Mental Health An Integral Component Of Right To Life: Supreme Court Transfers Case Involving Alleged Suicidal Death Of NEET Student At Hostel To CBI
|The Supreme Court remarked that there remains a legislative and regulatory vacuum in the country with respect to a unified, enforceable framework for suicide prevention of students in educational institutions, coaching centres, and student-centric environments.
The Supreme Court has transferred a case to the Central Bureau of Investigation (CBI), involving the alleged suicidal death of a 17-year-old female student at a hostel in Vishakhapatnam, Andhra Pradesh, who was preparing for the National Eligibility-cum-Entrance Test (NEET) examination.
The Court also emphasised upon the right to mental health under Article 21 of the Constitution.
A Criminal Appeal was preferred by the father of the deceased student, challenging the Judgment of the Andhra Pradesh High Court, which rejected his prayer seeking transfer of investigation to the CBI.
The two-Judge Bench comprising Justice Vikram Nath and Justice Sandeep Mehta held, “Mental health is an integral component of the right to life under Article 21 of the Constitution of India. This Court has, in a consistent line of precedents, affirmed that the right to life does not mean mere animal existence, but a life of dignity, autonomy, and well-being. Mental health is central to this vision. … this Court recognised mental integrity, psychological autonomy, and freedom from degrading treatment as essential facets of human dignity under Article 21 of the Constitution of India.”
The Bench remarked that despite the constitutional and international obligations, there remains a legislative and regulatory vacuum in the country with respect to a unified, enforceable framework for suicide prevention of students in educational institutions, coaching centres, and student-centric environments.
Advocate Joydeb B. Saha represented the Appellant while ASG Rajkumar Bhaskar Thakare represented the Respondents.
Facts of the Case
The Appellant resided in West Bengal with his family and in May 2022, his 17-year-old daughter took admission at a coaching institute namely Aakash Byju’s Class in Vishakhapatnam, A.P. to prepare for the NEET exam. She got a rented residential accommodation in Sadhana Ladies Hostel on the recommendation of Aakash Institute and took admission into Achiever’s Junior College for Class XII studies, concurrently pursuing her NEET preparation. In July 2023, at around 11:54 p.m., the Appellant received a phone call from the Assistant Branch Manager (Operations) of Aakash Institute, informing that his daughter had fallen from the 3rd floor of the hostel’s building at about 10:20 p.m. and had sustained severe injuries and taken to the hospital. The Appellant immediately called his daughter’s friend, who informed him that all the students had been locked inside a room and that she couldn’t tell what exactly happened.
The Appellant’s friend who hailed from Vishakhapatnam, visited the hospital and found his daughter conscious and talking. The Appellant immediately took the first available flight and reached, where he found his daughter unconscious and on ventilator support. The hospital’s management told him that his daughter suffered a heart attack but could not receive proper treatment due to the unavailability of a specialist medical faculty and hence, was placed on a ventilator. Being dissatisfied with the care and medical treatment, he shifted his daughter to another hospital for better treatment. However, while undergoing medical treatment, she passed away. Hence, an FIR was registered and being aggrieved by the suspicious circumstances, the Appellant approached the High Court, which disposed of his Writ Petition. He then lodged an FIR under Sections 302 and 120 of the Indian Penal Code, 1860 (IPC) against Aakash Institute, Sadhana Hostel, Venkataramana Hospital, and others. Thereafter, he filed a second Writ Petition seeking transfer of investigation of the case to the CBI, but the same was rejected. This was under challenge before the Apex Court.
Court’s Observations
The Supreme Court in the above regard, observed, “As articulated by numerous philosophers across history, the purpose of education was never confined to mere academic success or professional advancement. Rather, education was envisioned as a means for holistic development, intellectual, emotional, ethical, and spiritual. Jean-Jacques Rousseau, in his prominent treatise “Émile, or On Education”3, emphasised that education must be adapted to the developmental needs of the child and should cultivate reason, autonomy, and emotional well-being. He warned against an educational system that neglects the individuality of the learner in pursuit of rigid societal expectations.”
The Court said that education is meant to liberate, not burden the learner, and that its true success lies not in grades or rankings but in the holistic growth of a human being capable of living with dignity, confidence, and purpose.
“… the contemporary academic framework, particularly in the context of competitive examination systems, often subjects students to relentless psychological pressure. The very soul of education appears to have been distorted. Increasingly, education is perceived as a high-stakes race, a pressure-laden path toward narrowly defined goals of achievement, status, and economic security. The joy of learning has been replaced by anxiety over rankings, results, and relentless performance metrics. Students, especially those preparing for competitive examinations, are often caught in a web that rewards conformity over curiosity, output over understanding, and endurance over well-being”, it added.
Growing Crisis of Student Suicides
The Court noted that life becomes a series of tests, and failure is seen not as a part of growth but as a devastating end and in a system driven by performance metrics, competition, and institutional rigidity, students are often subjected to immense psychological strain, particularly in environments geared towards examinations.
