Conviction under Section 306 IPC Set Aside: Suicide Pact and Medical Evidence Did Not Establish Abetment — Supreme Court

Case Name: Gudipalli Siddhartha Reddy v. State C.B.I.
Citation: 2026 INSC 160; Criminal Appeal No. 457 of 2012 with Criminal Appeal Nos. 894–895 of 2012
Date of Judgment/Order: 17 February 2026
Bench: Hon’ble Mr. Justice Manmohan, and Hon’ble Mr. Justice Rajesh Bindal

Held: The Supreme Court held that conviction under Section 306 IPC for abetment of suicide requires clear and cogent evidence of instigation, intentional aid, or active participation in the commission of suicide. Where medical, forensic, and expert evidence conclusively establishes death by organophosphate poisoning and rules out manual strangulation or sexual assault, and where the material on record suggests a consensual suicide pact without proof of coercion or instigation by the accused, the essential ingredients of abetment are not satisfied. Suspicion, contradictory medical opinions, or public controversy cannot substitute proof beyond reasonable doubt.

Summary: The deceased, a film actress, and the appellant were in a long-standing relationship and intended to marry, but the appellant’s family opposed the alliance. On 23 February 2002, both consumed poison and were admitted to CARE Hospital; the deceased died the next day while the appellant survived. An initial postmortem conducted by Dr. B. Muni Swamy opined death due to manual strangulation and suggested sexual assault. However, AP FSL reports (27 February 2002) detected organophosphate poison in the viscera and stomach wash, and found no semen or spermatozoa. A three-member Expert Committee constituted by the State Government (report dated 09 March 2002) concluded death due to organophosphate poisoning and held that injuries noted in the postmortem were therapeutic artefacts misinterpreted as strangulation marks. An AIIMS medical board (report dated 02 May 2002) affirmed that the cause of death was organophosphorus poisoning and that the postmortem opinion of manual strangulation was an error of judgment. CFSL reports also detected monocrotophos insecticide in viscera and found no evidence of semen. DNA analysis excluded the appellant and others from being the source of male DNA detected on a cotton swab, with contamination not ruled out. Despite the absence of evidence of homicide or sexual assault, the appellant was convicted under Sections 306 and 309 IPC. The High Court reduced the sentence under Section 306 IPC but upheld conviction. Before the Supreme Court, the central issue was whether the evidence established abetment of suicide within the meaning of Section 107 IPC so as to sustain conviction under Section 306 IPC.

Decision: The Supreme Court allowed the appeal, set aside the conviction of the appellant under Section 306 IPC, and held that the prosecution failed to establish instigation or intentional aid to commit suicide. The Court found that the medical and forensic evidence conclusively demonstrated death by poisoning and negated allegations of strangulation or sexual assault, and that the circumstances indicated a consensual act rather than abetment. Consequently, the conviction and sentence were quashed, and the appellant was acquitted of the charge under Section 306 IPC.