The Madhya Pradesh High Court has observed that a case of suicide cannot be closed merely on a prima facie assessment that the deceased died by suicide, holding that the police must examine material indicating possible abetment before concluding the investigation. 

The bench of Justice Himanshu Joshi observed:

"The fact that the death was prima facie a case of suicide by hanging also does not, by itself, bring the matter to an end. Where material is brought before the police suggesting that the deceased may have been subjected to conduct which could have contributed to or facilitated the commission of suicide, the investigating agency is required to examine such material in accordance with law". 

A plea was filed by the deceased's mother, who claimed that her son died on the intervening night of July 12-13, 2025, in a hotel in Burhanpur. Upon information from the hotel manager, an inquest intimation was registered, and a post-mortem was conducted. The reason for death was asphyxia as a result of hanging. 

The petitioner alleged that her son, before his death, had uploaded a video on his Facebook account wherein he blamed his wife, his father-in-law, and his wife's relatives for the circumstances which led to his death. The petitioner claimed that she approached the police authorities and submitted a representation before the Superintendent, Chief Minister, and Inspector General of Police, but no action was taken. 

The petitioner stated that her other son sought information regarding the investigation under the Right to Information Act, but he was informed that the investigation was still under process. The petitioner alleged that despite multiple representations, the police are treating this matter as a mere matrimonial dispute. 

The counsel for the petitioner argued that the deceased had made a video before his suicide naming multiple people for his death, which should be investigated properly. 

The government advocate for the State opposed the petition, stating that the Merg (preliminary) Inquiry was already under investigation. Further, it cannot be concluded that there was commission of any offence merely based on the allegations made by the petitioner. 

The court deemed it appropriate to direct the Superintendent of Police to ensure that the investigation is conducted by a police officer not below the rank of Deputy Superintendent of Police. 

Accordingly, the petition was disposed of with the following directions

"(i) The Superintendent of Police, Burhanpur, shall ensure that the investigation/inquiry arising out of Merg/Inquest Intimation No.06/2025 dated 13.07.2025, Police Station Kotwali, District Burhanpur, is conducted fairly, impartially and expeditiously.

(ii) The investigation shall be entrusted to a responsible officer, preferably not below the rank of Deputy Superintendent of Police, other than any officer against whom allegations of bias or involvement have been specifically raised.

(iii) The investigating officer shall examine the alleged video uploaded by the deceased, its authenticity and source, the original electronic record and other relevant electronic evidence, besides recording the statements of relevant witnesses and examining all circumstances preceding and surrounding the death.

(iv) The representations submitted by the petitioner, including those dated 12.08.2025 and 23.10.2025, filed as Annexure-P/4, shall also be taken into consideration.

(v) Upon completion of the requisite inquiry/investigation, if the material discloses commission of a cognizable offence, appropriate proceedings shall be initiated in accordance with law. If no cognizable offence is found to have been made out, the competent authority shall take a reasoned decision in accordance with law.

(vi) The Superintendent of Police, Burhanpur, shall monitor the progress of the investigation and ensure that the same is brought to its logical conclusion expeditiously, preferably within a period of three months from the date of production of a certified copy of this order". 

Case Title: LBD v State of Madhya Pradesh, WP-18696-2026

Citation: 2026 LiveLaw (MP) 355

For Petitioner: Advocate Santosh Anand 

For State: Government Advocate Priyanka Mishra

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