“Cannot Travel Beyond Suicide Note": Telangana High Court Quashes Case Abetment Case Against Accused Not Named By Deceased

The Telangana High Court has partly allowed a petition seeking quashing of proceedings in a case registered under Section 108 read with 3(5) of the Bharatiya Nyaya Sanhita (BNS), holding that that continuation of proceedings against accused Nos.4 to 13 would amount to abuse of process of law, considering the victim's suicide note, that did not attribute any fault to them. The Court, however, refused to quash proceedings against accused Nos.1 to 3, who found direct mention in the suicide note.

Justice Tirumala Devi Eada was dealing with a Criminal Petition filed by accused Nos.1 to 13 seeking quashing of Crime on the file of Neelwai Police Station, Ramagundam.

According to the prosecution, the petitioners abetted the suicide of the victim by harassing him through a false complaint alleging that he had outraged the modesty of a woman. It was alleged that, unable to bear the humiliation, the victim committed suicide.

The complaint states that on 02.10.2025, during Dasara festival celebrations, there was an altercation. On 03.10.2025, accused No.11 lodged a complaint against the victim alleging offences under the SC & ST Act and certain provisions of BNS. It was further alleged that the victim, who enjoyed a reputation and a political background in the village, was harassed and humiliated due to the said complaint and subsequently, on 10.10.2025, he committed suicide by hanging.

A suicide note allegedly written by the deceased was placed on record.

The petitioners contended that mere registration of a crime against an individual would not amount to abetment of suicide. It was argued that the ingredients of abetment were not attracted even as per the averments in the complaint, and that the suicide note did not disclose any instigation.

Further, reliance was placed on Madan Mohan Singh v. State of Gujarat, Ayyub v. State of Uttar Pradesh, Rajesh @ Raja Yadav v. State of M.P., and Atul Kumar v. State of NCT Delhi, to contend that specific abetment and intention are required to attract the offence.

The Court observed that the case was registered under Section 108 read with 3(5) of BNS. It noted that the suicide note revealed that accused Nos.1 to 3 were responsible for the death of the victim. The Court further observed that though 13 persons were arrayed as accused, the suicide note specifically referred to accused Nos.1 to 3 and alleged that they were instrumental in getting a false complaint lodged against the victim.

The Court held that issues relating to the truth of the allegations and the proximity between the alleged act of abetment and the act of committing suicide are matters to be decided at trial. Hence, it was noted that the investigation was still in progress and that the prima facie case could not be discarded at the nascent stage.

Importantly, the Court engaged with the contention that mere registration of a crime could not amount to abetment of suicide. Hence, in reference to the accused No. 11, who was instrumental in lodging the complaint at the instigation of the first three accused, the Court held that “lodging of complaint filed by accused No. 11 would amount to initiating a legal proceeding, which cannot be said to be an act abetting the suicide of the victim”.

Moreover, the High Court primarily held that since the suicide note did not attribute responsibility to accused Nos. 4 to 13, holding a prima facie case against them would not be justified.

“It is mentioned in the suicide note that accused Nos. 1 to 13 have abetted the suicide of the victim. Even according to the complaint, it is the victim who suffered the alleged humiliation and it is only the victim who knows about the alleged harassment experienced by him and if at all accused Nos.4 to 13 have also committed any such act of abetting the suicide of the victim, then he could have mentioned the names of accused Nos.4 to 13 also. But, it is revealed from the suicide note that the victim is aggrieved by the acts of accused Nos.1 to 3 and it is specifically alleged that these three people have got the false complaint filed by accused No.11 against the victim…The allegations of the complaint lodged by the son of the victim, cannot travel beyond the contents of the suicide note. In the said circumstances, holding a prima facie case against accused Nos.4 to 11 would not be justified”, the Court said.

Consequently, in view of the above, the High Court quashed the proceedings against them. However, the Criminal Petition was dismissed insofar as petitioner Nos.1 to 3 are concerned.

Miscellaneous petitions, if any pending, were directed to stand closed.

Case Name: Rudrabatla Santhosh Kumar and Ors v The State of Telangana

Case No.: Criminal Petition No. 13500 of 2025

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