Suicide Note Alone Lacks Sufficient Grounds for Culpability: P&H HC

Suicide Note Alone Lacks Sufficient Grounds for Culpability: P&H HC

In a recent ruling, the Punjab and Haryana High Court dismissed a case of abetment of suicide, highlighting that simply being mentioned in a suicide note does not constitute grounds for establishing guilt.

An FIR was filed following the suicide of Kehri Singh, who named three individuals in his note, including Sunil Chauhan and Mubin Khan, accusing them of withholding payments and causing him mental distress. Singh died by hanging on July 14, 2023, after visiting Chauhan's construction site. The FIR invoked Sections 306 (abetment of suicide) and 34 (common intention) of the IPC.

The petitioners, Chauhan and Khan, contended that the non-payment of dues did not constitute abetment under Section 107 of the IPC, which defines abetment as instigating, conspiring, or intentionally aiding an act. Their counsel argued that merely owing money, as alleged in the suicide note, does not meet the threshold for abetment, referencing legal precedents like Harbhajan Sandhu v. State of Punjab & Another (2022), where similar allegations were insufficient for prosecution.

The High Court noted that to establish abetment of suicide, there must be clear evidence of instigation or conspiracy directly leading to the victim’s drastic action, referencing Gauri Devi v. State of J&K (2021).

The Court ruled that simply being named in a suicide note does not imply criminal culpability unless there is a direct and overt act linked to the suicide. Considering post-mortem findings and the police investigation, which revealed no substantive evidence of active harassment or threats by the accused, the Court determined that the petitioners could not be held legally responsible for Singh's death.

Justice Jasjit Singh Bedi emphasized that abetment requires a clear "live and proximate link" between the accused's actions and the suicide. He stated that a person of ordinary prudence would not be driven to suicide solely due to unpaid dues, suggesting that Singh's decision was more likely a result of hypersensitivity. The Court further noted that the complainant had legal avenues to recover outstanding amounts instead of resorting to extreme measures.

Consequently, the Court quashed the FIR and all related legal proceedings.

Case Title: Sunil Chauhan versus State of Haryana & another and connected matters

 
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