ABETMENT OF SUICIDE: AN OVERVIEW

Author: -Vallabhi Rastogi

Introduction

The Indian Legal System has contributed to safeguard and uphold the significance of human life by not only penalizing people who take another individual’s life but also punishing those who try to take their own life. The easiest yet most disturbing way that people find, these days, for facing severe depression or failure is to take one’s own life. This opinion is because, past few months, the suicide rates have elevated to an enormous extent in India. ‘India accounts for approximately 18% of all the reported suicide cases which makes it the most common cause of death in the age group ranging from adolescence to their late 30s.’1 Not only this, India recorded a rise of approximately 4% in the number of suicide deaths in the year 2019. Other than attempting to commit suicide, abetment of suicide and abetment to attempt to commit suicide is also brought under the penal purview. 

Abetment of suicide is instigating or provoking an individual to take his own life or helping that individual to take his own life, out of which the latter alone is prohibited by law. Therefore, such provocation which makes a person take his own life is punishable under the provisions of Indian law under section 306 of Indian Penal Code (IPC), 1860.2

The aforementioned section is based on the principle of public policy so that no individual takes his own life or instigates or facilitates another individual to commit suicide.

Evolution

Abetment of suicide constitutes an offence only because an attempt to commit suicide is considered a crime in the Indian Legal System. Suicide is a ‘voluntary act of taking one’s own life,3 and a person attempting to take his own life is punishable under the law of India. The issue of whether an attempt to commit suicide is an offence or not has been a debatable topic for quite some time now. The Court observed in the case of Gangula Mohan Reddy v. State of Andhra Pradesh4 that “while suicide in itself is not an offence in India, considering that successful offender would be beyond the reach of the law, attempt to commit suicide is an offence.” The Apex Court has decided many cases dealing with the constitutionality of Section 309 of the Indian Penal Code (IPC), 18605 that provides punishment for attempt to commit suicide. In the case of P. Rathinam v. Union of India6, the Supreme Court held that section 309 IPC was unconstitutional and that the ‘right to die’ is implicit of Article 217 which cannot be violated. However, this was overturned in the significant case of Gian Kaur v. the State of Punjab8 which stated that the right to live with dignity cannot be considered to ‘incorporate to end one’s own life until the natural process of death begins.’ Through all these instances, this paper tries to reflect that the abetment of suicide comes into the picture only when a suicide attempt was counted as an offence.

General overview and distinctions

Abetment of an attempt to commit suicide is beyond the ambit of Section 306 IPC since it falls under the scope of Section 309 read along with Section 107 IPC. Therefore, in circumstances where ‘punishment for attempt to commit suicide is not considered desirable, its abetment is made a penal offence in the interest of society. Such a provision is considered desirable to prevent the danger inherent in the absence of such a penal provision.9 Moreover, Naresh Morotrao v. Union of India held that Section 306 is independent in its entirety and is very well in sync with Articles 14 and 21 guaranteed by Part III enshrined in the Constitution of India.

  • MURDER VIS – A – VIS ABETMENT OF SUICIDE

Abetment of suicide has a separate meaning attached to it when compared with murder. The Supreme Court in the landmark case of Sangarabonia Sreenu v. State of Andhra Pradesh10 held that the ‘ultimate critical act of causing the death of an individual is committed by the alleged person in case of murder which in no situation is same as abetment of suicide’. Therefore, the abetment of suicide cannot be equated with murder.

  • CRIMINAL CONSPIRACY VIS – A – VIS ABETMENT BY CONSPIRACY

Criminal Conspiracy u/s 120-A IPC11 has minute differences when equated with abetment by conspiracy u/s 306 IPC.  ‘A person is said to abet the commission of an offence by conspiracy if he engages with one or more persons to do a legal act by illegal means or do an illegal act or some act is done in pursuance thereof.’ Therefore12, u/s 306 he is not the actual perpetrator but only an abettor whereas a person involved in the criminal conspiracy is the actual perpetrator committing the offence. As far as abetment by conspiracy is concerned, a mere agreement is not sufficient; ‘an act or illegal omission must take place in pursuance of the conspiracy and order to the doing of the thing conspired for.13 However, if it had been for criminal conspiracy, a mere agreement would be enough to hold the people engaged guilty of the offence under Section 120-A and Section 120-B.14

Essentials to the offence of abetment of suicide

Certain requisites are necessary to constitute this offence. For an act to constitute as ‘Abetment’, which itself is a crime laid down under Section 107 of IPC,15 should include an instigation/provocation/engagement/facilitation of an act which if committed by a competent person with the same intention as that of the abettor16 is prohibited by law. A guilty mind serves as the pre-requisite for establishing the offence of abetment. For facilitation, the abettor has to intentionally aid in the commission of the wrongful act.

