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Rohini Sudarshan Gangurde vs. The State of Maharashtra

Not available · 2024 INSC 519Decided 10 Jul 2024
Not available
Justice Vikram Nath · Justice Satish Chandra Sharma

Background

The appellant's husband, Sudarshan Gangurde, was found hanged in the couple's home in February 2020, with no suicide note and no injuries noted in the post-mortem. His mother filed an FIR alleging that the appellant had harassed and beaten him over money and pressured him to transfer their jointly-purchased house into her name, and that this harassment drove him to suicide. The trial court rejected the appellant's application to be discharged from the case, and the Bombay High Court upheld that rejection in a revision petition, prompting the appeal to the Supreme Court.

Decision Breakdown

The Supreme Court reviewed the legal ingredients of abetment under Sections 306 and 107 IPC, reaffirming through precedent that a conviction (or even continuation of trial) requires clear evidence of a positive, proximate act of instigation or intentional aid that left the deceased with no option but to end his life: mere allegations of harassment are not enough. Examining the record, the Court found no evidence of any active or direct act by the appellant proximate to the suicide, noting the house was jointly owned (undermining the "transfer demand" allegation) and that no colleague or family statement suggested the appellant had ever suggested or instigated suicide. Concluding that none of the three essential ingredients of Section 107 read with Section 306 were made out even prima facie, the Court allowed the appeal, set aside the High Court's order, and discharged the appellant from the case.

Lesson Learnt

A criminal charge of abetment of suicide cannot rest merely on allegations of general harassment or marital discord. The prosecution must show a specific, proximate act of instigation or intentional aid, and courts must scrutinise this carefully even at the discharge stage before allowing a trial to proceed.

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

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