Name of the Case: Chilikuri Mariyadas & Anr. v. The State of Andhra Pradesh.
Citation: Crl.R.C. No. 44 of 2011
Hon’ble Andhra Pradesh High Court’s Bench: Hon’ble Justice Dr. Y. Lakshmana Rao
Date: 16.06.2025
In a recent case that dealt with the issue of abetment to suicide, the Hon’ble High Court set aside the conviction by allowing the revision of the deceased’s husband and her brother-in-law, who had been sentenced to 4 years of imprisonment for allegedly provoking the deceased to end her life. The deceased ended up suffering 100% burn injuries and had reportedly made a dying declaration wherein she blamed her husband and her brother-in-law for beating her with ‘chappal’, humiliating her and allegedly stating that “why should I lead this life and why should not I die”. Post which she poured kerosene over herself and set herself on fire. The Hon’ble Court reviewed the evidence on record and concluded that despite a quarrel and alleged physical abuse the previous night, there was no clear mens rea or sustained course of conduct intended to drive the deceased to suicide.
Further, the Hon’ble Court stated that statements made in a moment of anger, in the absence of any continuous or proximate incitement or demonstrable intent, could not amount to abetment under Section 306 IPC. The Hon’ble Court went ahead to highlight the “oversensitive” nature of the victim and placed reliance on the absence of any medical certification regarding the state of her mind during the time of giving the dying declaration1.