Mere allegations of harassment or strained relations were not enough to sustain a conviction under Section 306 of Indian Penal Code, the Court said.
In a recent judgment in Ravindra Singh v. State of Uttarakhand through Home Secretary, the Supreme Court set aside the conviction of a man who had spent nearly three decades facing allegations linked to his wife’s suicide.
The Bench, comprising Justices JK Maheshwari and Aravind Kumar, held that mere allegations of harassment or marital discord do not suffice to sustain a conviction under Section 306 of the Indian Penal Code, which deals with abetment of suicide.
The Court emphasized that such a conviction must be grounded in substantive evidence, extending beyond prior disputes or emotional strain within the marriage.
“Merely because there was some dispute between the parties by itself would not establish the act of abetment. Nothing has been brought on record to show that there was any direct link between the act of appellant and commission of suicide by the deceased,” the Court noted in its judgement.
Consequently, the Supreme Court set aside the judgments of both the trial court and the High Court, noting the lack of direct evidence indicating that the accused had incited or intentionally driven the deceased to take her own life.
The case revolved around a woman who succumbed to burn injuries at her matrimonial home in Uttarakhand. The prosecution alleged that she had been deserted by her husband, who was reportedly living with another woman. Her family referred to a complaint she had filed with the principal of her husband’s school, which had resulted in a police-facilitated settlement. A dispute between the couple was said to have occurred two days prior to her death.
The trial court convicted the husband in 2001, a decision that was later affirmed by the High Court in 2013. However, the Supreme Court observed that even if the alleged facts were presumed to be true, they failed to demonstrate the requisite intent to abet suicide under Section 306 of the IPC, and therefore could not justify imposing criminal liability.
While setting aside the conviction, the Court reiterated that mere strained relations are inadequate to secure a conviction under Section 306 of the IPC; there must be explicit and direct evidence of instigation.
