The Supreme Court has discharged a school correspondent, Thangavel, from charges of abetment to suicide under Section 306 of the Indian Penal Code, observing that no reasonable person could have foreseen that a scolding would lead a student to take his own life.
The bench of Justice Ahsanuddin Amanullah and Justice Prashant Kumar Mishra allowed Criminal Appeal No. ___ of 2025 (@ SLP (Crl.) No. 9099 of 2024) and set aside the order of the Madras High Court dated 14 June 2024, which had refused to discharge the appellant in Crl.R.C. No. 682 of 2024.
Background
The appellant was accused in FIR No. 01/2014, registered by the CBCID, for offences under Sections 306 of the IPC and 174 of the CrPC. The case pertained to an incident at a school hostel where the appellant, acting as correspondent and manager, scolded a student following a complaint made against him by another student. The scolding allegedly prompted the student to lock himself in a room and die by suicide.
Charges under Section 306 IPC were later framed against Thangavel. His challenge to the framing of charges was dismissed by the Madras High Court, leading to the present appeal.
Submissions by Parties
Senior Advocate Gaurav Agarwal, appearing for the appellant, argued that the reprimand was not personal but was a necessary step in maintaining discipline in the hostel. It was submitted that the appellant acted in good faith and had no intention to abet suicide. The counsel emphasized that “the appellant could not, even in his wildest dreams, have imagined that such scolding would lead to the deceased taking his life.”
Appearing for the State of Tamil Nadu, Senior Counsel Amit Anand Tiwari conceded that there did not appear to be sufficient grounds for continuing the charge under Section 306 IPC.
Despite notice, Respondent No. 2 — the father of the deceased student and complainant in the case — did not appear before the Court.
Supreme Court’s Observations
Taking note of the factual context and submissions, the Court held:
“No normal person could have imagined that a scolding, that too based on a complaint by a student, would result in such tragedy due to the student so scolded taking his own life.”
The Court further observed that the act of scolding was in response to a legitimate complaint and was part of the appellant’s role as a school administrator:
“Such scolding was the least, a correspondent was required to do, to ensure that the complaint made against the deceased by another student was taken note of and remedial measures effected.”
Concluding that no mens rea (criminal intent) could be attributed to the appellant for abetment of suicide, the Court held that the charge under Section 306 IPC was unsustainable.
Decision
The Supreme Court allowed the appeal and set aside the order framing charge under Section 306 IPC. The appellant stands discharged from all charges in connection with FIR No. 01/2014.
Case Title: Thangavel vs The State, Through Inspector of Police & Anr.
Case No.: Criminal Appeal No. ___ of 2025 (@ SLP (Crl.) No. 9099 of 2024)
