List of Current Affairs

Source: Supreme Court

Why in News? 

A bench of Justice J.B. Pardiwala and Justice K. Vinod Chandran of the Supreme Court decided Chittibarika Chandra Shekar & Ors. v. The State of Telangana & Anr. (2026). It held that a refusal to marry does not, by itself, constitute abetment of suicide under Section 306 of the Indian Penal Code, 1860 (IPC) (108 of BNS) even if the woman later dies by suicide. The Court quashed the criminal proceedings against all six accused. 

What was the Background of Chittibarika Chandra Shekar v. State of Telangana (2026) Case? 

• The deceased woman was in a consensual relationship with the first accused. 
• The two had been living together at his house for about three months, and his family had accepted the relationship. 
• The FIR was registered on the basis of a statement given by the deceased's sister. 
• According to the prosecution:  
  • The first accused later refused to marry the deceased, after which she died by suicide. 
  • The other accused had influenced him against marrying her. 
• Apart from the first accused, five others were named as accused:  
  • His parents. 
  • His sister. 
  • A friend. 
  • The proposed bridegroom of his sister. 
• The matter reached the Supreme Court in appeal arising from a criminal revision before the Telangana High Court. 

What were the Court's Observations? 

On whether a breakup ending in suicide is abetment: 

• The Court observed that people react differently to situations. 
• A breakup that ends in suicide cannot automatically be treated as abetment to suicide. 

On the requirement of intention or knowledge: 

• A refusal to marry can amount to abetment only if it is accompanied by an intention to drive the woman to suicide, or knowledge that she would take her life as a result. 
• The Court held that the refusal to marry in this case was not made with any intention to drive the woman to suicide. 
• Nor could the accused be attributed with knowledge that she would die by suicide on such refusal. 

On the absence of instigation: 

• The Court found no material showing that any of the accused had instigated the deceased to take her own life. 
• Even if the informant's version was fully believed, at most it showed a refusal of marriage that was followed by the woman's suicide. 
• This was neither intended as, nor could it be called, abetment. 

On the prosecution: 

• Since the essential ingredients of abetment were missing, the prosecution could not be sustained on the allegations made against the accused. 

Conclusion 

• Legal position: A refusal to marry, without instigation and without an intention or knowledge to drive the person to suicide, does not amount to abetment of suicide under Section 306 IPC. 
• Outcome: The appeal was allowed and the criminal proceedings against all six accused were quashed.

What is Abetment to Suicide? 

• Section 107 of the IPC, 1860 and Section 45 of the Bharatiya Nyaya Sanhita, 2023 (BNS) define abetment. When read with Section 306 IPC (Section 108 BNS), abetment of suicide requires a deliberate act by the accused that leads to the suicide. 
• Three essential components establish abetment:  
  • Direct instigation of a person to commit the act. 
  • Engagement in conspiracy with others to facilitate the act. 
  • Intentional aid through action or illegal omission. 
• The prosecution bears the burden to definitively prove that the accused directly instigated or materially aided the deceased in committing suicide. 
• Legal consequences under Section 306 IPC (Section 108 BNS) include imprisonment up to 10 years plus fine. 
• Statistical evidence from NCRB reveals a notably low conviction rate of 17.5% in 2022 for abetment cases. 
• The burden of proof requires establishing clear causation between the accused's actions and the victim's decision. 
• In workplace-related cases, courts mandate a higher evidentiary standard due to the professional nature of relationships. 
• Mere harassment or professional pressure without specific intent to cause suicide does not constitute abetment. 
• Courts require concrete evidence of "direct and alarming encouragement" rather than circumstantial connections. 
• The law distinguishes between general misconduct and specific actions intended to drive someone to suicide. 
• Investigations must establish a clear chain of events showing the accused's direct role in the suicide. 

Source: Supreme Court

Why in News?

A bench of Justice Prashant Kumar Mishra and Justice Shree Chandrashekhar of the Supreme Court decided V. Pon. Paneerselvam v. S. Regupathy & Others (2026). It held that an election petition under the Representation of the People Act, 1951 (RP Act) must be presented by the election petitioner himself. A petition presented only by counsel does not satisfy Section 81 and must be dismissed under Section 86. The Court upheld the Madras High Court's dismissal of the election petition. 

