Featured image for Supreme Court Judgment dated 25-07-2019 in case of petitioner name Ude Singh & Ors. vs State of Haryana
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Abetment of Suicide: Supreme Court Upholds Conviction in Haryana Case

The case of Ude Singh & Ors. v. State of Haryana revolves around the tragic suicide of a young woman due to continuous harassment by her relatives. The Supreme Court upheld the conviction of the accused under Section 306 IPC (abetment of suicide), reinforcing the legal framework that protects individuals, especially women, from harassment leading to extreme consequences.

Background of the Case

The case originated in the village of Shahadatnagar, Haryana, where the complainant’s daughter, an unmarried young woman, was subjected to continuous humiliation by her relatives. The appellants, Ude Singh, Manoj Kumar, and Daulat Ram, along with one deceased accused, Hem Karan alias Hemla, repeatedly taunted the victim, referring to her as ‘wife,’ ‘Chachi’ (aunt), and ‘Bohoria’ (younger brother’s wife). This harassment continued for a prolonged period, leading to her eventual suicide on May 6, 1996.

Key Events

  • On April 15, 1996, the accused Hem Karan physically dragged and insulted the victim.
  • The family did not report the incident to the police due to societal pressures.
  • On May 5, 1996, the accused again verbally harassed the victim in front of witnesses.
  • That evening, she expressed her distress to her mother, stating she could no longer bear the humiliation.
  • On May 6, 1996, she was found dead, having hanged herself.
  • The complainant, her father, lodged an FIR, leading to an investigation and trial under Section 306 IPC.

Arguments of the Parties

Petitioner’s (Appellants’) Argument

  • The accused argued that there was no direct evidence linking them to the suicide.
  • The victim was under personal distress due to a failed school examination and a broken engagement.
  • There was previous enmity between the families, leading to a false case against them.
  • They contended that their actions, even if proven, did not amount to abetment of suicide.

Respondent’s (State of Haryana’s) Argument

  • The prosecution presented evidence that the accused harassed the victim regularly.
  • Multiple witnesses testified that the accused publicly humiliated her, leading to her mental distress.
  • The victim had specifically stated her intention to commit suicide due to the harassment.
  • The chain of events clearly established that the accused’s actions directly contributed to her suicide.

Supreme Court’s Analysis

Legal Interpretation of Abetment of Suicide

The Court examined the legal framework of Section 306 IPC and the definition of ‘abetment’ under Section 107 IPC. It ruled:

“Instigation means to goad, urge forward, provoke, incite, or encourage a person to commit an act.”

The Court also referenced its past judgments, including Ramesh Kumar v. State of Chhattisgarh (2001), which held that abetment requires direct or indirect acts of instigation.

Findings on the Accused’s Actions

  • The Court noted that the accused continuously humiliated the victim, targeting her with demeaning remarks.
  • The harassment was not a one-time event but a prolonged pattern of abuse.
  • The Court observed that the accused’s words and actions were calculated to break the victim’s self-esteem.
  • The immediate proximity of the final incident on May 5, 1996, and her suicide the next morning established causation.

Judgment on the Juvenile Accused

The Court acknowledged that one of the accused was a minor at the time of the incident and extended him the benefit of the Juvenile Justice Act, terminating proceedings against him.

Final Ruling

The Supreme Court upheld the convictions of the remaining accused under Section 306 IPC and maintained the sentence of two and a half years of rigorous imprisonment as imposed by the High Court.

Significance of the Judgment

  • Strengthens Legal Protections: The ruling reinforces legal protections for victims of harassment.
  • Defines Abetment of Suicide: It clarifies the legal interpretation of abetment under the IPC.
  • Sets a Precedent: The case sets a judicial precedent for similar cases involving mental harassment.
  • Recognizes the Impact of Harassment: The judgment acknowledges the severe consequences of continuous humiliation and societal pressures on individuals.

Conclusion

The Supreme Court’s decision in Ude Singh & Ors. v. State of Haryana underscores the importance of holding individuals accountable for actions that mentally and emotionally drive victims to suicide. The ruling highlights that prolonged harassment, even without physical violence, can amount to abetment under Section 306 IPC. This landmark decision serves as a reminder that society must take issues of verbal abuse and psychological torment seriously.


Petitioner Name: Ude Singh & Ors..
Respondent Name: State of Haryana.
Judgment By: Justice Dinesh Maheshwari.
Place Of Incident: Shahadatnagar, Haryana.
Judgment Date: 25-07-2019.

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