In a significant ruling the Supreme Court of India has recently clarified that broken relationships, while emotionally challenging, do not automatically constitute abetment of suicide unless there is evidence of criminal intent.
The bench, consisting of Justices Pankaj Mithal and Ujjal Bhuyan, overturned the conviction of Kamaruddin Dastagir Sanadi, who had been sentenced to 5 years in prison for cheating and abetment of suicide under the Indian Penal Code (IPC), which has since been replaced by the Bharatiya Nyaya Sanhita (BNS).
The Court observed, “This is a case of a broken relationship, not criminal conduct,” in its judgment, emphasizing that personal emotional struggles, even in the case of a suicide, are not enough to label someone as criminally liable without clear evidence of intent.
Background of the Case
Sanadi’s case had its roots in a tragic incident in August 2007 when a 21-year-old woman, who had been in a relationship with him for eight years, died by suicide. Her mother filed a police complaint accusing Sanadi of failing to keep his promise to marry the woman, alleging that this had caused her emotional distress and ultimately led to her death.
Sanadi was initially charged with multiple offenses, including Sections 417 (cheating), 306 (abetment of suicide), and 376 (rape) of the IPC. While a trial court had acquitted him of all charges, the Karnataka High Court later convicted him on charges of cheating and abetment of suicide, following an appeal by the state.
Court’s Analysis
In its ruling, Justice Mithal examined the woman’s two dying declarations, which were crucial in determining the cause of her suicide. The Court found that the declarations did not accuse Sanadi of any direct actions that could be considered criminal. In particular, they did not suggest that Sanadi had engaged in any form of physical abuse or intentional behavior that led to the woman’s tragic decision to end her life.
The Court also emphasized that emotional distress stemming from a personal relationship, even one as significant as a long-term romantic involvement, does not automatically equate to criminal conduct. The judgment highlighted that such emotional struggles are a part of human relationships and are commonly experienced, without necessarily leading to criminal charges.
Key Legal Principles
The Supreme Court reiterated that for a conviction under Section 306 of the IPC (abetment of suicide), there must be clear evidence of the accused’s criminal intent. The Court ruled that emotional anguish alone, even in cases where a person dies by suicide due to a relationship breakdown, cannot be enough to establish guilt.
“Until and unless some guilty intention on the part of the accused is established, it is ordinarily not possible to convict him for an offence under Section 306 IPC,” the Court stated, making it clear that a suicide linked to a broken relationship does not automatically imply criminal responsibility.
Impact of the Ruling
This judgment brings much-needed clarity on the legal threshold for abetment of suicide cases, particularly in situations involving personal relationships. The ruling emphasizes that courts must look for intent and direct evidence of culpability rather than relying solely on emotional distress or the breakdown of relationships as grounds for criminal liability.
The case also highlights the nuanced approach that courts must take when evaluating the complex emotions involved in relationship-related cases, particularly when they result in tragic outcomes like suicide. While the emotional toll of broken relationships is undeniably real, the Supreme Court’s decision reinforces the principle that criminal liability requires more than just an unfortunate sequence of events—it demands clear evidence of a deliberate, unlawful action.
In overturning the conviction, the Court has sent a strong message about the importance of distinguishing between personal emotional crises and criminal behavior, setting a precedent for future cases involving similar circumstances.
