirely devoid of any malicious intent to cause death, fails to satisfy this stringent legal test."
Court's Decision
After independently examining the material on record, the High Court concluded that the prosecution had failed to establish the essential ingredients required to frame a charge of abetment of suicide.
Holding that the allegations primarily reflected civil and administrative disputes rather than evidence of direct instigation, the Court found the trial court's discharge order to be legally justified.
It ruled that no jurisdictional error or legal infirmity warranted interference in revision and, accordingly, dismissed the State's criminal revision petition.
Case Details
- Case Title: State of Madhya Pradesh v. Suresh Bhadoriya and Others
- Case Number: Criminal Revision No. 2586 of 2024
- Judge: Justice Jai Kumar Pillai
- Decision Date: 22 July 2026