What was the Background of V. Pon. Paneerselvam v. S. Regupathy & Others (2026) Case? 

• The petitioner, V. Pon. Paneerselvam, contested the 2026 Tamil Nadu Assembly elections from the Thirumayam Assembly Constituency. 
• DMK candidate S. Regupathy was elected from the constituency. 
• The petitioner filed an election petition before the Madras High Court challenging the election. He alleged, among other things:  
  • Corrupt practice of undue influence. 
  • Suppression and false declaration of the returned candidate's spouse's assets and income in the statutory Form 26 affidavit. 
• The Madras High Court dismissed the election petition. It found that the petition had been presented by the petitioner's counsel and not by the petitioner personally. 
• The petitioner challenged the dismissal before the Supreme Court through a Special Leave Petition. 

What were the Court's Observations? 

On the nature of an election petition: 

• Relying on G.V. Sreerama Reddy v. Returning Officer (2009), the Court noted that an election petition is a serious proceeding that may vitiate an electoral process. 
• The procedure prescribed by an election statute must therefore be strictly followed. 
• The requirement that the petition be presented "by" the petitioner lets the High Court carry out a preliminary verification at the stage of presentation itself. This ensures the proceeding is not frivolous or vexatious. 

On the requirements of Section 81(1) RP Act: 

• The Court noted that Section 81(1) contains five specific requirements:  
  • The petitioner must be a candidate or an elector. 
  • The petition must be presented "by" the petitioner. 
  • It must be based on the grounds specified in the statute. 
  • It must be presented before the High Court. 
  • It must be filed within the prescribed period of 45 days. 
• These requirements are not merely procedural. 

On the consequence of non-compliance under Section 86(1): 

• Section 86(1) mandates that the High Court shall dismiss an election petition that does not comply with Section 81. 
• Compliance with the presentation requirement therefore bears a direct nexus with the maintainability of the election petition. 
• Any defect in presentation is not curable. 

On the legislative history of Section 81: 

• The original Section 81(2) expressly allowed an election petition to be presented either by the petitioner or by a person authorised in writing by him. It also allowed presentation through registered post. 
• This provision was omitted by the Representation of the People (Amendment) Act, 1966. 
• The provision as it now stands does not recognise presentation through an authorised person or by registered post. 

On distinguishing Sheo Sadan Singh v. Mohan Lal Gautam (1969): 

• In Sheo Sadan Singh, presentation by an advocate's clerk was treated as substantial compliance, because the petitioner was himself present with the clerk at the time of presentation. 
• In the present case, the petitioner did not claim that he was present along with his counsel when the petition was presented. 
• That decision therefore did not help the petitioner. 

Conclusion 

• Legal position: An election petition under the RP Act must be presented by the election petitioner himself. Presentation only by counsel does not satisfy Section 81, and the defect is not curable. 
• Outcome: The mandatory requirement under Section 81 was not satisfied, so the Supreme Court refused to interfere with the Madras High Court's findings and dismissed the petition.

What is Section 81 of the RP Act, 1951? 

• Section 81 deals with the presentation of election petitions. 
• Under Section 81(1), an election petition calling in question any election may be presented to the High Court by any candidate at such election or any elector. 
• It must be based on one or more of the grounds specified in Section 100(1) and Section 101 of the Act. 
• It must be presented within 45 days from the date of election of the returned candidate. If there are two or more returned candidates elected on different dates, the period runs from the later of those dates. 
• Every election petition must be accompanied by as many copies as there are respondents mentioned in the petition. 

What is Section 86 of the RP Act, 1951? 

• Section 86 deals with the trial of election petitions. 
• Under Section 86(1), the High Court shall dismiss an election petition that does not comply with the provisions of Section 81, Section 82 or Section 117 of the Act. 
• An order of dismissal under Section 86(1) is deemed to be an order made under Section 98(a) of the Act.