Abetment to suicide quashing refused where persistent harassment and humiliation disclosed a prima facie case.

Persistent harassment, humiliation and illegal demands may amount to instigation for abetment to suicide where the materials, including a suicide note and family statements, show a continued course of conduct rather than a stray remark. At the quashing stage, the court must only form a tentative view and not decide guilt finally. Applying the settled test under Section 306 of the Indian Penal Code, sustained conduct capable of leaving the deceased with no real option but to commit suicide was treated as sufficient to disclose a prima facie case. The prayer for quashing was rejected and the criminal proceedings were allowed to continue.

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Issues: Whether the criminal proceedings for abetment to suicide deserved to be quashed in view of the allegations of persistent harassment, humiliation, and illegal demands made against the accused.

Analysis: The materials on record, including the suicide note and statements of family members, indicated not a stray or casual remark but a continued course of conduct involving repeated humiliation, demoralisation, and pressure to resign. For an offence under Section 306 of the Indian Penal Code, 1860, the relevant enquiry is whether the accused's conduct amounted to instigation, intentional aid, or such sustained harassment as could reasonably create circumstances leaving the deceased with no real option but to commit suicide. At the stage of quashing, the Court was required to form only a tentative view, not a final assessment of guilt. Applying the settled principles on instigation and abetment, the allegations were sufficient to proceed.

Conclusion: The prayer for quashing was rejected and the criminal proceedings were held fit to continue.

Ratio Decidendi: Persistent and continuous harassment, coupled with conduct capable of goading the deceased into suicide, may amount to instigation for the purpose of abetment, and such proceedings should not be quashed where the allegations disclose a prima facie case.

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