Suicide Of Child Requires Different Investigative Approach Than Adult: Karnataka High Court Rejects Closure Report

The Karnataka High Court has recently quashed a trial court order accepting police's second 'B' report in a case involving the alleged suicide of a student who is claimed to have left behind a death note stating 'marks is not everything' while naming her principal, teachers, and classmates. [2026 LiveLaw (Kar) 320]

The single judge bench of Justice M. Nagaprasanna, while allowing the criminal petition filed by the mother of the deceased, noted:

“…In the considered view of this Court, the case could not have been closed by accepting the 'B' report. The re-investigation proceeded on a completely different footing on a wrong provision of law that it is an abetment to suicide of an adult under Section 306 of the IPC, while it was an abetment to suicide of a child under Section 305 of the IPC. If it is abetment to suicide of a child, the rigours of investigation would be completely different. The analysis and examination of the outcome of the investigation again would completely differ as the psychological impact of any harassment of the school or teachers on a child, compared to the adult, is different…”, the court pointed out that this difference was not taken into account by the trial court or the investigating officers.

The court also noted that the investigating officers failed to give due significance to death note and FSL report about the same.

“…Accused No.4/the 5th respondent - mathematics teacher is said to have hurled abuses intermittently. The principal is said to have hurled abuses against the child repeatedly that she was 34 ruining the reputation of the school by bringing in bakery products to the school…”, the court noted from the complaint.

The plea was filed challenging a trial court order that accepted the B report filed by the police in an FIR registered under Sections 306(abetment to suicide), 34 (common intention) IPC lodged against the management, principal and teachers of a school where her daughter was studying.

The petitioner was the mother of a 9th standard student in a private school at Hesaraghatta, Bengaluru.

In 2022, the student had gone missing from her home, and her body was later found by a loco pilot between Yeshwanthpur and Chikkabanavara railway stations which suggested suicide.

The police registered an unnatural death report, and upon investigation, found a death note in a book, allegedly written by the deceased student, insinuating the principal, teachers and other students while adding that 'marks are not everything'. After FSL, it was confirmed the handwriting was that of the victim.

The complaint against the school administration was registered almost a year after the incident, on March 20, 2023, after the petitioner and her husband approached the Human Rights Commission against the school.

The High Court in its order noted :

“…A perusal at the 'B' report would indicate that the victim was not able to score high marks due to change in syllabus. The investigation comes to a conclusion indicating that the rules of the School were not followed by the victim as she was bringing bakery products to school. In the opinion of the Investigating Officer, the parents are said to have scolded the victim to sleep before the day of her exam and neglected her. These findings are recorded by the Investigating Officer without even recording the statement of the mother of the victim after the registration of the complaint in Crime No.26 of 2023”.

It is pertinent to note here that the trial court had rejected the first B Report filed by the police in the matter, reasoning that IO had not enquired into the circumstances surrounding the child's death when even the FSL report has verified the death note as written by the deceased child.

However, the trial court accepted the second 'B' report filed by another investigating officer on the grounds that the deceased was psychologically not adjusted to the new syllabus, and that teachers scolding students for eating junk food cannot be termed as bullying. It was also stated by the police that the parents were not taking adequate care of the deceased.

However, the High Court refused to validate such acceptance of B report by the trial court.

“…A perusal at the documents that are produced along with the petition would indicate that the statement of the victim's parents was taken on 17-02-2022, on the date of death and no statement is recorded after registration of the crime in Crime No.26 of 2023. The witness statements of the Principal, teachers and other staff were taken in December, 2023 after investigation was handed over to the second Investigating Officer. The second Investigating Officer does nothing new, but, repeats the old saga. Therefore, it becomes a classic case where reinvestigation into the matter must ensue, but not at the hands of the same jurisdictional police…”.

Hence, the court rejected the B report and consequently, the trial court accepting the said B report, while directing fresh investigation by a different Investigating officer of different jurisdictional police.

“….The competent authority is directed to entrust the matter to a different Investigating Officer of a different jurisdictional Police to conduct re-investigation into the matter; monitor the said investigation and place the report of investigation papers before the concerned Court, within three months from the date of its entrustment in Crime No.26 of 2023…”, the court concluded.

Quashing the B report, the court directed the competent authority to entrust the matter to a different Investigating Officer of a different jurisdictional Police to conduct re-investigation into the matter; monitor the investigation and place the report  before the concerned Court, within three months from the date of its entrustment.

Case Title: Smt. Kavitha Murthy v. State of Karnataka & Ors.

Case No: Criminal Petition No.17375 of 2025

Citation: 2026 LiveLaw (Kar) 320

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