The Supreme Court, in the case of Wazir Chand v. the State of Haryana,17 held that to convict any person for instigating another person to commit suicide, it is to be established that the victim had committed suicide and that the accused should have instigated or provoked or engaged or facilitated the victim to commit such a wrongful act. Further, the person abetting the suicide should not necessarily be capable in law. However, the Court, in the ruling of Pallem Deniel Victoralions Victor Manter v. State of Andhra Pradesh,18 has stated that men’s rea of the accused to abet the deceased to commit suicide19 is a mandatory pre-condition for abetment of suicide, that is, the accused should have an intention to provoke.20 Moreover, in the case of Jagannath Mondal v. State of West Bengal,21 the Court held that the involvement of the accused with the victim in provocation or facilitation should be direct. 

Another important aspect that is to be taken care of is that the abetment must be of an offence or conduct which constitutes an offence because ‘if the thing abetted is not an offence, then the person abetting will not be considered as an abettor and the act would not fall within the purview of Section 306 IPC.22 The act would only attract punishment under this section if the suicide is committed and is not an instance of attempted suicide. The onus of proof lies on the prosecution to establish the direct link between provocation or facilitation and suicide.23 This was stated in the judgment of Gurbachan Singh v. Satpal Singh.24

Abetment of suicide by a married person 

Under Section 498-A,25 if a woman is subjected to cruelty by her husband or his relatives and commits suicide as a result of it within seven years of her marriage then this would be presumed as abetment to suicide as per Section 113 A of the Indian Evidence Act, 1872.26 However, if the person accused of abetment can establish that the married woman committed suicide due to some other reason different from that which is required for abetment, then the accused has a chance to contradict and refuse the allegations against him. Also, the ‘cruelty and harassment should be of such intensity that led the deceased to commit suicide otherwise this presumption cannot be applied by the Court’.27 This section of the evidence act is only applicable when the wife is imperilled to cruelty.

Abetment of Suicide v/s Killing by Consent (Euthanasia) 

Though both the concepts involve the killing of a person the former is instigating/facilitating another individual to take his own life while the latter is killing another individual by consent which generally means euthanasia. Euthanasia or the ‘aid in dying’ is wherein a person commits suicide with the help/assistance of another individual, commonly a medical practitioner or doctor. However, passive euthanasia was recently permitted in India28 in which the person whose life is to be ended due to incurable suffering, is in an unconscious state and his life is ended by terminating his life support or discontinuing his medication. In the landmark judgment, the Court outrightly rejected active euthanasia which is helping the incurably suffering person by administering him with lethal substances. This was another case that opened the debate on the constitutional validity of Section 309 IPC since passive euthanasia was one of the few steps in abetment of an attempt to suicide. 

Conclusion

Considering the recent rise in the number of suicide cases in India due to various reasons, the provisions dealing with it are to be looked into. Along with a rise in suicide rates, there has also been an increment in abetment of suicide. However, there have been many instances wherein the accused have presented the arguments in such a manner that the provisions of the law were interpreted in their favour. Given this situation, the accused who are guilty in reality remain free due to the existing loopholes. Therefore, provisions need to be brought in that can bridge the gap in such a way that the offenders are not permitted to roam freely or left free without being penalized for their wrongful acts. 

The Mental Healthcare Bill 2016 has decriminalized suicide and the Courts have ruled to prevent and protect the people who are unnecessarily harassed as being abettors just because they were somehow linked with the deceased. The Madras High Court in the case of Manikandan v. State observed, “a person may die like a coward. They may do this because of being weak-minded. They are persons of frail mentality. For their foolish mentality/decision, another person cannot be blamed”.The Court  in another case stated that “only those acts would be deemed to be incitement, which by their very nature, whether by way of words spoken or person so abetted, that he is compelled to act in a particular manner and no other, which the person so inciting/abetting intended or had the knowledge that the person so incited/abetted would act in a particular manner.” 

Therefore, all these situations make it clear that there should be a direct link between the act of abetment and suicide. Furthermore, there are lot many reasons for suicide that do not necessarily lead to abetment. 

This paper has tried to highlight and reflect all these significant aspects related to the concept of abetment of suicide provided under section 306 of the Indian Penal Code, 1860. The suggestions are the personal opinion of the author after understanding the application of this section in contemporary times.

