Supreme Court Restores Acquittal in Abetment to Suicide Case, Emphasizes Limited Appellate Review

Case Snapshot

• Case Name: Sanjay Kumar v. State of Himachal Pradesh

• Citation: 2026 INSC 948

• Bench: Justice Ujjal Bhuyan and Justice Atul S. Chandurkar

• Date of Judgment: September 3, 2026

• Area of Law: Criminal Law, Abetment to Suicide, Section 306 IPC, Acquittal Appeals

The Judgment in One Line

Supreme Court restores trial court acquittal, holding High Court erred in reversing acquittal without finding perversity in trial court's appreciation of evidence.

Why This Judgment Matters

This judgment reinforces the well-settled principles governing appeals against acquittal. It reminds appellate courts that reversing an acquittal requires a finding that the trial court's view is perverse or impossible, not merely because another view is possible. The ruling also clarifies that general allegations of harassment are insufficient to prove abetment to suicide under Section 306 IPC without specific evidence of instigation or intentional aid. The judgment protects the presumption of innocence and the trial court's advantage of observing witness demeanour.

Background

Sanjay Kumar married Lata in January 2008. The prosecution alleged that the appellant and his family members harassed and tortured the victim for dowry, leading her to commit suicide on November 16, 2009 by consuming poison. Charges were framed under Sections 498-A and 306 IPC against the appellant and three family members.

The Sessions Court acquitted all accused on June 10, 2010, finding the evidence hearsay and general in nature, with no specific incidents of torture or dowry demand. The High Court, on appeal by the State, reversed the acquittal only against the appellant, convictin

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