The Patna High Court on Monday overturned the conviction of a Rohtas man who had been sentenced to more than three years in prison for allegedly abetting his wife’s suicide, holding that the prosecution failed to show any clear act of instigation or cruelty. The court noted that suspicion and emotional narratives, howsoever tragic, cannot replace proof in criminal law.
Background
The case arose from the death of Neha Kumari in June 2023 at her matrimonial home in Chenari, Rohtas district. Her father lodged a complaint accusing her husband, Nanhak Rai, of killing her over disputes related to livelihood and alleged dowry issues. An FIR was registered initially for dowry death and murder.
During trial, however, the Sessions Court acquitted Rai of murder and dowry death charges but convicted him under Section 306 of the IPC for abetment of suicide, sentencing him to three years and six months’ simple imprisonment along with a fine.
Rai challenged this conviction before the High Court, arguing that there was no evidence to show he drove his wife to take her own life.
Court’s Observations
Justice Alok Kumar Pandey, after a detailed examination of witness testimonies and medical evidence, found the prosecution story riddled with inconsistencies. The court pointed out that the father of the deceased had repeatedly improved his version during trial, making allegations that did not appear in his original complaint.
The bench noted that even the informant admitted in cross-examination that villagers were saying Neha had hanged herself. Crucially, he also conceded that no dowry demand was made at the time of marriage. “No act of instigation was attributed to the appellant,” the court observed, adding that emotional distress alone cannot be equated with legal abetment.
Medical evidence further weakened the prosecution’s case. The post-mortem report clearly stated that the cause of death was asphyxia due to hanging, with no signs of physical violence. The investigating officer also admitted that no witness spoke of cruelty, assault, or dowry demand.
Addressing the trial court’s reasoning that Neha took the extreme step because her husband refused to go outside the village for work, the High Court was blunt. The bench observed that disagreement over livelihood decisions, without more, cannot amount to abetment. “There was no evidence of any positive act which left the deceased with no other option but to commit suicide,” the judgment noted.
Relying on multiple Supreme Court rulings, the court reiterated that for a conviction under Section 306 IPC, there must be a clear intention and active role in provoking or aiding the suicide. Mere marital discord or poverty cannot fill that legal gap.
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Decision
Allowing the appeal, the Patna High Court set aside the conviction and sentence, holding that the prosecution failed to prove its case beyond reasonable doubt. The court ordered the immediate release of Nanhak Rai from custody, unless required in any other case.
Case Title: Nanhak Rai vs The State of Bihar
Case No.: Criminal Appeal (SJ) No. 3685 of 2025
Case Type: Criminal Appeal (Abetment of Suicide – Section 306 IPC)
Decision Date: 22 December 2025
