Prabhat Kumar Mishra @ Prabhat Mishra Vs. State of Uttar Pradesh [Supreme Court, March 5, 2024]
Background and Facts
Prabhat Kumar Mishra, a government officer, was prosecuted under Section 306 of the Indian Penal Code (abetment of suicide) and Section 3(2)(v) of the Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989. The case stemmed from the suicide of a subordinate employee, who left a note blaming work pressure and, indirectly, the appellant. The prosecution alleged that Mishra’s conduct amounted to abetment and that the acts were committed against a member of a Scheduled Caste, invoking the SC/ST Act.
Procedural History
Mishra sought quashing of the criminal proceedings under Section 482 CrPC before the Allahabad High Court, which was rejected. He then appealed to the Supreme Court.
Supreme Court’s Analysis
Abetment of Suicide (Section 306 IPC): The Supreme Court held that the essential ingredients for abetment—active instigation or intentional aiding of suicide—were not present. The Court noted that mere work-related pressure or administrative actions, without evidence of deliberate harassment or intent to drive the deceased to suicide, do not constitute abetment. The suicide note did not reveal any such instigation by Mishra.
SC/ST Act (Section 3(2)(v)): The Court emphasized that for the SC/ST Act to apply, the alleged IPC offence must be committed on the ground of the victim’s caste. The charge sheet and case records did not indicate any caste-based motivation or conduct by Mishra. The Supreme Court cited its own precedent (Masumsha Hasanasha Musalman v. State of Maharashtra) to clarify that Section 3(2)(v) cannot survive if the underlying IPC offence is not established or is not caste-related.
Abuse of Process: The Court observed that the investigating agency had initially proposed a closure report after thorough investigation, indicating the absence of prosecutable evidence. The subsequent prosecution was deemed unwarranted and a misuse of judicial process.
Judgment and Outcome
The Supreme Court quashed the High Court’s order and all criminal proceedings against Prabhat Kumar Mishra under Section 306 IPC and Section 3(2)(v) of the SC/ST Act. The Court concluded that the prosecution was not justified, as the necessary legal ingredients for both offences were lacking, and allowing the case to proceed would amount to gross abuse of the process of law.
Key Points:
Mere work pressure or administrative actions do not amount to abetment of suicide without clear evidence of instigation or intent.
SC/ST Act provisions require a clear caste-based motive, which was absent in this case.
The Supreme Court quashed the proceedings, reinforcing the need for strict adherence to statutory requirements in criminal prosecutions.
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