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The Supreme Court recently quashed an abetment to suicide case against senior officials of Hindustan Unilever Limited (HUL), cautioning lower courts and police about the improper application of principles governing abetment to suicide under Section 306 of the Indian Penal Code (IPC). The Court emphasized that courts must apply the correct legal standards and not assume intent merely from the fact of suicide.
The bench comprising Justices J.B. Pardiwala and Manoj Misra criticized the tendency of courts to allow cases to proceed to trial without considering whether there is sufficient evidence of intention or instigation by the accused. The Court stressed that abetment requires a direct and alarming form of encouragement or incitement to commit suicide, which was not present in this case.
The case involved allegations that HUL officials harassed and humiliated a deceased salesman during a meeting, compelling him to take voluntary retirement, leading to his suicide. The Allahabad High Court had refused to quash the charges, prompting the accused to approach the Supreme Court.
The Supreme Court clarified that for a case of abetment to suicide, it must be shown that the accused’s actions left the deceased with no option but to commit suicide. The Court listed factors that lower courts should examine, such as whether the accused exploited the deceased’s emotional vulnerability, threatened him with severe consequences, or humiliated him in a way that left him feeling suicide was the only escape.
In quashing the case, the Supreme Court found no evidence that the HUL officials had directly instigated or incited the suicide. The Court concluded that proceeding with the trial would amount to an abuse of the legal process.
Case Title: Nipun Aneja and Others v. State of Uttar Pradesh
Citation: 2024 LiveLaw (SC) 786
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