The Supreme Court ruled that a heated exchange or scuffle between neighbours cannot amount to abetment of suicide under Section 306 IPC, stressing that intent is essential for conviction.
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NEW DELHI: On 9 September 2025, the Supreme Court of India delivered a judgment, clarifying the scope of Section 306 IPC (abetment of suicide).
A Bench comprising Justice B.V. Nagarathna and Justice K.V. Viswanathan acquitted the appellant Geeta, who had been convicted by the Karnataka High Court for allegedly abetting the suicide of her 25-year-old neighbour, Sarika, in 2008.
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Background of the Case
Incident (August 12, 2008): Sarika, a student who also conducted tuition classes, set herself on fire after a heated quarrel with her neighbour, Geeta. In her hospital statement, she alleged continuous harassment, abusive language, and ridicule for being unmarried. She succumbed to burn injuries on September 2, 2008.
The Trial Court (2011) convicted Geeta under Section 306 IPC and Section 3(2)(v) SC/ST Act, sentencing her to 5 years imprisonment and life imprisonment respectively. Four co-accused were acquitted.
The High Court (2018) set aside the conviction under the SC/ST Act but upheld the conviction under Section 306 IPC, reducing the sentence to 3 years. The Court observed that Sarika, being a “sensitive person,” took the extreme step after persistent fights.
The Supreme Court (2025) set aside the conviction, holding that the evidence did not prove the intention required for abetment of suicide.
Legal Principles
The Supreme Court reiterated settled principles on the instigation and abetment of suicide:
The court emphasized that neighbourhood quarrels are common,
“Though ‘love thy neighbour’ is the ideal scenario, neighbourhood quarrels are as old as community living itself. Such disputes, by themselves, cannot amount to abetment.”
The court further noted that casual words are not Instigation, referring to Ramesh Kumar v. State of Chhattisgarh and Swamy Prahaladdas v. State of M.P., the Court held that casual, angry, or abusive words spoken in the heat of the moment do not constitute instigation unless intended to push the victim into suicide.
Mens rea is essential for conviction under Section 306 IPC. The prosecution must prove a clear intention or active role of the accused in compelling the deceased to commit suicide.
The victim’s sensitivity is not sufficient. The subjective sensitivity of the deceased cannot substitute for the statutory requirement of instigation or abetment.
Court’s Final Observations
- The quarrels, though unfortunate, were mutual and recurring, not a deliberate attempt by Geeta to drive Sarika to suicide.
- Evidence failed to show that Geeta had the mens rea or that Sarika was left with “no other option but to commit suicide.”
- Accordingly, the Court acquitted Geeta, setting aside the High Court’s order.
Appearance:
The appellant Geeta: Advocates Sharanagouda Patil, Jyotish Pandey, Yash S Tiwari, Vinod Kumar Srivastava and Supreeta Sharanagouda.
The respondent: Advocate DL Chidananda.
Case Title:
Geeta vs. The State of Karnataka
CRIMINAL APPEAL NO.1044 OF 2018
Read Judgment:
