Student Suicide: MP High Court Upholds Discharge Of College Chairman, Says Fee Hike, Stipend Disputes Don't Constitute Abetment
The Madhya Pradesh High Court has upheld the discharge of the Chairman and the Head of the Anaesthesia Department of a medical college in a case relating to the suicide of a postgraduate medical student, holding that disputes over fee hike, denial of leave, stipend deductions and other administrative issues, without any direct instigation or mens rea, do not constitute the offence of abetment...
The Madhya Pradesh High Court has upheld the discharge of the Chairman and the Head of the Anaesthesia Department of a medical college in a case relating to the suicide of a postgraduate medical student, holding that disputes over fee hike, denial of leave, stipend deductions and other administrative issues, without any direct instigation or mens rea, do not constitute the offence of abetment of suicide under Section 306 IPC. [2026 LiveLaw (MP) 298]
The bench of Justice Jai Kumar Pillai observed:
"Upon a careful and circumspect scrutiny of the material available on record, it is clear that the case of abetment of suicide does not met. The allegations leveled by the prosecution reflect civil and administrative disputes which inherently lack the proximate mens rea required by law to substantiate a grave charge under Section 306 of the IPC".
A revision was filed by the State challenging the order of November 14, 2022, of the Trial Court wherein private respondents no 1 and 2 were discharged from serious charges framed for abetment of murder (Section 306 of IPC).
Per the prosecution, the brother of the deceased forwarded information to the authorities regarding the death of his sister, who was pursuing her Doctor of Medicine degree from Index Medical College in Indore, due to the administration of an anaesthetic injection from a bottle.
The informant had received this news through a phone call made by the deceased's batch-mate. An FIR was filed on July 7, 2018. Following an initial inquiry, an FIR was registered against accused Suresh Bhadoria, who was the Chairman of Index Medical College and Dr K.K. Khan, who is the head of the Anaesthesia Department.
The investigation also discovered a deceased's suicide note alleging that she committed suicide because the accused persons arbitrarily demanded excessive fees. The note asserted that she was subjected to severe mistreatment and was continuously tortured by management and the department head.
The Trial Court, thereafter, framed the charges but discharged the accused men after hearing the arguments advanced by both parties.
The counsel for the revisionists contended that the Trial Court's order of discharge was neither proper nor correct in its appreciation of the material. The counsel claimed that respondent no 1 and 2 had a direct and undeniable role in inciting the deceased to commit suicide.
The counsel for the revisionist claimed that the accused men had continuously harassed and abetted the deceased by arbitrarily demanding an extra unauthorised fee of ₹4 Lakh over the rightfully determined fees of ₹8.55 Lakhs.
The counsel further referred to a previous writ petition no 18901/2016 challenging the arbitrary demand of excess fees and is currently pending with the Jabalpur Bench of the High Court.
The counsel for the State opposed the petition, arguing that the reasoning adopted by the Trial Court was well reasoned and legally sound. The counsel argued that the administrative act of demanding fees or managing academic affairs was not the direct and proximate cause of the suicide. The prerequisite of the essential element of mens rea was entirely lacking in the present case.
Following the Supreme Court's established principles, the bench held that to establish a charge of abetment, the prevailing law dictates that the act of the accused must inevitably be the direct and proximate cause of the tragic suicide.
The court, examining the deceased's suicide note, noted that it mentions the accused men but also mentions multiple circumstances and was addressed to several persons.
Further, it was noted that the Trial Court's order was well reasoned. The Trial Court found that the deceased was in a live-in relationship with the batch mate who informed her brother. The Trial Court noted that the batch mate's refusal to marry her due to their age difference of 4 years caused her severe depression and led to frequent quarrels.
From the Trial Court's order, the bench noted that the deceased's suicide note was not recovered from the deceased's immediate possession but from the batch mate. Even a witness testified to seeing the batch mate hurriedly hiding a note in his drawer.
The bench further concurred with the Trial Court's order, observing glaring flaws in the prosecution's case, including the cut, copy and paste mechanism to witness statements.
Regarding the students' ongoing petition, the court noted that the High Court had granted an interim stay, granting protection to the deceased and 29 other students.
From the evidence and prosecution documents on record, the court held, " that the dispute over the fee hike, denial of leave by the college HOD, deduction of stipend amount for absence, and the alleged harassment for filing a writ petition, cannot be legally construed as reasons that instigated the deceased to commit suicide".
Therefore, the bench concluded that the Trial Court's discharge order was perfectly legal and does not warrant any revisional interference. The petition was thus dismissed.
Case Title: State of Madhya Pradesh v Suresh Bhadoriya, CRR 2586/2024
Citation: 2026 LiveLaw (MP) 298
For State: Government Advocate Aditya Garg
For Respondent: Advocate Hemendra Jain