Citation

1.*Third Year B.A.LL.B Student of Symbiosis Law School, Noida (SIU).

  National Crime Bureau, India Data 2019.

2.  Abetment of suicide.—If any person commits suicide, whoever abets the commission of such suicide, shall be punished with imprisonment of either description for a term which may extend to ten years, and shall also be liable to fine.

3. Suicide (n), Merriam-Webster Dictionary (1828).

4.  2010 (1) SCC 750.

5. Attempt to commit suicide—Whoever attempts to commit suicide and does any act towards the commission of such offence, shall he punished with simple imprisonment for a term which may extend to one year 1[or with fine, or with both].

6.  1994 (3) SCC 394.

7.  Protection of life and personal liberty-No person shall be deprived of his life or personal liberty except according to procedure established by law.

8. 1996 (2) SCC 648.

9. Mohini Chaturvedi, Abetment to Suicide, ILJ (2019).

10. 1997 (5) SCC 348.

11. Definition of criminal conspiracy.—When two or more persons agree to do, or cause to be done,—

(1) an illegal act, or

(2) an act which is not illegal by illegal means, such an agreement is designated a criminal conspiracy: Provided that no agreement except an agreement to commit an offence shall amount to a criminal conspiracy unless some act besides the agreement is done by one or more parties to such agreement in pursuance thereof. Explanation.—It is immaterial whether the illegal act is the ultimate object of such agreement, or is merely incidental to that object.

12. Nishi Kumar, Abetment and Criminal Conspiracy: An Analysis, 1 LPJ (2019).

13. Rishabh Shrivastava, Abetment Of Suicide, 4IJLLJS 249, 245-280 (2017).

14. Punishment of criminal conspiracy.—

(1) Whoever is a party to a criminal conspiracy to commit an offence punishable with death, 2[imprisonment for life] or rigorous imprisonment for a term of two years or upwards, shall, where no express provision is made in this Code for the punishment of such a conspiracy, be punished in the same manner as if he had abetted such offence.

(2) Whoever is a party to a criminal conspiracy other than a criminal conspiracy to commit an offence punishable as aforesaid shall be punished with imprisonment of either description for a term not exceeding six months, or with fine or with both.

15. Abetment of a thing.—A person abets the doing of a thing, who—

(First) — Instigates any person to do that thing; or

(Secondly) —Engages with one or more other person or persons in any conspiracy for the doing of that thing, if an act or illegal omission takes place in pursuance of that conspiracy, and in order to the doing of that thing; or

(Thirdly) — Intentionally aids, by any act or illegal omission, the doing of that thing. Explanation 1.—A person who, by wilful misrepresentation, or by wilful concealment of a material fact which he is bound to disclose, voluntarily causes or procures, or attempts to cause or procure, a thing to be done, is said to instigate the doing of that thing.

16. Section 108 of the Indian Penal Code, 1860.

17. AIR 1989 SC 378.

18. (1997) 1 Cr 499 (AP).

19. S.S. Cheena v. Vijay Kumar Mahajan

20. Chitresh Kumar Chopra v. State (Govt. of NCT of Delhi)

21. 2013 CriLJ 1994(Cal).

22. Supra note 14.

23. Satvir Singh v. State of Punjab, AIR 2001 SC 2826.

24. AIR 1990 SC 209.

25. Husband or relative of husband of a woman subjecting her to cruelty.—Whoever, being the husband or the relative of the husband of a woman, subjects such woman to cruelty shall be punished with imprisonment for a term which may extend to three years and shall also be liable to fine. Explanation.—For the purpose of this section, “cruelty” means—

(a) any wilful conduct which is of such a nature as is likely to drive the woman to commit suicide or to cause grave injury or danger to life, limb or health (whether mental or physical) of the woman; or

(b) harassment of the woman where such harassment is with a view to coercing her or any person related to her to meet any unlawful demand for any property or valuable security or is on account of failure by her or any person related to her to meet such demand.

26. Presumption as to abetment of suicide by a married woman.—When the question is whether the commission of suicide by a woman had been abetted by her husband or any relative of her husband and it is shown that she had committed suicide within a period of seven years from the date of her marriage and that her husband or such relative of her husband had subjected her to cruelty, the Court may presume, having regard to all the other circumstances of the case, that such suicide had been abetted by her husband or by such relative of her husband

27.  Bimla Devi v. State of Punjab, Unreported Cr. Appeal N. 424-SD 1985 decided on 12.08.1988.

28. Aruna Ramchandra Shaunbag v. Union of India & Ors., 

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