Actress Prathyusha's Death : Supreme Court Rules Out Murder; Convicts Siddhartha Reddy For Abetment Of Suicide

The Supreme Court today dismissed the plea filed by Gudipalli Siddhartha Reddy, who challenged his conviction on the charge of abetment to suicide in 23 years old case of the suicide of Telugu/Tamil actress Prathyushya.

A bench comprising Justice Rajesh Bindal and Justice Manmohan pronounced the judgment. The bench also dimissed the plea by Prathyushya's mother Sarojini Devi who alleged that death was due to murder.

It ruled out murder by strangulation and observed that the overwhelming ocular and medical evidence proves death due to poisoning.

"One is, murder by strangulation is ruled out. Two, overwhelming ocular and medical evidence proves death due to poisoning. Three, the offence of rape against the appellant accused is not made out. Four, at the belated stage, it is difficult to allege that the cause of death was rape and strangulation...defense of accidental consumption rejected. Abetment by purchase of neurontone established," the bench pronounced.

As per the brief facts, Prathyushya and Reddy were in a relationship which was opposed by the latter's parents. It was the case that they consumed poison together, but Reddy survived. Later, he was convicted on charges of abetment to suicide and attempt to suicide. He was sentenced to five years of imprisonment, which was later reduced to two years by the Andhra Pradesh High Court in 2004.

Challenging his conviction on the charge of abetment to suicide, he approached the Supreme Court. Prathyushya's mother also approached the Supreme Court, challenging the reduction of the sentence to Reddy. She alleged that her daughter was raped and poisoned. During the hearing, the appellant was granted bail. The Court had also called for the postmortem report of Dr B Muni Swamy, who had expressed that the death of the actress was caused due to strangulation. However, Dr Muni Swamy was not examined during the course of the trial. 

"Five, Dr Muni Swamy had furnished an unprofessional postmortem report. Six, consequences of premature and deliberate publication of the report."

However, the Court rejected the allegation of rape. 

"...surviving partner in a mutual suicide pact is legally culpable. Conclusion is, due to the above reasons, the present appeal on merits is dismissed subject to the no order as to the cost. The appellant is directed to surrender within four weeks."

Senior Advocates Nagamuthu and L. Narasimha Reddy appeared for the accused.

Senior Advocate Nachiketa Joshi appeared for the CBI.

Advocate Gireesh Kumar appeared for Sarojini Devi, mother of Prathyusha.

Headnote

Criminal Law — Indian Penal Code, 1860 — Sections 306, 307, and 109 — Abetment of Suicide — Suicide Pacts — Culpability of the Surviving Partner - Held: The survivor of a mutual suicide pact is legally culpable for the abetment of the other's suicide under Section 307 of the IPC - A suicide pact involves mutual encouragement and a reciprocal commitment to die together, where the survivor's presence and participation act as a direct catalyst for the deceased's actions - The resolve of each party is reinforced and strengthened by the participation of the other; if not for the active participation of both parties, the act would not occur - The law treats such conduct as abetment because the State has a fundamental interest in preserving life, and any assistance in ending it is a crime against the State.

Criminal Procedure — Evidence — Section 313 CrPC — Adverse Inference — Failure to Explain Incriminating Circumstances - Held: When an accused gives incorrect or false answers or maintains complete denial regarding facts within their exclusive knowledge during a Section 313 CrPC statement, the court is entitled to draw an adverse inference - In this case, the Appellant-Accused denied his relationship with the deceased and even his admission to the hospital despite overwhelming evidence to the contrary - Such conduct fails to meet the explanation expected of a person of normal prudence and tilts the case in favor of the prosecution.

Medical Jurisprudence — Postmortem Examination — Professional Misconduct — Premature Disclosure to Media - Held: The conduct of an autopsy surgeon in furnishing an erroneous report based on "naked eye" observations—without waiting for forensic (FSL) results and publicizing sensational claims to the media constitutes professional misconduct and contempt of court - Such actions spread misinformation, erode trust in investigative agencies, and violate the sub judice rule - Justice is served by truth established through impartial investigation, not by following majority sentiment or public pressure amplified by premature media reports. [Relied on Munna Kumar Upadhyay Alias Munna Upadhyaya vs. State of Andhra Pradesh, (2012) 6 SCC 174; State of W.B. vs. Mir Mohammad Omar & Ors., (2000) 8 SCC 382; Raj Kumar vs. State of Madhya Pradesh, (2014) 5 SCC 353; Abhinav Mohan Delkar vs. State of Maharashtra, 2025 SCC Online SC 1725; Patel Babubhai Manohardas vs. State of Gujarat, 2025 SCC Online SC 503; Paras 102-106, 110, 117-119]

Case Details: GUDIPALLI SIDDHARTHA REDDY v STATE C.B.I.|Crl.A. No. 457/2012 and P SAROJINI DEVI v.CBI |Crl A 894-895/2012

Citation : 2026 LiveLaw (SC) 166

Click here to read the judgment

Also from the judgment - Surviving Partner In Mutual Suicide Pact Liable For Abetment :Supreme Court