Allahabad High Court Overturns Lower Court's Decision, Discharges Accused in Abetment to Suicide Case

Court rules mere matrimonial disputes insufficient to constitute abetment under Section 306 IPC

In a significant ruling, the Allahabad High Court on September 8, 2025, set aside a lower court's order, discharging Rachana Devi and her parents from charges of abetment to suicide under Section 306 of the Indian Penal Code (IPC). The court found that mere matrimonial disputes or casual remarks during quarrels do not amount to abetment unless there is evident intent or provocation leading to suicide.

The case revolved around the tragic suicide of the son of the complainant, with allegations that Rachana Devi, the deceased's wife, along with her parents, instigated the act. The complainant alleged that repeated insults and harassment by the accused led to the suicide. However, the High Court emphasized the lack of prima facie evidence showing direct or indirect instigation or mens rea, which are critical components for charges under Section 306 IPC.

Justice Sameer Jain, presiding over the matter, highlighted that the mere existence of matrimonial discord is not uncommon and does not automatically imply abetment to suicide. The judgment also referenced various precedents, reinforcing that words spoken in the heat of the moment do not constitute the requisite mens rea for abetment unless they directly incite the act of suicide.

The court's decision underscores the importance of clear evidence of intent in such cases, preventing potential misuse of legal provisions in situations of domestic discord. The ruling is expected to influence future cases involving similar charges, stressing the need for substantial evidence before proceeding with abetment to suicide allegations.

Bottom Line:

Discharge of accused under Section 306 IPC - Mere matrimonial disputes or casual remarks made during quarrels without the requisite mens rea do not constitute abetment to suicide under Section 306 IPC. Prima facie evidence of intention or instigation is essential to frame charges. 

Statutory provision(s): Indian Penal Code, 1860 Sections 306 and 107; Criminal Procedure Code, 1973 Section 227

Rachana Devi v. State of U.P., (Allahabad) : Law Finder Doc Id # 2787223