Supreme Court Quashes Abetment of Suicide Case and Orders Reinvestigation

The Supreme Court of India, in the case of Ayyub & Ors. v. State of Uttar Pradesh & Anr., quashed the criminal proceedings against the appellants under Section 306 of the Indian Penal Code (IPC) and directed a reinvestigation into the circumstances leading to the deaths of Ziaul Rahman and Tanu. The Court found that the investigation was one-sided, partial, and driven by ulterior motives, thereby necessitating an independent probe.

Background of the Case

The case involved two tragic deaths that occurred in quick succession in Saharanpur, Uttar Pradesh. On November 2, 2022, Ziaul Rahman was allegedly beaten to death by the family members of Tanu due to suspicions regarding their relationship. Later the same day, Tanu was found dead by hanging in what was recorded as a suicide.

First FIR: The Death of Ziaul Rahman

The first appellant, Ayyub, lodged an FIR on November 2, 2022, at 19:15 hours against the family members of Tanu. The FIR alleged that Bhuru @ Janeshwar (Tanu’s relative), Maneshwar Saini (Tanu’s father), Priyanshu, and Shivam (Tanu’s brother) had brutally assaulted Ziaul Rahman with sticks and fists. Ziaul suffered 14 injuries and succumbed to his injuries while being taken for treatment. The post-mortem revealed that he died due to shock and hemorrhage caused by ante-mortem injuries.

Second FIR: Alleged Abetment of Suicide by Tanu

On November 3, 2022, at 17:07 hours, the second respondent, Vijay, lodged another FIR accusing the appellants of abetting Tanu’s suicide. According to the complaint:

The appellants had visited Tanu’s house at 8:00 AM on November 2, 2022.
They allegedly taunted her, saying, “Because of you, our boy has died. Why don’t you die?”
They threatened to file a case against her and get her arrested.
Tanu, feeling humiliated, took her own life between 10:30 AM to 11:00 AM on the same day.

Investigation and Legal Proceedings

Following the FIR:

A charge-sheet was filed against the accused under Section 306 IPC on May 2, 2023.
The Judicial Magistrate, Saharanpur, took cognizance and issued summons on June 17, 2023.
The appellants moved the Allahabad High Court under Section 482 CrPC, seeking quashing of the charge-sheet.
The High Court dismissed their petition, holding that a proximate link existed between the appellants’ alleged statements and Tanu’s suicide.
Aggrieved, the appellants approached the Supreme Court.

Arguments Presented

Petitioners’ Arguments (Ayyub & Ors.)

The entire case was an act of vendetta by Tanu’s family to counter the case against them for Ziaul’s death.
The alleged statements made at 8:00 AM were not sufficient to instigate suicide within two hours, as required under Section 306 IPC.
The delay in lodging the FIR on November 3, despite the suicide occurring on November 2, was highly suspicious.
The statements of witnesses were recorded much later and appeared fabricated.
There was no independent verification of whether Tanu was under psychological distress due to other reasons, including Ziaul’s death.

Respondents’ Arguments (State of Uttar Pradesh & Complainant Vijay)

The verbal abuse by the appellants pushed Tanu into a state of distress, leading to her suicide.
Witnesses supported the claim that the appellants had harassed and threatened Tanu.
Tanu was hypersensitive and could not handle the public humiliation caused by the appellants’ words.
The High Court had correctly ruled that the proximate link between the accused’s conduct and the suicide was well established.

Supreme Court’s Observations

The Supreme Court found serious lapses in the investigation and the prosecution’s approach. The Court observed:

“The entire investigation appears to be one-sided and driven by ulterior motives.”
“Despite clear signs of foul play in Ziaul’s death, no alternative theories for Tanu’s suicide were explored.”
“Prosecution witnesses have merely parroted the contents of the FIR without adding any substantive value.”
“There is no direct evidence that the appellants’ alleged statements had such an impact on Tanu that she had no choice but to commit suicide.”

Final Judgment

The Supreme Court ruled:

The charge-sheet filed against the appellants was quashed.
The criminal proceedings before the Judicial Magistrate, Saharanpur, were terminated.
A Special Investigation Team (SIT) was ordered to conduct a fresh probe into the unnatural death of Tanu.
The SIT was granted liberty to register a fresh FIR if deemed necessary.
The investigation report was to be submitted to the Court within two months.

Impact of the Judgment

The Supreme Court’s ruling has significant implications:

Reinforces fair investigation: Ensures that criminal cases are not used as tools for vendetta.
Strict standards for abetment of suicide cases: Requires clear intent and direct link between the accused’s actions and the victim’s death.
Prevention of wrongful prosecution: Protects individuals from baseless allegations motivated by revenge.
Accountability for law enforcement: Calls for impartial investigations, especially in cases involving conflicting versions.

Conclusion

The Supreme Court’s decision in Ayyub & Ors. v. State of Uttar Pradesh & Anr. highlights the need for judicial intervention in cases where investigations appear biased. By ordering a fresh investigation, the Court ensures that justice is served and that individuals are not wrongly prosecuted based on fabricated narratives.

Petitioner Name: Ayyub & Ors..
Respondent Name: State of Uttar Pradesh & Anr..
Judgment By: Justice Sanjiv Khanna, Justice Sanjay Kumar, Justice K.V. Viswanathan.
Place Of Incident: Saharanpur, Uttar Pradesh.
Judgment Date: 07-02-2025.

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