Mere allegations of harassment or strained relations were not enough to sustain a conviction under Section 306 of Indian Penal Code, the Court said.
A Bench comprising Justices JK Maheshwari and Aravind Kumar ruled that mere claims of harassment or marital discord are insufficient to uphold a conviction under Section 306 of the Indian Penal Code, which pertains to abetment of suicide.
The Supreme Court recently overturned the conviction of a man who had spent nearly thirty years under the shadow of allegations related to his wife’s suicide in the case of Ravindra Singh v. State of Uttarakhand through Home Secretary.
The Court underscored that such a conviction must be supported by evidence beyond past quarrels or emotional distress in 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.
Accordingly, the Supreme Court overturned the trial court and High Court verdicts, citing the absence of direct evidence showing that the accused had instigated or deliberately compelled the deceased to end her life.
The case involved a woman who died of burn injuries at her matrimonial home in Uttarakhand. The prosecution claimed she had been abandoned by her husband, who was allegedly cohabiting with another woman. Her family cited a complaint she had submitted to the principal of her husband’s school, which had led to a police-mediated settlement. A quarrel reportedly took place two days before her death.
The trial court convicted the husband in 2001, and the High Court upheld the verdict in 2013. However, the Supreme Court held that even if the alleged circumstances were accepted as true, they did not establish the necessary intent to abet suicide under Section 306 of the IPC, and thus were insufficient to sustain criminal liability.
In overturning the conviction, the Court reaffirmed that strained relations alone are not sufficient for a conviction under Section 306 IPC; there must be clear and direct evidence of instigation.