Supreme Court: In a criminal appeal challenging the judgment of the Karnataka High Court, wherein the Court confirmed the conviction of the appellant under Section 306 of the Penal Code, 1860 (‘IPC’), the Division Bench of BV Nagarathna and KV Viswanathan*, JJ. held that the evidence did not establish the ingredients of abetment to suicide. The Court observed that the quarrels between the appellant’s family and the victim’s family were in the nature of heated exchanges that occur in everyday life and could not be construed as instigation to such an extent that the victim was left with no option but to commit suicide. It therefore concluded that the appellant was not guilty of the offence under Section 306 IPC and acquitted her of the charge. The appeal was accordingly allowed; the judgment of the Karnataka High Court was set aside.
Background
The victim used to give tuition classes at her house and had complained that persistent noise from the appellant’s house disturbed her work. On several occasions, when she objected, the appellant abused her, called her derogatory names, questioned her unmarried status, and threatened her. On 10-08-2008, the appellant, along with her sisters, again abused the victim and her family. On 12-08-2008, around 8:00 p.m., the appellant and others allegedly stood in front of the victim’s house, hurled filthy abuses, assaulted her and her mother, and issued life threats. Deeply hurt and humiliated, the victim poured kerosene on herself later that night and set herself on fire. Her family and neighbours attempted to save her and rushed her to the Government Hospital, Bijapur, where she succumbed to her injuries on 02-09-2008.
The Trial Court had convicted the appellant for offences under Section 306 of the IPC as well as under Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 (‘SC/ST Act’). For the offence under Section 306 IPC, the Trial Court had imposed a sentence of five years’ imprisonment, whereas for the offence under Section 3(2)(v) of the SC/ST Act, it had imposed life imprisonment along with a fine of ₹5,000. In appeal, the High Court acquitted the appellant of the offence under Section 3(2)(v) of the SC/ST Act. As regards the conviction under Section 306 IPC, the High Court modified the sentence from five years to three years’ imprisonment, while maintaining the fine of ₹5,000 with a default sentence of six months in case of non-payment.
Analysis and Decision
From the judgment of the High Court, the Court noted that a minor dispute between the victim and the appellant, which had persisted for about six months, escalated on the fateful day. The victim, though educated and working as a private teacher, was unable to bear the constant harassment by the appellant and took the extreme step of committing suicide. The Court observed that the victim was a sensitive person and, lacking support against the appellant, who had the backing of her family, felt miserable and defeated, which impulsively drove her to suicide in a state of depression. It was further noted that the allegation of caste-based abuse was mentioned by the victim only after the incident and was not corroborated by most neighbours. The evidence instead suggested that the quarrels between the victim and the appellant arose primarily out of strained relations as immediate neighbours.
The Court noted that though the victim had alleged caste-based abuses, the evidence was insufficient, resulting in the acquittal of all five accused on that charge. The other four family members were also acquitted of the offence punishable under Section 306 IPC. The appellant herself was acquitted of the charges of being a member of an unlawful assembly, rioting, causing hurt, criminal intimidation, and intentional insult with intent to provoke breach of the peace. These acquittals, as well as the acquittal under the SC/ST Act, had attained finality.
The Court observed that the only question to be examined was whether, even taking the prosecution case at its highest, the conviction of the appellant under Section 306 IPC could be sustained. It framed the issue as whether the evidence against the appellant was of such a nature that the overt acts attributed to her had left the victim with no option but to commit suicide. The Court answered in the negative, stating that the evidence did not justify such a conclusion.
For examining whether the ingredients of Section 306 IPC were attracted, the Court proceeded based on the prosecution case taken at its highest. The record indicated that for several months there had been disputes between the victim and the appellant’s family. While the victim felt disturbed by noise during her tuition classes, the appellant’s family had grievances that their children were being scolded by the victim and her family. The evidence showed not only heated exchanges but also allegations of physical blows. However, the appellant stood acquitted of the offences punishable under Sections 323, 504 and 506 IPC, and the State had not preferred any appeal against those acquittals.
The Court then considered whether, even assuming that physical blows were administered, such acts by themselves could constitute abetment to suicide. Referring to Swamy Prahaladdas v. State of M.P., (1995) Supp (3) SCC 438, where the accused had told the deceased to “go and die” and the deceased thereafter committed suicide, the Court noted that such conduct had been held insufficient to sustain a conviction under Section 306 IPC.
Taking note of various precedents, the Court held that it was unable to accept the contention that the quarrels between the appellant’s family and the victim’s family reflected any intention to abet or cause the victim to take her own life. The Court observed that such heated exchanges were part of everyday life, and on the facts of the case, it could not be concluded that there was instigation by the appellant to such a degree that the victim was left with no option but to commit suicide.
The Court ultimately held that the appellant was not guilty of the offence under Section 306 IPC and acquitted her of the charge. Consequently, the appeal was allowed, and the judgment of the Karnataka High Court was set aside. As the appellant was already on bail, her bail bonds were ordered to stand discharged.
[Geeta v. State of Karnataka, 2025 SCC OnLine SC 1938, decided on 09-09-2025]
*Judgment Authored by: Justice KV Viswanathan
Advocates who appeared in this case:
For Appellant(s): Ms. Supreeta Sharanagouda, AOR Mr. Sharanagouda Patil, Adv. Mrs. Supreeta Sharanagouda (aor), Adv. Mr. Jyotish Pandey, Adv. Mr. Yash S Tiwari, Adv. Mr. Vinod Kumar Srivastava, Adv.
For Respondent(s): Mr. D. L. Chidananda, AOR
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