Madhya Pradesh High Court

Mere matrimonial discord and common household disputes do not constitute abetment to suicide under Section 306 IPC.

The State Of Madhya Pradesh vs Rupkumar

Madhya Pradesh High CourtJUDGMENT: June 18, 20262 MIN READSOURCE JUDGMENT
THE ORIGINAL LAWLENS SUMMARY
01

Facts

The deceased, Rajendra, married respondent Bharti in June 2018. The prosecution alleged that Bharti pressured the deceased to live separately from his disabled mother, leading to frequent disputes

Source reference: para. 2

On 03.02.2019, Bharti’s parents (respondents Rupkumar and Anita) allegedly argued with and physically assaulted Rajendra in public, telling him to "die" and "hang himself"

Source reference: para. 2

The following day, Rajendra’s body was found on a railway track

Source reference: para. 2

A charge sheet was filed under Section 306 IPC (Abetment of Suicide). The Trial Court acquitted the respondents on 25.11.2022, finding the prosecution failed to prove instigation

Source reference: para. 1

The State appealed this acquittal, seeking leave to appeal under Section 378(III) Cr.P.C.

Source reference: para. 1
02

Issues

1. Whether the alleged acts of the respondents, including verbal abuse and matrimonial discord, constitute "instigation" or "abetment" under Section 306 read with Section 107 of the IPC

Source reference: para. 10-18

2. Whether the High Court should interfere with a trial court's judgment of acquittal when the view taken by the trial court is a "plausible view"

Source reference: para. 21-26
03

Law Applied

Section 306 of the IPC regarding abetment of suicide and Section 107 of the IPC, which defines abetment as instigation, conspiracy, or intentional aid.

Source reference: para. 11, 10

Abetment requires mens rea and an active act intended to push the deceased into suicide (S.S. Cheena v. Vijay Kumar Mahajan).

Source reference: para. 13

Without a positive act to instigate, a conviction cannot be sustained (M. Mohan v. State).

Source reference: para. 14

An appellate court should not overturn an acquittal if the trial court’s view is legally plausible, even if an alternative view exists (H.D. Sundara v. State of Karnataka and Mallappa v. State of Karnataka).

Source reference: para. 22, 26
04

Reasoning

The Court observed that the marriage was initially happy and no dowry was demanded. While the prosecution witnesses (relatives of the deceased) alleged a dispute on 03.02.2019, their testimonies contained material contradictions, omissions, and improvements.

Source reference: para. 18

Notably, no police complaint was filed regarding the alleged cruelty until 11 days after the death (15.02.2019), and initial police intake forms (Safina Form/Dehati Nalishi) contained no such allegations.

Source reference: para. 18

The Court noted that the respondent wife was two months pregnant at the time, indicating a degree of domestic harmony.

Source reference: para. 20

Applying the cited precedents, the Court reasoned that "ordinary matrimonial disagreements" or verbal outbursts like "go and die" during a heated argument do not amount to the deliberate mens rea required for "instigation" under Section 107 IPC.

Source reference: para. 16, 20-21
05

Holding

The High Court held that the prosecution failed to prove the essential ingredients of abetment beyond reasonable doubt.

The High Court dismissed the application for leave to appeal and the criminal appeal, affirming that the Trial Court's judgment was not perverse and represented a plausible view based on the evidence.

Source reference: para. 28, 21, 27
Madhya Pradesh High Court

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The State Of Madhya PradeshvsRupkumar

Madhya Pradesh High Court · June 18, 2026

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