Institutional Accountability, Governance Implications And Constitutionalising Mental Health: The Significance Of Sukdeb Saha Verdict

In July 2025, the Supreme Court of India delivered a ruling that reframed the constitutional parameters of mental health significantly. The case was initiated by the petitioner Sukdeb Saha, a bereaved father. He lost his 17-year-old daughter, a NEET aspirant living alone in a hostel in Visakhapatnam, Andhra Pradesh. He alleged that the local police had failed to conduct a critical investigation into her death. Saha approached the Supreme Court, where his petition questioned the accountability of state authorities when the High Court declined to order a more rigorous investigation. Along with transferring the investigation to the CBI, the Court affirmed the importance of mental health as an aspect of the right to life under Article 21 of the Indian Constitution. The judgment marks a jurisprudential shift by transforming mental health from a statutory entitlement to a fundamental right under Article 21. It is a necessary intervention, but it also reflects the failure of legislative and regulatory bodies to address student mental health in time.

Constitutional Grounding

The Supreme Court's decision addressed an important societal issue of rapid increase in number of student suicides in India. From a criminological perspective, the decision focuses on systemic victimization, which is rarely contemplated when it comes to students' deaths. A general lack of awareness about mental health, combined with the intense pressure of coaching centres and the apathy of educational institutions, creates an environment that makes young individuals more vulnerable. The state and its agencies have failed to put proper protective mechanisms in place, allowing such harm to continue. When institutions fail in this way and students are pushed to their limits, it becomes difficult to see these deaths as purely individual tragedies. Questions of institutional responsibility inevitably arise. Traditional victimology has mainly focused on identifiable aggressors, but the Court moves beyond this approach and recognises institutions themselves as sources of harm.

Students are therefore not only dealing with personal distress. They exist within an education system that ignores holistic welfare, promotes competitive ideas of self-worth, and shows ongoing governmental indifference to mental health. By recognising mental health as part of the right to life, the Court treats this form of victimisation as structurally rooted. In doing so, it shifts the understanding of student deaths from isolated personal tragedies to a wider social problem. The judgment also addresses a critical regulatory shortcoming in India's mental health framework. Although the Mental Healthcare Act, 2017 ensures people can access mental health services, there has been absence of standardisation in implementation, and enforcement is also tenuous. The Court has made mental health a fundamental right, thereby establishing a higher standard. This elevation is consistent with principle of constitutional morality. Psychological well-being can now be asserted as a right instead of a statutory advantage. To make sure that this decision results in a move and does not remain on a symbolic plane, the Court made interim directives, which became the Saha Guidelines, binding on the schools, colleges, hostels, and coaching centres to establish adequate mental health support systems. It directed states and union territories to operationalise these guidelines to the best of their ability in two months and required monitoring bodies at the district level. These guidelines operate with binding normative force as interim judicial legislation until Parliament enacts a comprehensive statutory framework. The Court's reliance on interim guidelines raises questions about how far judicial directions can substitute sustained policy action. Another important issue that is raised due to the judgment concerns state accountability. When institutional dereliction results in student suicides, is it possible to observe that institutional neglect is a form of structural violence?

According to the theory of Johan Galtung, the harm inflicted by the breakdown of social systems that provide individuals with the primary needs is as severe as the actual violence.The state and institutions fail to provide the necessary safe educational conditions, which leads to the creation of detrimental circumstances. This transforms the perception regarding student suicides as individual failures, turning it into an indication of institutional injustice. The ruling in the victimological sense reveals the victims who have always been overlooked. The students who have been starved with stigma or have been cut-throat subjects of scholastic settings have rarely been recognised as rights-bearing persons in mental health discourse. 

Psychological integrity should be included in Article 21, so that their grievances can be addressed and the path to restoration, such as counselling systems, institutional changes, and prevention-oriented accountability measures, can be opened. Inasmuch as mental health professionals and the activists have hailed the decision on the impacts it may have on it, caution should be taken. Uncomplicated utterances of the judiciary may prove insufficient to change deeply rooted cultural attitudes or institutional resistance. The question of whether or not learning institutions and governments would go ahead and adhere to the guidelines, open up resources and train people to offer real mental health help is the real question.

Way Forward 

India cannot afford to take this verdict as a symbolic statement. The educational institutions need well structured mental health models which are based on professional counselling, crisis intervention and follow-up. The staff members of the hostel, teachers, and administrators would be sensitized to recognise the signs of distress and treat them appropriately. The regulation of the coaching centres is necessary so that they can eliminate bad habits and embrace the most appropriate ethical standards that will enhance the wellbeing of the students. A policy on student mental health at the educational and institutional level is central in order to integrate well-being into the strategy of teaching and institutions. The reduction of unhealthy competitiveness may be achieved through exam changes, reduced focus on high-stakes testing, and a return to comprehensive learning. Beyond institutions, society has to face and alter the cultural discourses that glorify stress, humiliation, and equate success with academic success only.

The Sukdeb Saha verdict represents an important development in Indian constitutional law and education governance. By proclaiming mental health as one of the essential rights, the Court has shown that such persistent pressure of institutions and system may be damaging. It clarifies that students cannot be treated merely as recipients of instruction, but as individuals entitled to psychological safety and dignity within educational spaces. The practical value of the judgment will depend on how far governments and institutions act upon this recognition in their everyday functioning. While the decision acknowledges harms that have long remained unaddressed, its impact will remain limited unless followed by sustained institutional action. If institutional actors fail to respond meaningfully, the constitutional recognition of mental health risks remaining declaratory rather than effective.

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