Allegations in Abetment to Suicide Case Cannot Travel Beyond Contents of Suicide Note: Telangana HC [Read Order]

Telangana: The High Court for the State of Telangana at Hyderabad, in a significant ruling, partly allowed a criminal petition seeking quashing of proceedings in a case registered for abetment of suicide, holding that the allegations made in a complaint lodged by the son of the deceased cannot travel beyond the contents of the suicide note left behind by the victim.

The Bench of Justice Tirumala Devi Eada, while quashing the proceedings against ten of the thirteen accused persons, held that continuing criminal proceedings against accused who are not specifically named in the suicide note would amount to an abuse of process of law.

The prosecution alleged that the petitioners had abetted the suicide of the victim by harassing him through a false complaint filed against him, alleging that he had outraged the modesty of a woman, and that the victim, unable to bear the humiliation, committed suicide.

As per the complaint filed by the son of the deceased, the petitioners were celebrating the Dasara festival when local residents, including the victim, raised objections and complained to the Station House Officer. When no action was taken, they dialed the emergency number 100. It was alleged that thereafter the petitioners went to the victim’s house, abused him in filthy language, and threatened to kill him if he stepped out.

On the following day, October 3, 2025, the Sub-Inspector of Police called the victim to the police station, where he informed the SHO about the threats and sought protection. It was further alleged that the petitioners got a complaint lodged by accused No. 11 against the victim under the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act and provisions of the Bharatiya Nyaya Sanhita (BNS), alleging that he had outraged her modesty.

The son of the victim further alleged that his father enjoyed a good reputation and had a political background, and that the petitioners fabricated false allegations as his political progress was not acceptable to them. It was also alleged that the victim was harassed by the police over phone calls on the morning of October 10, 2025. Unable to bear the humiliation of being falsely implicated, he allegedly went to a nearby forest the same morning and died by suicide by hanging.

The petitioners, on the other hand, submitted that they were celebrating the Bathukamma festival when the victim allegedly entered the venue with others, created a disturbance, and pulled the hand of accused No. 11, thereby outraging her modesty.

They contended that accused No. 11 accordingly lodged a complaint on October 3, 2025, for offences under the SC/ST (Prevention of Atrocities) Act and the BNS. The petitioners argued that the present case, registered on October 10, 2025, was a counterblast to that complaint and that they were in no way responsible for the victim’s suicide.

Counsel for the petitioners further submitted that mere registration of a criminal case would not amount to abetment of suicide, as the essential ingredients of abetment were not made out even on the basis of the complaint averments. It was argued that the suicide note did not disclose any specific act of harassment by the petitioners instigating the victim to commit suicide. It was also contended that it was beyond imagination that all thirteen persons would have instigated the victim to take his life. Additionally, it was submitted that the police failed to follow the procedure laid down under the Bharatiya Nagarik Suraksha Sanhita and did not conduct a preliminary inquiry as required, in violation of the guidelines laid down in State of Haryana v. Bhajan Lal.

Upon perusal of the record, the Court noted that the suicide note specifically attributed responsibility to accused Nos. 1 to 3 for the death of the victim. The Court also observed that even the name of accused No. 11, who had lodged the earlier complaint in FIR No. 95 of 2025, did not figure in the suicide note.

The Court further observed that although accused No. 11 appeared to have lodged the complaint at the instigation of accused Nos. 1 to 3, the mere act of initiating legal proceedings cannot, by itself, amount to abetment of suicide. The Court held that the allegations in the complaint lodged by the son of the victim cannot travel beyond the contents of the suicide note, and that making out a prima facie case against accused Nos. 4 to 13 would not be justified.

The Court distinguished the present case from the judgments relied upon by the petitioners in Madan Mohan Singh v. State of Gujarat, Ayyub and Ors. v. State of Uttar Pradesh, Rajesh @ Raja Yadav v. State of M.P., and Atul Kumar v. State of NCT of Delhi, holding that those decisions were not applicable in view of the specific factual matrix, including the alleged false complaint, the victim’s reputation in the village, and the humiliation allegedly suffered by him.

The Court held that the questions regarding the truthfulness of the allegations and the proximity between the alleged act of abetment and the act of suicide are triable issues to be determined by the trial court. Accordingly, it declined to quash the proceedings against petitioner Nos. 1 to 3.

The criminal petition was thus partly allowed.

The proceedings in Crime No. 99 of 2025 on the file of Neelwai Police Station, Ramagundam, were quashed against petitioner Nos. 4 to 13 (accused Nos. 4 to 13), while the petition in respect of petitioner Nos. 1 to 3 was dismissed, and proceedings against them were directed to continue.

Appearances:
For the Petitioners: Sri V. Raghunath, Senior Counsel, representing Ms. V. Sanjana, Advocate-on-Record
For the Respondents: Sri Prabhakar Rao, Senior Counsel, representing Sri K. Sanjeev, Advocate-on-Record for Respondent No. 2; Sri Jithender Rao Veeramalla, Additional Public Prosecutor for Respondent No. 1 – State of Telangana

Case Title: Rudrabatla Santhosh Kumar and 12 Others v. State of Telangana & Another, Criminal Petition No. 13500 of 2025

[Read Order]