Abetment to Suicide Case Reopened: Supreme Court Reverses High Court’s Decision

Legal disputes regarding abetment to suicide are highly sensitive and require a careful examination of evidence and intent. One such case, Munshiram vs. State of Rajasthan and Another, reached the Supreme Court after the High Court of Rajasthan quashed an FIR related to the suicide of Brijesh Singh. The Supreme Court’s ruling reinstating the investigation marks a crucial development in the legal framework surrounding abetment to suicide.

The appeal was filed against the judgment dated April 15, 2015, of the High Court of Rajasthan, Jaipur Bench, which had quashed FIR No. 318 of 2013 registered under Section 306 of the IPC (Abetment to Suicide). The Supreme Court, in its ruling on April 9, 2018, found that the High Court had prematurely terminated the investigation, thereby setting aside its judgment.

Background of the Case

The case revolves around the suicide of Brijesh Singh, son of the appellant, Munshiram. Brijesh was married to Khushboo on February 10, 2008, and the couple had a child in 2009. However, their relationship soon turned contentious, leading to multiple legal disputes.

The deceased’s wife had filed several complaints against him, some of which were later settled. However, on March 7, 2013, she initiated another legal proceeding, which allegedly pushed Brijesh into a state of constant fear of arrest. The situation escalated when she filed another FIR (No. 152 of 2013) against Brijesh and his family members, followed by a domestic violence case.

On July 8, 2013, Brijesh Singh committed suicide, leaving behind two suicide notes detailing the reasons for his extreme step.

Contents of the Suicide Notes

Before taking his life, Brijesh Singh wrote two suicide notes, which provided insight into his mental state and the alleged harassment he faced. The suicide notes mentioned:

• Allegations that his wife and in-laws had been filing false cases against him and his family.
• Claims of an illicit affair between his wife and a neighbor.
• Accusations that his in-laws wanted to take over his family’s property and factory.
• A plea for the safety of his parents, stating that his wife did not allow them to meet their grandchild.

Excerpt from Suicide Note 1:

“My wife Khushboo and her parents and family members have been threatening me and my family since after marriage. They have filed false cases of dowry and domestic violence. My wife Khushboo has an illicit relation with Rajkumar, the second son of SI Gajadhar. My wife, my in-laws, and these people are trying to grab my parents’ factory and house. Me and my parents are in deep agony since my marriage.”

Excerpt from Suicide Note 2:

“My wife Khushboo, under the influence of Rajkumar, Rajesh Aggarwal, and her in-laws, has filed a false case against me and my family. I am in deep mental stress. My wife wants to flee to Delhi after grabbing our property. She abuses and threatens to kill us. She does not let us meet my son. I have always loved my wife, but she has betrayed me.”

Legal Proceedings and High Court’s Judgment

Following Brijesh’s suicide, his father, Munshiram, filed an FIR (No. 318 of 2013) against his daughter-in-law and her family members, alleging that their actions had driven his son to suicide.

During the police investigation:

• The forensic science laboratory (FSL) confirmed that the suicide notes were written by the deceased.
• Multiple witnesses provided statements supporting the claims of harassment.
• Call records and other evidence were gathered to analyze the circumstances leading to the suicide.

However, the accused filed a petition under Section 482 of the CrPC before the High Court, seeking to quash the FIR. On April 15, 2015, the High Court ruled in their favor, citing the following reasons:

• The suicide notes merely mentioned ongoing litigation and failed to establish clear abetment.
• There was no direct evidence to prove that the wife had instigated the suicide.
• The deceased had acknowledged prior mental distress in his notes.
• The allegations regarding the wife’s alleged extramarital affair lacked evidence.

Supreme Court’s Decision

Unhappy with the High Court’s ruling, Munshiram approached the Supreme Court through a Special Leave Petition. The Supreme Court took a different view, stating that the High Court had prematurely quashed the FIR without allowing a full investigation.

Key Excerpt from the Supreme Court Judgment:

“We are of the opinion that the High Court has prematurely quashed the FIR without proper investigation being conducted by the Police. Further, it is no more res integra that Section 482 of CrPC has to be utilized cautiously while quashing the FIR. The court has quashed FIRs only after concluding that continuing the investigation would amount to an abuse of process. In this case, the court abridged the investigation, which needed to ascertain certain factual assertions made in the FIR.”

The Supreme Court also emphasized the forensic findings that matched the suicide notes with the deceased’s handwriting and took into account the detailed status report provided by the police.

Final Verdict

Setting aside the High Court’s decision, the Supreme Court ruled that the investigation should proceed:

• The police were directed to complete the investigation promptly.
• The Court clarified that the observations made should not influence the investigation, which should proceed independently.
• Pending aspects of the case, such as the role of absconding accused individuals, were to be investigated further.

Accordingly, the Supreme Court allowed the appeal and reinstated the FIR against Khushboo and her family.

Conclusion

This case underscores the importance of thorough investigations in abetment to suicide cases. The Supreme Court’s ruling ensures that justice is not denied due to premature judicial interventions. The reinstatement of the FIR will allow authorities to probe the allegations in detail and ensure that due process is followed.

Furthermore, the judgment reinforces the principle that quashing an FIR under Section 482 CrPC should be done with extreme caution, particularly in cases involving serious allegations like abetment to suicide.

Petitioner Name: Munshiram.
Respondent Name: State of Rajasthan and Another.
Judgment By: Justice N. V. Ramana, Justice S. Abdul Nazeer.
Place Of Incident: Rajasthan.
Judgment Date: 09-04-2018.

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