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Mariano Anto Bruno & Anr. vs The Inspector of Police

Criminal Appeal · 2022 INSC 1073Decided 12 Oct 2022
Criminal Appeal No. 1628 of 2022

Background

The appellants, a doctor-husband and his mother-in-law, were convicted by a trial court and the Madras High Court under Sections 498A (cruelty) and 306 (abetment of suicide) IPC after the husband's wife, also a doctor, died by asphyxiation at home in 2014. A complaint alleging dowry harassment and cruelty was lodged by the deceased's mother three weeks after the death, after a dispute arose over custody of the couple's son. The husband's defence was that the wife had a long-documented history of bipolar disorder and suicidal tendencies (including a suicide attempt during her MBBS days), which was concealed before marriage, and that he had in fact cared for her for nine years and taken her to a psychiatrist just one day before her death.

Decision Breakdown

The Supreme Court held that a conviction under Section 306 IPC requires cogent evidence of a positive, proximate act of instigation or continuous cruelty that leaves the victim with no option but suicide: mere allegations of harassment, especially raised for the first time weeks after death by interested witnesses (the mother and siblings), are insufficient. The Court found no evidence of any complaint or discord during the nine years of marriage, found that the trial court and High Court had ignored the treating psychiatrist's (PW-9's) evidence documenting the deceased's pre-existing depressive illness and recent suicidal ideation, and found that the husband's own conduct (seeking psychiatric help for her) contradicted the harassment narrative. On the Section 498A charge, the Court found no evidence beyond the same interested witnesses' statements. Concluding both the trial court and High Court had erred, the Supreme Court set aside the convictions and acquitted both appellants.

Lesson Learnt

A conviction for abetment of suicide cannot rest merely on allegations of harassment raised belatedly by interested family witnesses; courts must find cogent evidence of a specific, proximate act of instigation, and must not overlook medical evidence (such as a documented pre-existing mental illness) that offers an alternative explanation for the death.

Official source (sci.gov.in)View Judgment (PDF)

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