In a landmark judgment addressing the escalating crisis of student suicides, the Supreme Court of India has transferred the investigation into the unnatural death of a 17-year-old NEET aspirant to the Central Bureau of Investigation (CBI) and issued a comprehensive set of interim guidelines to safeguard the mental health of students in all educational institutions nationwide. A Division Bench comprising Justices Vikram Nath and Sandeep Mehta quashed the Andhra Pradesh High Court’s refusal to transfer the probe, citing glaring inconsistencies and the “ineffectiveness of the local police officials.”
The Court, framing the case within the larger “systemic malaise” of student distress, exercised its powers under Article 141 of the Constitution to establish a preventive and supportive framework, which will be binding until specific legislation is enacted.
Background of the Case
The appeal was filed by Sukdeb Saha, the father of a 17-year-old student, Ms. ‘X’, who died tragically on July 16, 2023. The deceased was from West Bengal and had been enrolled at Aakash Byju’s Institute in Vishakhapatnam for NEET coaching since May 2022. She was residing at the Sadhana Ladies Hostel, which was recommended by the coaching institute.
On July 14, 2023, the appellant was informed that his daughter had fallen from the third floor of the hostel and was admitted to Venkataramana Hospital with severe injuries. The appellant immediately traveled to Vishakhapatnam, finding his daughter unconscious and on ventilator support by the time he arrived on July 15, 2023. Dissatisfied with the medical care, he shifted her to Care Hospital, where she passed away the following day.
Initially, an FIR was registered by the IV Town Police Station under Section 174 of the Code of Criminal Procedure (CrPC). The appellant, alleging inaction and a flawed investigation, filed multiple writ petitions before the Andhra Pradesh High Court. The High Court, in one order, appointed an Advocate Commissioner to secure CCTV footage, and in another, directed that preserved forensic samples be sent to AIIMS, New Delhi, for DNA testing. However, the High Court rejected the appellant’s primary prayer to transfer the investigation of the main FIR to the CBI, citing jurisdictional issues as another FIR had been filed in West Bengal. This rejection led to the present appeal before the Supreme Court.
Arguments of the Parties
Appellant’s Submissions:
The appellant’s counsel argued that the investigation by the local police was “manifestly arbitrary and perfunctory.” It was contended that the police hastily concluded the death was a suicide, ignoring the appellant’s assertion that it was an unnatural death warranting a probe under Section 302 of the IPC.
Key submissions included:
- Medical Negligence: Venkataramana Hospital was accused of gross dereliction of duty, as the deceased was conscious upon admission but was not provided proper treatment and was placed on a ventilator without parental consent. No effort was made by the police to record her statement while she was fit to communicate.
- Flawed Evidence Collection: The police failed to fully cooperate with the court-appointed Advocate Commissioner and did not seize crucial CCTV footage or collect forensic samples from the scene of the incident.
- CCTV Discrepancies: A significant contradiction was highlighted in the CCTV footage, which showed a girl in “salwar/trousers” going upstairs, while later footage of the fall showed a girl in “blue half pants and a T-shirt,” raising doubts about the identity of the person.
- Withholding Forensic Reports: Crucial documents, including the chemical analysis report and the final opinion on the cause of death, were deliberately withheld, despite the autopsy report noting a “suspicious smell” in the stomach contents.
- Conflict of Interest: A single doctor, Dr. P. Venkataramana Rao, served as the autopsy surgeon, a chemical analyst, and a member of the medical inquiry committee, which was an “egregious conflict of interest.”
Respondents’ Submissions:
Opposing the appeal, the respondents argued that the investigation was conducted diligently. They claimed that over 40 witnesses were examined, evidence was sent to the FSL, and the charge was altered to Section 304 Part-II of the IPC, reflecting the investigation’s seriousness.
They further submitted:
- Proper medical treatment was provided to the deceased in line with standard protocols.
- Aakash Institute had no control over the hostel accommodation chosen by the family and could not be held vicariously liable.
- Relying on Arnab Ranjan Goswami v. Union of India, counsel argued that mere dissatisfaction of a complainant is not a ground for transferring an investigation to the CBI, a power to be used “sparingly” and in “rare and exceptional cases.”
The Court’s Analysis and Decision
The Supreme Court began its analysis by reiterating the legal principle that the power to transfer an investigation to the CBI is an “extraordinary power” to be exercised cautiously, citing State of West Bengal v. Committee for Protection of Democratic Rights, West Bengal. However, the Bench found that the present case presented “compelling factors” demonstrating the “ineffectiveness of the local police officials.”
The Court found the following factors conclusive for ordering a CBI probe:
- Unsubstantiated Suicide Theory: The narrative of suicide was deemed a “post-facto justification aimed at diluting the gravity of the incident,” as no suicide note was found, and no evidence of psychological history was established.
- Contradictory Evidence: Glaring inconsistencies in the CCTV footage regarding the deceased’s clothing were never reconciled by the investigators.
- Medical Records vs. AIIMS Report: The claim that the student was unconscious was contradicted by the AIIMS Medical Board, which noted she was admitted in a “conscious and irritable state” with a Glasgow Coma Scale (GCS) score of 10/15. The failure to record her statement in this state reflected “gross medical negligence” and “possible suppression of key evidence.”
- Forensic Lapses: The Court described the premature destruction of the deceased’s viscera before the court-ordered DNA match as an act that “irrevocably compromised the proceedings.”
- Autopsy Inconsistencies: The presence of semi-digested food and a “suspicious smell” in the stomach was found to be “irreconcilable with the claim that the deceased was on continuous ventilatory support.”
- Withholding of Reports: The failure to produce the Chemical Analysis Report and the final cause of death report created “a grave doubt on the bona fides of their actions.”
In light of these findings, the Court concluded that the circumstances were “rare and extraordinary” and that transferring the investigation to the CBI was “not only justified but essential” to ensure fairness and uphold the rule of law.
The Court quashed the High Court’s order and directed the Andhra Pradesh police to hand over all case records to the CBI forthwith. The CBI was directed to complete its investigation and submit a final report within four months.
Part B: Guidelines on Student Mental Health
Beyond the specifics of the case, the Court addressed the “deepening crisis” of student suicides, noting that the case “must not be viewed in isolation.” Citing NCRB data showing 13,044 student suicides in 2022, the Court acknowledged the immense psychological pressure on students.
Invoking its constitutional obligation under Article 21, which guarantees the right to life including mental health, and drawing a parallel to its role in the Vishaka case, the Court issued a set of binding interim guidelines for all educational institutions, including schools, colleges, and coaching centres. Key guidelines include:
- Mental Health Policy: All institutions must adopt and publicize a uniform mental health policy.
- Counsellors: Institutions with over 100 students must appoint at least one qualified counsellor.
- Prohibition of Public Shaming: Coaching centres must refrain from batch segregation based on academic performance and public shaming.
- Institutional Culpability: Failure to act on complaints of harassment, bullying, or discrimination that contributes to self-harm will be treated as “institutional culpability.”
- Safety Measures: Residential institutions must install tamper-proof fans and restrict access to high-risk areas.
- Career Counselling: Institutions must provide structured career counselling to reduce unrealistic academic pressure.
- Monitoring: A district-level monitoring committee chaired by the District Magistrate shall be constituted in each district to oversee implementation.
The Union of India has been directed to file a compliance affidavit within 90 days. The matter is scheduled to be listed again on October 27, 2025, to review compliance.
