In a landmark ruling on March 5, 2025, the Supreme Court overturned the conviction of four individuals accused of abetting suicide under Section 306 IPC. The case involved allegations that the accused blackmailed the deceased using compromising photographs and videos. The Court, however, clarified that a suicide note alone cannot establish guilt unless the prosecution provides clear evidence of instigation, conspiracy, or intentional aid leading to the act.
The judgment emphasized that abetment to suicide requires a deliberate mental process of instigation or assistance. The prosecution must prove that the accused actively instigated, conspired, or aided the deceased with clear intent to abet suicide. Mere harassment or disputes are insufficient to sustain a conviction.
The Court also addressed the admissibility of a suicide note as primary evidence. It ruled that such a note must be corroborated by other evidence to establish abetment. Without forensic authentication, including an expert handwriting analysis presented in court, reliance on the note alone is unjustified.
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The case involved the conviction of four individuals by the Additional Sessions Judge, Mehsana. The prosecution argued that the deceased, an employee, was blackmailed using explicit photographs and videos. The deceased left a suicide note naming the accused. However, the appellants contended that there was no direct evidence of abetment, and the alleged blackmailing was unsubstantiated. They also pointed out that the suicide note surfaced 20 days after the incident, raising doubts about its authenticity.
The Supreme Court found merit in the defense's arguments and relied on precedents such as Ramesh Kumar v. State of Chhattisgarh (2001) 9 SCC 618, which established that instigation requires direct provocation. The Court also referenced Keshav Dutt v. State of Haryana (2010) 9 SCC 286, which held that expert handwriting analysis must be corroborated by additional evidence.
Several inconsistencies weakened the prosecution's case, including a 20-day delay in reporting the suicide note, the absence of forensic verification, and the lack of recovery of any blackmail material. Additionally, the deceased was under stress due to a financial misconduct case at work, which could have contributed to his decision to take his life.
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After reviewing the evidence, the Supreme Court ruled that since the prosecution failed to prove a proximate act of instigation or blackmailing, and due to significant lapses in the investigation, the conviction under Section 306 IPC could not be upheld. The Court, therefore, allowed the appeal, acquitting the accused and setting aside their convictions.
This ruling reinforces the importance of strong, direct evidence in cases of abetment to suicide. It underscores the necessity of thorough investigations, forensic authentication of evidence, and the establishment of a direct causal link between the accused's actions and the suicide. The decision serves as a precedent ensuring that convictions under Section 306 IPC are based on concrete proof rather than circumstantial or unverified allegations.
Case Title: Patel Babubhai Manohardas & Ors. v. State of Gujarat
Bench: Justices Abhay S. Oka and Ujjal Bhuyan
Date of Judgment: March 5, 2025
Representation:
- For Appellants: Mr. Rajiv Kumar, Adv., Mr. Sanjeev Gupta, Adv., Mr. Bhanu Kapoor, Adv.
- For Respondents: Ms. Deepanwita Priyanka, Adv., Ms. Swati Ghildiyal, Adv., Ms. Devyani Bhatt, Adv.
