A Critical Analysis Of The Supreme Court’s Ruling In Prabhat Kumar Mishra @ Prabhat Mishra V. State Of U.P. & ANR. (2024 INSC 172): Abetment To Suicide Or Administrative Pressure?
- IJLLR Journal
- 6 days ago
- 1 min read
Roushan Aktara, B.A.LL.B. (Hons.), Xavier Law School, St. Xavier’s University, Kolkata
ABSTRACT
The case of Prabhat Kumar Mishra @Prabhat Mishra v. State of U.P. & Anr. (2024 INSC 172) addresses the crucial thin line between administrative responsibility and criminal abetment under Section 306 of the Indian Penal Code. The appellant, a District Savings Officer, was accused of abetting the suicide of a subordinate employee, who left a note alleging humiliation and workplace harassment. The prosecution also invoked Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989, though no caste-based motive was evident. The Supreme Court quashed the criminal proceedings and held that the suicide notes alone did not disclose any act of instigation or intentional aid by the appellant. Mens rea is a necessary ingredient for abetment to suicide and that mere workplace pressure or official reprimand cannot be criminalized. The Court also clarified that the particular SC/ST Act applies only where the offence is committed on account of caste identity. The judgement by the two honourable judges Justice B.R. GAVAI and Justice SANDEEP MEHTA, not only reinforces the principal that criminal liability must rest on clear intent and proximate causation.