“These young individuals, often far away from home, isolated in demanding academic environments, find themselves without adequate emotional or institutional support. The culture of silence around mental health, coupled with insufficient safeguards in educational institutions, exacerbates their vulnerability. The gravity of this crisis cannot be overstated, and any incident involving the death of a student under such circumstances warrants the utmost seriousness, not just as an isolated tragedy, but as part of a larger systemic malaise that threatens the future of the young generation”, it further remarked.
The Court was of the view that the present case must not be viewed in isolation, but rather in the context of this deepening crisis and while the legal and factual question s concerns the unnatural/suicide death of a student, the broader social context in which such cases of suicide occur cannot be ignored.
“The foregoing facts and circumstances, including the glaring inconsistencies in the medical records, the autopsy report indicating suspicious contents of stomach despite the deceased allegedly being on ventilatory support, the unexplained lapses in seizure and preservation of critical forensic evidence, and the contradictory statements by authorities, collectively highlight a case of exceptional complexity and concern. These elements are not indicative of mere procedural irregularities but point towards a potentially deeper malaise in the investigational process. In such a situation, it becomes imperative to ensure that the sanctity of the administration of justice is preserved, and public confidence is upheld”, it observed.
Coming back to the facts of the case, the Court said that criminal investigation must, in all circumstances, be both fair and effective to uphold the rule of law and it is in these rare and extraordinary circumstances that the intervention of the Court is warranted, and the transfer of the investigation to the CBI becomes not only justified but essential.
“In light of the constant and deliberate non-cooperation by the local authorities, contradictory public statements by police officials, and allegations of suppression of material evidence, this Court is of the considered view that the investigation into the unnatural death of Ms. X has to be entrusted to the CBI. Such a transfer is necessary not only to ensure a comprehensive and impartial investigation but also to restore public confidence and address the legitimate concerns of the bereaved family, and ultimately, to ensure that the actual perpetrators of the crime, if any, are brought to justice”, it added.
Right to Mental Health
The Court emphasised that given the pressing nature of the crisis, particularly in cities like Kota, Jaipur, Sikar, Vishakhapatnam, Hyderabad, and Delhi (NCR), etc., where students migrate in large numbers for competitive examinations and face intense psychological pressure, immediate interim safeguards are the call of the day.
The Court also noted that under International Law, India’s obligations under various human rights instruments and treaties reinforce the constitutional imperative to protect and promote mental health.
“The International Covenant on Economic, Social and Cultural Rights, to which India is a State Party, under Article 12 recognises the right to the highest attainable standard of physical and mental health. The United Nations Committee on Economic, Social and Cultural Rights, in its General Comment No. 14, has affirmed that this right includes timely access to mental health services and prevention of mental illness, including suicide”, it said.
The Court remarked that the evolving international norms reinforce the view that suicide prevention is not merely a policy objective but a binding obligation flowing from the right to life, health, and human dignity.
Conclusion
The Court, therefore, directed that the investigation into the unnatural death of the Appellant’s daughter shall be transferred to the CBI forthwith and the Investigating Officer and concerned authorities shall hand over the entire case records, including all relevant papers, documents, CCTV footage, forensic reports, and any material evidence, to the office of Director, CBI without undue delay.
“The Director, CBI, shall ensure the immediate registration of an RC and assign the investigation of the same to a team of competent officials under the supervision of the jurisdictional Superintendent, CBI. … The concerned officials of CBI shall conduct an extensive and comprehensive investigation into the matter and, upon conclusion, submit a report under Section 193(2) of the Bharatiya Nagarik Suraksha Sanhita, 202323, before the competent Court having jurisdiction, within four months from the date of receiving the record”, it concluded.
Accordingly, the Apex Court disposed of the Appeal and transferred the case to the CBI.
Cause Title- Sukdeb Saha v. The State of Andhra Pradesh & Ors. (Neutral Citation: 2025 INSC 893)
Appearance:
Appellant: Advocates Joydeb B. Saha, Ayush Mittal, Oshin Maggu, Zazib Siddiqui, Gurrick Jassar, and Nb V Srinivasa Reddy.
Respondents: ASG Rajkumar Bhaskar Thakare, AORs Mukesh Kumar Maroria, Guntur Pramod Kumar, Sravan Kumar Karanam, Y. Raja Gopala Rao, Pulkit Agarwal, Abid Ali Beeran P, Anand Varma, Kunal Mimani, Advocates Vivek Gupta, Rohit Khare, Padmesh Mishra, Merusagar Samantaray, Tanmay Mehta, Prerna Singh, Dhruv Yadav, P. Santhosh Kumar, Abhiram Bannur, Dhuli Gopi Krishna, Akshay Singh, Sanjana Jain, Pranav Proothi, Manasi Chatpalliwar, M Srinivas R Rao, Saswat Adhyapak, Namita Kumari, Ayush Gupta, and Abhinav Rana.