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 ruling in Ravindra Singh v. State of Uttarakhand through Home Secretary, the Supreme Court overturned the conviction of a man who had spent nearly 30 years entangled in a case related to his wife’s suicide.
The Bench, comprising Justices JK Maheshwari and Aravind Kumar, observed that mere allegations 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 Court underscored that such a conviction must rest on concrete and substantive evidence, going beyond previous conflicts or emotional distress 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.
As a result, the Supreme Court overturned the verdicts of both the trial court and the High Court, citing the absence of direct evidence showing that the accused had provoked or deliberately compelled the deceased to end her life.
The case concerned a woman who died from burn injuries sustained 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 pointed to a prior complaint she had submitted to the principal of her husband’s school, which had led to a police-mediated settlement. A quarrel between the couple was also said to have occurred two days before her death.
The husband was convicted by the trial court in 2001, and the High Court upheld the conviction in 2013. However, the Supreme Court noted that even assuming the allegations were accurate, they did not establish the necessary intent to abet suicide under Section 306 of the IPC, and thus were insufficient to sustain criminal liability.
While overturning the conviction, the Court reaffirmed that strained relations alone are insufficient to warrant a conviction under Section 306 of the IPC; there must be clear and direct evidence of instigation.
