Everyday Neighbourhood Quarrels Cannot Amount To Abetment To Suicide: Supreme Court Acquits Woman In Section 306 IPC Case

The Supreme Court on September 9, 2025 ruled that neighbourhood quarrels involving heated exchanges and even physical blows cannot be construed as abetment to commit suicide under Section 306 of the Indian Penal Code. A bench of Justices B V Nagarathna and K V Vishwanathan set aside the conviction of Geeta, a resident of Karnataka, who had been held guilty of abetment to suicide following the death of her neighbour Sarika. The Court held that such quarrels are part of everyday life and in the absence of clear intention or instigation to drive a person to take their life, Section 306 cannot be attracted.

The incident dates back to August 12, 2008 when Sarika, who used to conduct tuition classes at her residence, set herself on fire around 10 p.m. She gave a dying declaration stating that the appellant Geeta abused her by calling her “bitch” as Sarika often complained about noise emanating from Geeta’s house which disturbed her classes. Sarika succumbed to her injuries on September 2, 2008, nearly three weeks later.

The trial court convicted Geeta under Section 306 IPC and sentenced her to five years’ imprisonment. It also convicted her under Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, imposing life imprisonment. On appeal, the Karnataka High Court by judgment dated April 27, 2018 acquitted her of the charge under the SC/ST Act but confirmed her conviction under Section 306 IPC, reducing the sentence to three years’ imprisonment. Geeta then approached the Supreme Court challenging the High Court order.

The Supreme Court examined the entire record and observed that neighbourhood quarrels are not uncommon in community life. The bench said that though “love thy neighbour” is the ideal, such disputes are as old as community living itself and cannot in every case be treated as abetment to suicide. The Court said: “We are not able to persuade ourselves to hold that when the appellant’s family and the victim’s family had heated exchanges, there was any intention to abet or to cause any member of either family to take their own life. These quarrels occur in everyday life, and on facts we are not able to conclude that there was an instigation on the part of the appellant to such an extent that the victim was left with no other option but to commit suicide.”

The Court reiterated that intention of the accused to aid, instigate, or abet the victim to commit suicide is essential for convicting a person under Section 306 IPC. It noted that in the present case there was no evidence to suggest such intention. The bench also pointed out that while the victim felt her tuition classes were disturbed by the noise from the appellant’s household, the appellant’s family had grievances that the victim and her family scolded their children.

On record there was evidence that both families were at loggerheads for several months. The Court recorded that not only were there heated exchanges but physical blows were also alleged to have been administered. However, insofar as the allegation of physical assault was concerned, the trial court had acquitted the appellant under Section 323 IPC. She had also been acquitted for offences under Sections 504 and 506 IPC. The State had not preferred any appeal against these acquittals.

The Court then considered whether even assuming that physical blows were administered, that by itself would amount to abetment to suicide. Referring to earlier precedents, the bench observed that in one case where the accused told the deceased “go and die” and the deceased thereafter committed suicide, this Court had absolved the accused of the charge under Section 306 IPC. It emphasised that the threshold for abetment is high and casual utterances, abuses or even quarrels cannot automatically bring a case within the scope of the provision.

Taking the prosecution case at its highest, the Supreme Court concluded that the evidence only established that the neighbours had serious disputes and quarrels, but there was no instigation of such intensity which could have left the victim with no other option but to end her life. The Court therefore held that the essential ingredients of Section 306 IPC were not satisfied.

Accordingly, the appeal was allowed and the conviction of Geeta under Section 306 IPC was set aside. The Court acquitted her of the charge of abetment to suicide.

Case Title: Geeta Vs State of Karnataka

Bench: Justices B V Nagarathna and K V Vishwanathan

Judgment Date: September 9, 2025