"Was There Anything More Sinister?": SC Quashes Suicide Abetment Case; Orders Reinvestigation By SIT
The Supreme Court reiterated the alleged harassment meted out should have left a victim with no other alternative but to put an end to their life to prove allegations of abetment of suicide.
While questioning whether there was anything more sinister to the circumstances of an alleged suicide by a girl, the Supreme Court has directed the Director General of Police, Uttar Pradesh to constitute a Special Investigation Team (SIT) to reinvestigate the unnatural death.
The Directions came from the Judgment by the Court hearing an Appeal under Section 482 of the CrPC challenging the decision of the Allahabad High Court which declined to quash the proceedings instituted against the Appellants under Section 306 of the IPC. The Court allowed the Appeal and quashed the criminal proceedings against the Appellants.
A Bench of CJI Sanjiv Khanna, Justice Sanjay Kumar, and Justice KV Viswanathan observed, “We are today left with the one sided version of the complainant R-2. Was there anything more sinister? Even if it was suicide what was the real cause? Was the deceased Tanu distraught with what happened to her friend Ziaul Rahman? Considering the under-currents and the disapproval of the relationship, was there any instigation for the suicide from any other quarter? Did the deceased Tanu resort to the extreme action of taking away her own life due to the ugly turn of the events and due to the fact that her family members were suspected to be involved? We have no answers today.”
AOR Bhuwan Raj represented the Appellant, while Advocate Prerna Dhall appeared for the Respondent.
Brief Facts
The prosecution alleged that one Ziaul Rahman, son of the first Appellant was allegedly beaten to death by relatives of the girl over suspicions regarding his relationship with her. The first Appellant lodged an FIR leading to a charge sheet under Section 304 IPC against the accused.
The very next day, a second FIR was filed against the Appellants, accusing them of abetting the suicide of the girl under Section 306 of the IPC. The complainant alleged that on the morning of November 2, 2022, the Appellants had confronted the girl, blaming her for Rahman’s death and threatening legal action. The FIR claimed that due to this humiliation, the girl committed suicide the same day.
Court’s Reasoning
However, the Supreme Court noted that records showed that the girl’s body was already in the hospital mortuary by the time the Appellant’s FIR was lodged, raising questions about the sequence of events.
“It is intriguing that the police authorities, merely by recording the statements of the complainant Vijay, Sunesh W/o Janeshwar and Sushil who have simply parroted the contents of the FIR, proceeded to file the chargesheet against the appellants. On our repeated queries to the counsel for the State as to whether any investigation to explore any other angle was pursued, we were met only with a stoic silence,” the Bench remarked.
Expressing dissatisfaction with the handling of the case, the Court stated, “Only an independent, thorough and comprehensive investigation will bring to light the true story. The charge-sheet, as it stands, appears to have proceeded in an unidimensional manner by accepting the version of the complainant (R-2) and his family members as the gospel truth.”
Consequently, the Court held that based on the the charge-sheet filed by the police and the “cryptic order of cognizance”, the proceedings against the Appellants cannot be allowed to be carried on. “Even taking the allegation on a demurrer, on the facts of the case, an offence under Section 306 IPC cannot be said to be made out against the appellants. The law on Section 306 IPC is well settled,” it held.
The Supreme Court directed the constitution of an SIT led by a Deputy Inspector General (DIG) to reinvestigate the unnatural death of the girl.
The SIT has been granted the discretion to treat the case as an unnatural death and re-register an FIR if necessary. The Court has ordered the SIT to submit a sealed report within two months.
Accordingly, the Supreme Court allowed the Appeal.
Cause Title: Ayyub & Ors. v. State Of Uttar Pradesh & Anr. (Neutral Citation: 2025 INSC 168)
Appearance:
Appellant: AOR Bhuwan Raj; Advocates Raman Singh, Manju Savita and Niraj Dubey
Respondent: Advocates Preeti Goel, Mukesh Kumar, Srikant Singh, Akash, Varnit Sharma, Suraj Pal Singh, Amit Sangwan, Ashu Bhindwar, Sneha Chandna, Varun Singh and Vikram Pratap Singh; AOR Vishwa Pal Singh and Divyesh Pratap Singh
