Summary and Analysis of Sukdeb Saha vs. The State of Andhra Pradesh & Ors (Criminal Appeal No. 3177/2025)

1. Heading of the Judgment

Sukdeb Saha vs. The State of Andhra Pradesh & Ors.
(Supreme Court of India, Criminal Appeal No. 3177 of 2025)

2. Relevant Laws and Sections

The judgment references:

• Constitution of India: Articles 21 (Right to Life), 32 & 226 (Writ Jurisdiction), 141 (Declared Law).

• Criminal Laws:
  Section 302 (Murder) & 120B (Criminal Conspiracy) of IPC.
  Section 304 Part-II (Culpable Homicide) of IPC.
  Section 174 CrPC (now Section 194 BNSS, 2023) (Inquiry for Unnatural Deaths).

• Mental Healthcare Act, 2017: Sections 18 (Right to Mental Healthcare) & 115 (Decriminalization of Attempted Suicide).

• International Law: UN Convention on Rights of Persons with Disabilities (CRPD).

3. Basic Case Details

• Parties:
  Appellant: Sukdeb Saha (father of deceased Ms. X, a 17-year-old NEET aspirant).
  Respondents: State of Andhra Pradesh, Police, Aakash Byju’s Institute, Sadhana Hostel & Hospitals.

• Incident: Ms. X died on 16 July 2023 after a fall from her hostel in Vishakhapatnam. Police termed it "suicide"; father alleged foul play.

• Appeal: Against Andhra Pradesh HC’s refusal to transfer investigation to CBI.

• Supreme Court Decision:
  Allowed appeal; transferred case to CBI.
  Issued nationwide guidelines for student mental health.

4. Explanation of the Judgment

Part A: Case-Specific Ruling (CBI Transfer)

The Supreme Court ordered a CBI probe due to serious lapses in the police investigation:

1. Unreliable Suicide Theory:
   No suicide note, psychiatric history, or witness statements supported the police’s "suicide" claim.
   Deceased was conscious after the fall (Glasgow Coma Score: 10/15) but her statement was never recorded.

2. CCTV Contradictions:
   Hostel footage showed a girl in salwar climbing stairs; shop footage showed a girl in half-pants lying injured. Police ignored this discrepancy.

3. Medical Negligence:
   Hospital placed Ms. X on ventilator without parental consent.
   Autopsy found "suspicious smell" in stomach contents, but viscera was destroyed before forensic analysis.

4. Conflict of Interest:
   Same doctor performed autopsy, forensic analysis, and medical inquiry, compromising impartiality.

5. Suppressed Evidence:
   Key reports (chemical analysis, cause of death) were withheld.

Court’s Conclusion:

"Local investigation was ineffective, biased, and aimed at shielding the institutions... CBI probe essential to ensure justice."

Part B: National Guidelines for Student Mental Health

The Court issued 15 binding guidelines under Article 141 to prevent student suicides:

1. Mental Health Policy: All institutions must adopt policies based on UMMEED/MANODARPAN initiatives.

2. Counsellors: Institutions with 100+ students must appoint trained mental health professionals.

3. Anti-Discrimination: Zero tolerance for caste/gender-based ragging, bullying, or harassment.

4. Parental Sensitization: Workshops to reduce academic pressure.

5. Infrastructure Safety: Tamper-proof fans, restricted rooftop access in hostels.

6. High-Risk Cities (e.g., Kota, Hyderabad): Enhanced counselling and monitoring.

7. Compliance: States must frame rules within 2 months; District Magistrates to monitor implementation.

Philosophical Basis:

"Education must liberate, not burden. Student suicides reflect institutional failure to protect mental health under Article 21."

Key Outcomes

1. For the Case: CBI to conclude investigation in 4 months.

2. For the Nation: Guidelines apply to all schools, colleges, coaching centers, and hostels. Non-compliance = institutional liability.

3. Compliance Deadline: Union of India to file affidavit within 90 days.