10 July 2024 Criminal Appeals & Suspension of Sentence >> Criminal Law   |   FIR >> Criminal Law  

In a significant ruling of Rohini Sudarshan Gangurde v/s The State of Maharashtra & Another, the Supreme Court has overturned a decision by the Bombay High Court regarding the case of Rohini Sudarshan Gangurde, accused of abetting the suicide of her husband, Sudarshan Gangurde. This article delves into the details of the case, examining the court's reasoning and the legal principles applied.

Case Background:

Rohini Gangurde was accused under Section 306 of the Indian Penal Code (IPC) following the tragic suicide of her husband on February 17, 2020. Sudarshan, aged 38, was found hanging in their shared residence in Shingnapur. His mother, Smt. Usha Gangurde, filed a complaint alleging that her son had been subjected to physical and mental harassment by Rohini, which led him to take his own life.

The couple had a tumultuous relationship marked by disputes over finances and property. Despite their love marriage in 2015, issues reportedly arose over Sudarshan's drinking habits and Rohini's alleged demands regarding their jointly owned home. Following Sudarshan’s death, a First Information Report (FIR) was lodged, culminating in a chargesheet filed by the police on November 4, 2020.

Judicial Proceedings:

The Trial Court rejected Rohini's application for discharge from the charges on February 24, 2022. Subsequently, the High Court dismissed her revision application on September 5, 2023, leading to her appeal to the Supreme Court. The crux of the Supreme Court's deliberation centered on whether there was sufficient evidence to establish that Rohini had played an active role in instigating or aiding Sudarshan's suicide, as required by Sections 306 and 107 of the IPC.

Legal Framework:

Section 306 of the IPC defines the offense of abetment of suicide, while Section 107 elaborates on the various forms of abetment, including instigation and intentional aid. The Supreme Court emphasized that mere allegations of harassment are insufficient; there must be clear evidence of direct acts that could be construed as instigation. In prior judgments, such as S.S. Chheena v. Vijay Kumar Mahajan and Amalendu Pal v. State of W.B., the court established that to convict someone under Section 306, there must be a clear mental process of instigation or an active role leading to the victim's suicide.

Supreme Court Findings:

Upon reviewing the evidence presented, the Supreme Court found no direct link between the marital disputes and Sudarshan's decision to end his life. The testimonies from Rohini and witnesses indicated ongoing personal struggles, particularly Sudarshan's issues with alcohol, which were significant factors in their troubled relationship. The Court noted that neither Rohini's actions nor any prior indications suggested that she had instigated Sudarshan's suicide. There were no allegations of her suggesting such an act, and the evidence failed to demonstrate any coercive conduct that might have compelled him to take this tragic step.

Conclusion:

The Supreme Court concluded that the prosecution had not established the necessary elements to warrant a charge under Section 306 IPC. As such, the appeal was allowed, the High Court's order was set aside, and Rohini's discharge application was granted. This ruling underscores the necessity for concrete evidence in abetment cases, affirming that emotional distress alone does not equate to criminal culpability. The judgment serves as a reminder of the critical legal standards required to prove abetment of suicide and highlights the importance of a careful examination of all circumstances surrounding such tragic events.

  Indian Penal Code, 1860