The Supreme Court of India, in a significant ruling on Friday, emphasized that while broken relationships can lead to emotional and psychological distress, they do not automatically translate into criminal liability for abetment of suicide unless there is clear and irrefutable evidence pointing to an intent to provoke or compel such an act. The court’s decision overturned a Karnataka High Court judgment that had convicted Kamaruddin Dastagir Sanadi, sentencing him to five years of rigorous imprisonment for charges of cheating and abetment of suicide under the Indian Penal Code (IPC), provisions now superseded by the Bharatiya Nyaya Sanhita (BNS).
Sanadi faced charges under Sections 417 (cheating), 306 (abetment of suicide), and 376 (rape) of the IPC in connection with the tragic death of a 21-year-old woman who had been in a romantic relationship with him for eight years. The woman, who died by suicide in August 2007, had reportedly been promised marriage by Sanadi, a promise her mother alleged was not honored. Following her death, the woman’s mother filed a complaint accusing Sanadi of betrayal that led to her daughter’s untimely demise.
A trial court acquitted Sanadi of all charges, citing a lack of substantive evidence. However, the Karnataka High Court later overturned the trial court’s decision, convicting him on charges of cheating and abetment of suicide based on the state’s appeal. The case was then escalated to the Supreme Court for further scrutiny.
A bench comprising Justices Pankaj Mithal and Ujjal Bhuyan delivered a detailed 17-page judgment that carefully analyzed the facts of the case, including the two dying declarations provided by the deceased woman. The bench observed that the declarations did not contain any allegations of a physical relationship between the two or any overt actions by Sanadi that directly led to the woman’s decision to end her life. Justice Mithal highlighted that the evidence on record failed to establish any deliberate or intentional act by Sanadi aimed at instigating or abetting the suicide.
In their judgment, the bench underscored that emotional distress, however severe, stemming from a failed or strained relationship does not in itself constitute a criminal offense under the law. The court remarked that while such situations are undoubtedly tragic, they are a part of the human condition and do not automatically impose criminal culpability on the individuals involved. The justices referred to established legal principles, noting that courts have consistently held that conflicts and discord in personal and domestic relationships are not uncommon and should not be construed as criminal acts unless there is compelling evidence of malicious intent.
The court further elaborated on the legal requirements for convicting an individual under Section 306 of the IPC, which deals with the abetment of suicide. The bench stated unequivocally that such a conviction necessitates proof of "guilty intention"—an intention on the part of the accused to instigate, provoke, or coerce the victim into taking their own life. "Absent clear evidence of such intent, it is neither just nor legally permissible to attribute criminal liability to the accused," the judgment stated. It further clarified that mere failure to fulfill a promise, while morally or ethically questionable, does not satisfy the criteria for criminal prosecution unless it is accompanied by evidence of deliberate actions aimed at causing harm.
The court also addressed the broader implications of this case, emphasizing the need for a careful and nuanced approach in dealing with matters of emotional and interpersonal conflict. It observed that criminal law must not be used as a tool to punish individuals for moral lapses or personal failures unless these are accompanied by clear violations of legal standards. The ruling thus reinforces the principle that criminal liability must be rooted in objective evidence and demonstrable intent, not merely in emotional grievances or societal expectations.
By overturning the Karnataka High Court’s decision, the Supreme Court has set a significant legal precedent, underscoring the importance of evidence-based judgments in cases involving allegations of abetment of suicide. The ruling serves as a reminder that while the justice system must be sensitive to the emotional and social dimensions of such cases, it must also uphold the fundamental principles of fairness, legality, and the presumption of innocence. This judgment will likely influence the handling of similar cases in the future, ensuring a more balanced and just application of the law.
