In a significant judgment, the Punjab & Haryana High Court ruled that simply being named in a suicide note does not automatically establish guilt under Section 306 of the Indian Penal Code (IPC), which pertains to abetment of suicide. The court quashed the First Information Report (FIR) against Sunil Chauhan and others, underscoring the need for a clear and direct connection between the accused's actions and the suicide.
Case Background
The case revolved around two petitions, CRM-M-62885-2023 ("Sunil Chauhan v. State of Haryana & Another") and CRM-M-583-2024 ("Mubin Khan v. State of Haryana & Another"), both stemming from the same FIR (No. 357, dated July 15, 2023), registered in Faridabad, Haryana. The complaint was lodged by Shiv Kumar, whose brother, Kehri Singh, tragically took his own life on July 14, 2023.
According to the complaint, Sunil Chauhan allegedly owed Rs. 4,00,000 to the deceased for construction work and had also introduced him to Narendra Kumar Sharma, who owed an additional Rs. 5.73 lakhs. Another accused, Mubin Khan, reportedly owed Rs. 93,152. The complainant argued that the financial stress caused by unpaid dues and threats from the accused led to the suicide.
Legal Question and Court's Observations
The core issue before the court was whether unpaid dues and being named in a suicide note amounted to abetment of suicide under Section 306 IPC. The accused contended that financial disputes and being mentioned in the suicide note did not directly instigate the suicide, and therefore, did not meet the definition of abetment under Section 107 IPC.
Justice Jasjit Singh Bedi, who presided over the case, carefully reviewed the facts, legal provisions, and relevant precedents. The court ruled that abetment requires a "proximate and live link" between the accused's actions and the suicide, noting that the accused’s behavior must directly compel the victim to take their life.
Citing past rulings, including Chitresh Kumar Chopra v. State (Govt. of NCT of Delhi) and Vikas Chandra v. State of Uttar Pradesh, the court stressed that mere financial disputes or being named in a suicide note does not constitute abetment unless it involves clear and direct instigation.
Court’s Conclusion
Justice Bedi firmly stated, "Merely being named in a suicide note does not establish the guilt of an accused under Section 306 IPC unless there is clear evidence of direct involvement." He further emphasized that refusal to pay debts or unresolved financial issues, as alleged, did not amount to instigation to the point where a person would feel compelled to take their life.
Ultimately, the court found no evidence of a direct link between the accused’s actions and the suicide, quashing the FIR and subsequent proceedings.
Case Title: Sunil Chauhan v. State of Haryana & Another
Bench: Justice Jasjit Singh Bedi
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