Broken Relationship Not Abetment to Suicide: Supreme Court Acquits Karnataka Man

The case of Kamaruddin Dastagir Sanadi vs. State of Karnataka revolves around the alleged abetment of suicide and cheating charges against the accused. The Supreme Court ruled in favor of the appellant, holding that merely refusing to marry someone does not constitute abetment to suicide under Section 306 of the Indian Penal Code (IPC). The judgment clarifies the legal standards required to establish instigation or mens rea in suicide cases.

Background of the Case

The case originates from the tragic death of Suvarna, a 21-year-old woman who was allegedly in love with the accused, Kamaruddin Dastagir Sanadi, for over eight years. According to the prosecution, Suvarna was led to believe that the accused would marry her. However, when he refused, she consumed poison and died on August 19, 2007, in Kakati, Karnataka.

Initially, the trial court acquitted the accused of all charges, including Sections 417 (cheating), 376 (rape), and 306 (abetment of suicide). However, the Karnataka High Court, upon appeal by the state, convicted him under Sections 417 and 306 IPC, sentencing him to:

1 year imprisonment under Section 417 IPC (cheating) along with a fine of Rs. 5,000.
4 years imprisonment under Section 306 IPC (abetment of suicide) with a fine of Rs. 20,000.

The present appeal was filed in the Supreme Court challenging this conviction.

Key Legal Issues

Whether the accused’s refusal to marry the deceased constituted abetment of suicide under Section 306 IPC?
Whether there was any evidence proving that the accused had induced the deceased to take the extreme step?
Did the accused commit cheating under Section 417 IPC?

Trial Court’s Findings

The Trial Court acquitted the accused, citing:

No evidence of a physical relationship between the accused and the deceased.
Absence of any clear promise of marriage by the accused.
No evidence that the accused instigated or aided in the deceased’s suicide.

High Court’s Reversal

The Karnataka High Court overturned the trial court’s decision, holding that:

The accused misled the deceased into believing that he would marry her.
His refusal to marry her directly led to her suicide.
The dying declarations and testimony of the deceased’s mother supported the prosecution’s case.

Supreme Court’s Analysis

1. What Constitutes Abetment Under Section 306 IPC?

The Supreme Court emphasized that abetment requires clear instigation or encouragement to commit suicide. The Court referred to Section 107 IPC, which defines abetment as:

“A person abets the doing of a thing, who – (1) instigates any person to do that thing; or (2) engages in a conspiracy; or (3) intentionally aids by act or omission.”

The Court held that merely refusing to marry someone does not amount to instigation or abetment.

2. No Evidence of Instigation

The Supreme Court found that:

The accused did not provoke or force the deceased to commit suicide.
The deceased herself traveled to Kakati with poison in her possession, indicating premeditation.
There was no evidence that the accused had any intention to harm her.

“The accused-appellant had simply refused to marry the deceased. Even assuming there was love between the parties, this is only a case of a broken relationship which by itself would not amount to abetment to suicide.”

3. Analysis of the Dying Declarations

Two dying declarations were recorded:

One by the Police Sub-Inspector (PSI) of Kakati.
One by the Taluka Executive Magistrate in the presence of a doctor.

The Supreme Court noted that neither declaration mentioned any instigation by the accused.

“The deceased stated that she loved the accused and wanted to marry him. When he refused, she consumed poison. There is no mention of any physical relationship, deception, or coercion by the accused.”

4. Cheating Under Section 417 IPC

The Supreme Court found that the allegations of cheating were not substantiated:

There was no proof that the accused falsely promised marriage.
No documentary evidence (such as written records from the village panchayat) supported the claim.
There was no evidence of a sexual relationship on false pretext.

“There is an allegation but no evidence to prove that the accused-appellant was also in love with the deceased or that he was in touch with her in any manner.”

Supreme Court’s Verdict

The Supreme Court acquitted the accused, holding:

There was no instigation, coercion, or active participation by the accused in the deceased’s suicide.
Mere refusal to marry does not constitute abetment to suicide.
Cheating was not proven beyond reasonable doubt.

The Court overturned the High Court’s judgment and reinstated the trial court’s acquittal.

“The accused-appellant stands acquitted as was done by the trial court.”

Conclusion

This ruling clarifies several important legal principles:

A broken relationship does not amount to abetment to suicide.
For a conviction under Section 306 IPC, there must be clear evidence of instigation or coercion.
Allegations of cheating under Section 417 IPC require solid proof of a false promise.

The Supreme Court’s verdict reaffirms the principle that criminal liability should not be imposed without clear, convincing evidence.

Petitioner Name: Kamaruddin Dastagir Sanadi.
Respondent Name: State of Karnataka Through SHO Kakati Police.
Judgment By: Justice Pankaj Mithal, Justice Ujjal Bhuyan.
Place Of Incident: Kakati, Karnataka.
Judgment Date: 29-11-2024.

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