Chhattisgarh High Court Acquits Husband and Father-in-Law in 12-Year-Old Matrimonial Suicide Case

Raipur, July 7 – The Chhattisgarh High Court has acquitted two men convicted in a 2014 matrimonial suicide case, ruling that routine domestic quarrels and isolated derogatory remarks do not, in themselves, constitute abetment of suicide unless accompanied by sustained cruelty or extraordinary provocation.

A division bench led by Justice Bibhu Datta Guru overturned the 2016 conviction of Kamal Kumar Sahu and his father Kaliram Sahu, who had been sentenced to seven years of rigorous imprisonment by a Raipur sessions court for allegedly abetting the suicide of Kamal’s wife, Sunita Sahu.

Sunita died on January 5, 2014, following severe burn injuries sustained on December 31, 2013, at her matrimonial home. The prosecution had alleged that the deceased was deeply humiliated after being called "Charkat" — a regional derogatory slur — by her husband and father-in-law for serving food to a mason. The humiliation, they claimed, drove her to immolate herself.

However, the High Court found the evidence insufficient to sustain the charge under Section 306 of the Indian Penal Code, which deals with abetment of suicide.

"Derogatory remarks or quarrels within a matrimonial relationship, without more, do not meet the threshold of abetment under Section 306 IPC unless they involve extraordinary provocation or consistent cruelty," the court observed.

In its ruling, the court emphasized the absence of any direct or proximate link between the alleged conduct and the suicide, as required by law. Citing Supreme Court precedents, including Ramesh Kumar v. State of Chhattisgarh (2001) and Kumar @ Shiva Kumar v. State of Karnataka (2024), the bench reaffirmed that a conviction under Section 306 IPC demands clear evidence of instigation or involvement.

Justice Guru further noted that Sunita and Kamal had been married for over 12 years and were parents to two children, disqualifying the case from the presumption of abetment that applies when suicide occurs within seven years of marriage.

Crucially, the court found no evidence of dowry demands or habitual cruelty — elements that would have bolstered the prosecution’s case. The allegations were limited to verbal altercations and the use of a single offensive term, which the court deemed part of the “normal wear and tear of matrimonial life.”

“I am of the view that the prosecution has failed to prove its case and the trial court has not properly appreciated the evidence,” Justice Guru concluded.

The High Court allowed the appeal and acquitted both appellants, while also directing that their bail bonds remain valid for six months under Section 437A of the Criminal Procedure Code, a procedural safeguard pending any potential further appeal.