Supreme Court: No abetment of suicide without intent to drive subordinate to death

The case concerns a criminal appeal by a senior Forest Department officer (Vinod Shivakumar) against his charge-sheet for abetment of suicide (Section 306 IPC) following the suicide of a subordinate Forest Range Officer. The core issue is whether the Appellant's official conduct and alleged harassment constitute the proximate cause of the suicide.

Appellant: Vinod Shivakumar; Respondent: The State of Maharashtra; Bench: Justice Satish Chandra Sharma.

• Leave granted for the appeal.
• The Court noted that the FIR against the Appellant for Section 312 IPC (voluntarily causing miscarriage) was previously quashed by the High Court.
• The Court observed that the incidents alleged by the deceased occurred at least one year prior to the suicide.
• The Court noted the absence of a 'proximate prior act' immediately preceding the suicide that directly drove the deceased to take her life.
• The Court noted that another senior officer (Mr. Reddy) was not charged and his FIR was quashed, and another individual (Manisha Uike) was not made a co-accused despite allegations in the suicide note.

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