Teacher Reprimanding Student For Irregular Attendance, Poor Academic Performance Not Abetment Of Suicide: Rajasthan High Court

The Rajasthan High Court has quashed charges under Section 305 IPC against teachers accused of abetting the suicide of a Class XII student, holding that mere reprimand or disciplinary action for poor attendance, academic performance or indiscipline cannot amount to abetment of suicide in the absence of instigation, intentional aid or the requisite mens rea. [2026 LiveLaw (Raj) 304]

The bench of Justice Kuldeep Mathur observed that the relationship between a teacher and a student is founded on discipline, guidance and academic supervision, and teachers are duty-bound to maintain discipline in educational institutions.

“A teacher is duty bound to maintain discipline and may legitimately reprimand a student for irregular attendance, poor academic performance or indiscipline. Such acts, performed in the ordinary course of discharging professional duties, cannot, by any stretch of imagination, be construed as instigation or intentional aid to commit suicide.”

The Court was hearing revision petitions against the order of the trial court that took cognizance against the petitioners under who were accused of abetting the suicide of a Class 12^th student, under Section 305, IPC.

For context, a complaint was filed by the deceased's father, with the allegations that the petitioners used to harass and insult the deceased, and were attempting to get her expelled from school, owing to which she hanged herself to death, leaving behind a suicide note.

On the contrary, it was submitted by the petitioners that a negative police report was filed which concluded that since the deceased was irregular in attending classes and was not studying properly, she was reprimanded by her teachers. Due to such reprimand, she felt distressed and committed suicide.

The petitioners further argued that before the offence under Section 305, IPC, could be made out, ingredients of abatement under Section 107, IPC, had to be established, which were missing in the present case since neither instigation nor intentional aid was reflected from the material on record.

After hearing the contentions, the Court highlighted, “the Investigating Agency, during the course of investigation, found that the deceased was not attending classes regularly and was repeatedly advised by her teachers to attend classes, prepare for her studies and appear in the regular class tests…she was asked to bring her father to the school if she continued to remain irregular.”

In this background, the Court held that for constituting offence under Section 305, IPC, ingredients under Section 107, IPC must be first established.

While underscoring the duties of a teacher, the Court opined that the acts of reprimanding or criticising for ensuring discipline, performed in the ordinary course of discharging professional duties by teachers, could not be construed as instigation or intentional aid to commit suicide.

It was stated that prima facie there was no material on record to suggest that the petitioners possessed requisite mens rea or committed any positive act to drive the deceased to commit suicide, or created any such circumstances that left her with no other option.

Accordingly, the revision petitions were allowed, and the charges framed against the petitioners were set aside.

Title: Smt. Swarna Kalra & Anr. v State of Rajasthan & Anr., and other connected petitions

Citaiton: 2026 LiveLaw (Raj) 304

For Petitioners: Mr. Muktesh Maheshwari; Mr. Abhishek Mehta

For Respondents: Mr. Sri Ram Choudhary, PP; Mr. D.S. Gharsana

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