In a recent ruling, the Supreme Court clarified the circumstances under which official superiors can be held liable for abetting the suicide of a junior official.
The bench, consisting of Justices J.B. Pardiwala and Manoj Misra, identified two primary categories of relationships that could contribute to suicide: one involving sentimental ties and the other involving official interactions.
The first category encompasses relationships where the deceased had emotional or physical connections with the accused, such as familial bonds. The court noted that conflicts in these relationships could lead to immediate psychological distress, potentially resulting in depression or suicidal tendencies. Examples include relationships between spouses, parents and children, or siblings, where emotional attachments can lead to heightened expectations.
In contrast, the second category involves relationships based on professional interactions, where expectations are more transactional. The court explained that in these cases, the deceased is primarily obligated to fulfill their official duties in exchange for compensation, such as salary or wages. “In the second category, the relationship is defined by official duties, where expectations are outlined by laws, rules, policies, and regulations. Unlike personal relationships, which often involve deeper emotional investments, professional relationships typically have more defined and limited expectations,” the court differentiated.
This analysis arose in a case where the relatives of a deceased individual, who had taken his own life, claimed that his senior officials (the appellants) had subjected him to humiliation and harassment, ultimately compelling him to resign voluntarily. They argued that the appellants’ harsh treatment led to the suicide.
The court, however, granted relief to the appellants by dismissing the pending criminal case under Section 306 of the Indian Penal Code (IPC), which pertains to abetment of suicide. The court emphasized that harassment or humiliation alone does not constitute instigation unless there is clear evidence that the appellants intended for the deceased to take his own life.
“The test the court should apply in such cases is to determine, based on the evidence available, whether there is any indication, even prima facie, that the accused intended the consequence of suicide,” the court stated. Essentially, the court concluded that unless the criteria outlined in Section 306 IPC are met, mere instances of humiliation and harassment cannot be deemed instigative of suicide.
The court underscored that this case fell into the second category, where the expectations between the deceased and the appellants were legally defined. Therefore, minor disputes or heated exchanges related to work responsibilities could not reasonably be construed as instigating factors for suicide.