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. 1-2On 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. 3The 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. 4Issues
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. 4-62. 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, 6Law 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, 4Procedural provisions of Section 482 of the Bharatiya Nagarik Suraksha Sanhita (BNSS), 2023, concerning the grant of anticipatory bail
Source reference: para. 1Doctrine of parity, noting that co-accused persons had already been granted similar relief
Source reference: para. 4Reasoning
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. 4The court observed that the alleged threats were purportedly extended to the children rather than the deceased himself
Source reference: para. 4Finding 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. 6Holding
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. 7Original Court PDF
Yogesh Alias Yogendra SisodiyavsThe State Of Madhya Pradesh
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