In a recent judgment, the Madhya Pradesh High Court addressed the charges framed against Khairu @ Satendra Singh Rawat, a resident of Shivpuri, in connection with the suicide of his sister-in-law, Vandana Rawat. The case stems from an incident reported on June 18, 2023, when Vandana was found hanging from a ceiling fan at her residence. Vandanaโs husband, Vikram Rawat, had taken their children for a haircut, and upon returning, discovered her body after she did not respond to his calls.
Vandana’s parents and brother alleged that Vikram and his cousin, Khairu, had been harassing Vandana, which led her to take her own life. Following these allegations, the police registered an FIR against Vikram and Khairu under Section 306 read with Section 34 of the Indian Penal Code (IPC), accusing them of abetting Vandana’s suicide.
Legal Issues Involved:
The primary legal issue in this case was whether the actions of the accused, particularly Khairu, constituted “abetment” to suicide under Section 306 of the IPC. Section 306 deals with the punishment for abetment of suicide, and the prosecution needed to prove that the accused had instigated or intentionally aided Vandana in committing suicide.
The defence argued that Khairu, being a distant relative and occasional visitor to Vikramโs home, had no significant involvement in Vandanaโs daily life. It was also argued that there was no direct evidence of Khairuโs involvement in instigating or aiding the suicide.
Courtโs Decision and Observations:
Justice Sanjeev S. Kalgaonkar, presiding over the case, thoroughly examined the allegations and evidence presented. The court referenced several key judgments, including Gangula Mohan Reddy v. State of Andhra Pradesh and Amalendu Pal @ Jhantu v. State of West Bengal, to clarify the legal interpretation of abetment.
The court observed that for an offense under Section 306 IPC, there must be a clear intention or mens rea on the part of the accused to instigate the suicide. The court emphasized that mere harassment or occasional misbehavior, without a direct or positive act of instigation, does not fulfill the criteria for abetment to suicide.
In the absence of specific allegations of instigation or encouragement by Khairu, the court found the charges against him to be unsupported by evidence. Justice Kalgaonkar noted:
“Mere occasional harassment or misbehavior does not amount to abetment to suicide… The general and omnibus allegations made against the applicant are trivial in nature, which generally take place in every household.”
The court concluded that the charges against Khairu under Section 306 read with Section 34 IPC were not prima facie made out. Consequently, the court set aside the order of the Sessions Judge and discharged Khairu from the case. The revision petition was allowed, and Khairu was acquitted of all charges.
Also Read
Case Details:
– Case Title: Khairu @ Satendra Singh Rawat vs. The State of Madhya Pradesh
– Case Number: Criminal Revision No. 639 of 2024
– Bench: Justice Sanjeev S. Kalgaonkar
– Advocates:
– For Petitioner: Shri Rameshwar Rawat
– For Respondent/State: Smt. Ankita Mathur, Public Prosecutor
– For Respondent/Complainant: Shri Sooraj Bhan Lodhi
