Chittibarika Chandra Shekar & Ors. v. The State of Telangana & Anr.

Supreme Court of India • 05 October 2026 • 2026 LiveLaw (SC) 1029; Criminal Appeal arising out of SLP (Crl.) No. 7239 of 2026

Case Summary
The Supreme Court quashed criminal proceedings against six accused for alleged abetment of suicide, holding that a breakup or refusal to marry followed by suicide does not, by itself, constitute abetment under Section 306 IPC. Even accepting the prosecution version, the Court found no material showing that the accused intentionally instigated the deceased to die by suicide or possessed the requisite intention or knowledge. The Court emphasised that people react differently to emotional situations and criminal liability cannot be inferred merely because a breakup or refusal to marry was followed by suicide.

Coram: Justice J.B. Pardiwala; Justice K. Vinod Chandran

Area of Law: Criminal Law — Abetment of Suicide — Sections 306 & 107 IPC — Mens Rea — Instigation — Refusal to Marry — Relationship Breakup

Citation: 2026 LiveLaw (SC) 1029; Criminal Appeal arising out of SLP (Crl.) No. 7239 of 2026

Date: 05 October 2026

Legal Issue

Whether a person's refusal to marry or termination of a consensual relationship, followed by the other partner's suicide, is sufficient to constitute abetment of suicide under Section 306 IPC, particularly where there is no specific material showing intentional instigation or conduct intended to drive the deceased to suicide.

The Court was essentially required to determine whether the allegations disclosed the necessary elements of abetment and mens rea, or whether continuation of the criminal prosecution would be unjustified.

Brief Facts

The deceased woman and the first appellant, Chittibarika Chandra Shekar, were in a consensual relationship and had lived together at his house for approximately three months. According to the informant herself, the relationship was consensual and had initially been accepted by the first appellant's family.

The deceased's sisters subsequently intervened and brought her back from the first appellant's residence.

On the following day, the deceased went to work. Later, the first appellant contacted the informant regarding bringing the deceased home. The deceased subsequently telephoned her eldest sister and allegedly stated that the first appellant had refused to marry her and that she intended to end her life. She thereafter died by suicide at the first appellant's house.

Six persons were implicated under Section 306 read with Section 34 IPC, including the deceased's partner, his parents, his sister, his friend and the sister's proposed bridegroom.

The prosecution alleged that certain family members and the friend had discouraged the marriage. In particular, it was alleged that the friend had spoken adversely about the deceased and that the first appellant's sister opposed the relationship because her own proposed marriage could be affected.

The Telangana High Court declined to quash the criminal proceedings. The accused therefore approached the Supreme Court.

Held / Decision

The Supreme Court allowed the appeal and quashed the criminal proceedings.

The Court found no instigation by the appellants that could be said to have driven the deceased to suicide. Even if the allegations in the First Information Statement were accepted, the case essentially amounted to a refusal to marry followed by suicide. That sequence of events, without the necessary criminal intent or instigating conduct, was insufficient to constitute abetment.

The Court specifically found that the refusal to marry was not shown to have been made with the intention of driving the deceased to suicide, nor could the accused be attributed knowledge that such refusal would cause her to take her life.

The proceedings in Sessions Case No. 101 of 2024, pending before the II Additional Senior Civil Judge-cum-Additional Chief Judicial Magistrate, Medchal-Malkajgiri District at Kushaiguda, Telangana, were therefore quashed.

The Court further directed that:
- If any appellant was in custody, he or she should be released forthwith, unless required in another case; and
- If the appellants were already on bail, their bail bonds would stand cancelled.

The appeal was accordingly disposed of.

Important Observations

The most important proposition from the order is that causation in fact is not the same as criminal abetment. The fact that a refusal to marry or breakup preceded the suicide does not automatically establish the ingredients of Section 306 IPC.

The Court observed: “People react differently to situations…” and held that a breakup ending in suicide “cannot always be termed an abetment to suicide.”

For liability under Section 306 IPC, the prosecution must establish the legally required element of abetment, rather than merely demonstrate that the accused's conduct emotionally affected the deceased.

On the facts, there was no material demonstrating that the accused intended their conduct to drive the deceased to suicide or knew that refusal to marry would result in suicide.

The ruling therefore reinforces the distinction between emotional or interpersonal conduct that precedes a suicide and criminal conduct amounting to abetment of suicide. The latter requires the ingredients of abetment recognised by criminal law and cannot be presumed merely from the tragic consequence.

Full Headnote

Indian Penal Code, 1860 — Sections 306, 107 & 34 — Abetment of Suicide — Instigation — Mens Rea — Refusal to Marry — Breakup of Relationship — Quashing of Criminal Proceedings: Deceased and first appellant were in a consensual relationship and had cohabited for approximately three months; relationship was initially accepted by appellant's family — Following subsequent events, first appellant allegedly refused to marry deceased, who thereafter died by suicide — Six persons, including partner, members of his family and friend, prosecuted under Section 306 read with Section 34 IPC — Held, mere fact that refusal to marry or breakup was followed by suicide does not by itself constitute abetment — People may react differently to emotional and interpersonal situations and a breakup culminating in suicide cannot automatically be characterised as abetment — Even accepting informant's allegations, Court found no instigation on part of accused intended to drive deceased to suicide — Refusal to marry was not shown to have been made with intention of causing deceased to die by suicide, nor could requisite knowledge that refusal would result in suicide be attributed to accused — Essential element of abetment not disclosed merely from chronological connection between refusal to marry and subsequent suicide — Criminal prosecution under Section 306 IPC cannot be sustained in absence of necessary instigating conduct and mental element — Proceedings in Sessions Case No. 101 of 2024 quashed; appellants directed to be released if in custody unless required in any other case; bail bonds of appellants already on bail cancelled.

Legal Significance

This ruling is useful for Section 306 IPC cases arising from failed relationships, refusal to marry and other emotionally distressing interpersonal events.

Its central significance is that courts must examine the actual ingredients of abetment rather than infer criminal responsibility solely from the fact that the accused's conduct was followed by suicide.

For prosecution under Section 306, there must be legally sufficient material connecting the accused to the suicide through the requirements of abetment, including the necessary instigation and mental element. A breakup, rejection or refusal to marry, even if it becomes the immediate emotional trigger for suicide, does not automatically satisfy that threshold.

The decision also demonstrates that the Supreme Court can intervene at the quashing stage where, even if the prosecution allegations are taken at their highest, the essential ingredients of abetment are not disclosed.

View Original Judgment

Disclaimer: This case summary and headnote are provided for informational and educational purposes. Readers should refer to the original judgment for the complete text and authoritative legal position.