Supreme Court: Scolding Does Not Amount to Provoking Suicide
The Supreme Court of India has clarified that scolding, by itself, does not amount to provoking or abetting someone to take their own life. This decision came in a case where a school and hostel in-charge was accused of driving a student to suicide following a reprimand based on a complaint by another student. The student subsequently died by suicide, and the official was charged under Section 306 of the Indian Penal Code (IPC), which pertains to abetment of suicide.
The bench, comprising Justices Ahsanuddin Amanullah and Prashant Kumar Mishra, stated that no reasonable or ordinary person could have foreseen that a mere scolding would result in such a tragic outcome.
The Court emphasized that the scolding was a minimal, necessary action to address a complaint and maintain discipline, not an act intended to provoke or harm the student.
The Supreme Court set aside the Madras High Court’s earlier refusal to discharge the teacher, holding that there was no evidence of mens rea (criminal intent or knowledge of wrongdoing) on the part of the accused.
The Court reiterated that to establish abetment to suicide under Section 306 IPC, there must be proof of instigation, provocation, or intentional aid in committing the act. Mere scolding, without evidence of such intent, does not meet this threshold.
“No normal person could have imagined that a scolding, that too based on a complaint by a student, would result in such a tragedy due to the student so scolded taking his own life… under such admitted factual position, no mens rea can be attributed to the appellant, much less, with regard to abatement of suicide committed by the deceased.”
The judgment also noted that the teacher’s actions were those of a responsible authority addressing a complaint, not of someone seeking to harm the student. There was no evidence of personal animosity or intent to instigate suicide.
The Supreme Court reaffirmed that for an act to amount to abetment of suicide, there must be clear evidence of instigation or intentional aid. Mere disciplinary actions or hurtful remarks, even if distressing, do not automatically constitute abetment unless accompanied by intent or encouragement to commit suicide.
The Supreme Court’s ruling underscores that scolding, in the absence of intent or provocation to cause suicide, does not amount to abetment under Indian law. The decision provides clarity for educators and guardians, emphasizing that reasonable disciplinary actions, without malicious intent, cannot be construed as criminal abetment to suicide.
