Madhya Pradesh High Court

Allegation of harassment for loan recovery without specific instigation does not constitute abetment of suicide.

Yogesh Alias Yogendra Sisodiya vs The State Of Madhya Pradesh

Madhya Pradesh High CourtJUDGMENT: May 08, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The applicant sought anticipatory bail regarding Crime No. 88/2026 registered at P.S. Morar for the offence of abetment of suicide

Source reference: para. 1-2

On September 15, 2025, one Ramesh Singh Parmar died by consuming poison. An inquiry under Section 194 of the Bharatiya Nagarik Suraksha Sanhita (BNSS) led to the recovery of a suicide note alleging that the applicant and others harassed him for loan recovery

Source reference: para. 3

The applicant contended that the allegations were vague, omnibus, and lacked evidence of direct instigation. Furthermore, statements from the deceased’s children suggested threats were directed at them, not the deceased

Source reference: para. 4
02

Issues

1. Whether the allegations of harassment for loan recovery, as stated in the suicide note and investigation, constitute "abetment" under the law sufficient to delete anticipatory bail

Source reference: para. 4-6

2. Whether the applicant is entitled to the protection of anticipatory bail under Section 482 of the Bharatiya Nagarik Suraksha Sanhita, 2023

Source reference: para. 1, 6
03

Law Applied

Section 108 of the Bharatiya Nyaya Sanhita (BNS), 2023, regarding abetment of suicide, which requires a specific act of instigation, provocation, or active participation

Source reference: para. 2, 4

Procedural provisions of Section 482 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, concerning the grant of anticipatory bail

Source reference: para. 1

Doctrine of parity, noting that co-accused persons had already been granted similar relief

Source reference: para. 4
04

Reasoning

The court evaluated whether the applicant's conduct met the threshold for "abetment." It noted the applicant's argument that mere allegations of harassment for loan recovery do not amount to abetment in the absence of a proximate or direct act driving the deceased to suicide

Source reference: para. 4

The court observed that the alleged threats were purportedly extended to the children rather than the deceased himself

Source reference: para. 4

Finding that the material did not suggest a risk of the applicant fleeing from justice and considering the lack of specific instigation attributed to the applicant, the court determined that the applicant was fit for bail

Source reference: para. 6
05

Holding

The court allowed the application and granted anticipatory bail

The applicant was directed to be released, in the event of arrest, upon furnishing a personal bond of Rs. 50,000 with one solvent surety, conditioned upon cooperating with the investigation, not threatening witnesses, and not leaving the country without permission

Source reference: para. 7
Madhya Pradesh High Court

Original Court PDF

Yogesh Alias Yogendra SisodiyavsThe State Of Madhya Pradesh

Madhya Pradesh High Court · May 08, 2026

Click to open original judgment

Original judgment, available to read, download and summarize on LawLens.in

Click to open original judgment