Justice Cannot Be Selective: Supreme Court Orders SIT Probe into “One-Sided” Investigation of Suicide Case Following Inter-Religious Relationship Tragedy

In a strong rebuke to investigative bias, the Supreme Court of India ordered a Special Investigation Team (SIT) probe into the suicide case of a young woman, Tanu, following an inter-religious relationship tragedy in Uttar Pradesh. Expressing serious concerns over the fairness of the probe, the Court quashed the criminal proceedings against Ayyub and others, who had been accused of abetting Tanu’s suicide under Section 306 IPC.

A Bench of Chief Justice Sanjiv Khanna, Justice Sanjay Kumar, and Justice K.V. Viswanathan found that the police investigation had been entirely one-sided, blindly accepting the complainant’s version while failing to explore other crucial aspects of the case. The Bench did not mince words in criticizing the manner in which the probe was conducted.

“Justice cannot be selective. A criminal investigation must be impartial and comprehensive, not driven by a singular narrative. This Court cannot overlook the glaring gaps in the investigation, which has proceeded with blinkers on, ignoring key facts and alternative explanations.”

The Court directed the Director General of Police, Uttar Pradesh, to constitute an SIT, headed by a Deputy Inspector General (DIG)-level officer, to reinvestigate the unnatural death of Tanu and submit a sealed report within two months.

A Tragic Chain of Events Leading to Questionable Investigations

The case is rooted in a tragic sequence of deaths that unfolded following an inter-religious relationship between Ziaul Rahman and Tanu. On November 2, 2022, Ziaul Rahman was allegedly beaten to death by Tanu’s family members, who disapproved of their relationship. That very evening, his father, Ayyub (the appellant), lodged an FIR at PS Rampur Maniharan, Saharanpur, accusing Tanu’s family members of murder under Section 304 IPC.

Just hours later, on the morning of November 3, 2022, Tanu was found dead by hanging in what was claimed to be a suicide. That same evening, her cousin, Vijay (Respondent No. 2), lodged a counter-FIR, accusing Ayyub and his relatives of abetting her suicide.

The allegations were based on a single claim—that on the morning of November 2, 2022, before Tanu’s death, the appellants visited her home and humiliated her by saying, "Because of you, our boy has died—why don’t you die too?" Vijay claimed that Tanu, unable to bear the humiliation, took her own life a few hours later.

However, glaring inconsistencies in the investigation raised serious doubts about the fairness of the proceedings. The post-mortem, conducted on November 2, 2022, at 5:00 PM, confirmed Tanu’s death by hanging, yet the police did not register the FIR for abetment of suicide until November 3, 2022, at 5:07 PM—almost 24 hours later.

The investigation then relied solely on witness statements that were almost verbatim repetitions of the FIR, without any independent verification. No effort was made to explore whether Tanu’s suicide was influenced by factors other than the alleged remarks made by the appellants.

The Allahabad High Court, rejecting Ayyub’s plea to quash the proceedings, ruled that Tanu was “hypersensitive and deeply humiliated”, and that the appellants’ alleged words were sufficient provocation to establish abetment of suicide. This ruling was challenged before the Supreme Court, which took a far more nuanced view of the matter.

Supreme Court Finds Investigation "Unidimensional" and Orders SIT Probe

The Supreme Court found the investigation deeply flawed, raising serious questions about the manner in which the police had conducted the probe. The Bench highlighted the failure to investigate alternative causes of Tanu’s distress, observing:

"We are left with only the complainant’s version, but no one has asked the fundamental questions: Was Tanu already distraught over her relationship? Was her family’s disapproval a factor? Were there other pressures that led her to take this extreme step? These remain unanswered because the investigation was conducted with a singular focus on implicating the appellants."

The Court was particularly critical of how witness statements merely repeated the FIR without providing any new insights, casting doubts on their credibility. Expressing deep concerns over the police’s failure to probe whether Tanu was under distress due to other factors, the Bench observed: “A proper investigation cannot be an exercise in validation. It must be an impartial pursuit of truth. Here, the probe has proceeded with a predetermined conclusion, completely ignoring alternative possibilities.”

Emphasizing the need for an independent and comprehensive reinvestigation, the Supreme Court quashed the criminal proceedings against Ayyub and others under Section 306 IPC and ordered the constitution of a Special Investigation Team (SIT). The SIT was given the authority to either treat the FIR as a case of unnatural death or re-register a new FIR if necessary.

The Court directed the SIT to submit its findings in a sealed cover within two months, setting the next hearing for April 15, 2025.

Addressing the legal question of whether the alleged remarks of the appellants could constitute abetment of suicide, the Supreme Court found that the case did not meet the threshold required under Section 306 IPC.

Relying on Swamy Prahaladdas v. State of M.P. (1995 Supp (3) SCC 438), where the Supreme Court had ruled that telling someone to "go and die" did not amount to abetment, the Bench held: “For an offence under Section 306 IPC, there must be active encouragement or instigation to commit suicide. Mere verbal abuse, humiliation, or a heated exchange, without an element of coercion, is not sufficient to constitute abetment.”

The Court cautioned against the misuse of abetment laws, stating: "A criminal charge cannot be sustained merely on the basis of perceived humiliation. To constitute abetment, there must be a clear, direct link between the accused’s actions and the victim’s suicide. That link is missing here."

The Supreme Court’s decision sends a clear message that investigations must be impartial, exhaustive, and free from bias. By ordering an SIT reinvestigation, the Court has ensured that the real circumstances surrounding Tanu’s death are thoroughly examined, rather than allowing a one-sided narrative to dictate legal proceedings.

In cases where communal and emotional sensitivities are involved, the Court has reinforced that justice must be rooted in objective truth, not in selective investigations. By quashing the charges under Section 306 IPC and ordering a fresh probe, the Supreme Court has upheld the principle that an investigation must seek justice, not merely validation of a preconceived version of events.

As the SIT takes up the reinvestigation, the Supreme Court’s directive stands as a powerful reminder that justice cannot be dictated by bias, pressure, or predetermined narratives. Truth must be pursued, no matter where it leads.

Date of Decision: February 7, 2025