05 March 2024 Evidence >> Criminal Law  

Facts:

• Prabhat Kumar Mishra (Appellant), a District Savings Officer, was charged with the offenses of abetment to suicide under Section 306 of the Indian Penal Code (IPC) and violation of Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act (SC/ST Act) following the suicide of his colleague, Data Ram (Deceased).
• A suicide note left by the deceased alleged harassment by the appellant and another coworker, potentially contributing to his decision.
• The investigating officer initially filed a closure report, but later, a charge sheet was filed against the appellant based on the suicide note.

Conclusion:

• The Supreme Court of India quashed the charges against Prabhat Kumar Mishra. The court found that the allegations in the suicide note alone were insufficient to establish abetment to suicide under Section 306 IPC.
• The court determined that the prosecution failed to provide concrete evidence demonstrating the appellant's actions directly caused or incited Data Ram's suicide.
• Additionally, the court concluded that the facts did not warrant invoking Section 3(2)(v) of the SC/ST Act.