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Naresh Kumar vs. State of Haryana

Not available · 2024 INSC 149Decided 22 Feb 2024
Not available
Justice J.B. Pardiwala · Justice Manoj Misra

Background

Naresh Kumar was convicted by a Trial Court, and the conviction affirmed by the Punjab and Haryana High Court, for abetting the suicide of his wife Rani under Section 306 IPC. The couple married in 1992 and had a daughter. Rani died by consuming poison in November 1993. The prosecution's case, based on the testimony of her brother and father, was that Naresh and his parents had repeatedly demanded money from Rani's family so Naresh could start a shop, and that this harassment drove her to suicide.

Decision Breakdown

The Supreme Court allowed the appeal and acquitted Naresh Kumar, setting aside the conviction. It held that the oral evidence of the deceased's brother and father showed only a demand for money to start a business, with no proof of the kind of incessant cruelty or harassment that would leave a person with no option but suicide. Relying on precedents including Geo Varghese v. State of Rajasthan and S.S. Cheena v. Vijay Kumar Mahajan, the Court reiterated that abetment under Section 107 IPC requires a positive act of instigation or intentional aiding with a clear mens rea, and that a mere demand for money, without more, does not amount to cruelty or harassment sufficient to sustain a conviction under Section 306 IPC.

Lesson Learnt

A conviction for abetment of suicide cannot rest on evidence of financial demands or family friction alone. The prosecution must show a clear, proximate act of instigation or intentional aiding with the requisite guilty intent; courts will not presume abetment merely because a spouse died within a few years of marriage.

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

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