Akash Sharma: Suicide Abetment Case Quashed

Supreme Court Quashes Abetment of Suicide Case After Co-accused Acquitted on Same Evidence

Akash Sharma v. State of Chhattisgarh & Ors. Decided 4 November 2026

Published: 6 November 2026 · NyayVidhan · 2 min read

In Akash Sharma v. State of Chhattisgarh, the Supreme Court quashed the criminal proceedings for abetment of suicide (Sections 306/34 IPC) against the appellant, after the Chhattisgarh High Court had refused to quash the FIR (para 3). The Trial Court had acquitted the three co-accused, finding no ingredient of abetment made out even on the allegations and the suicide note; trying the appellant on the same evidence would be ‘an empty formality’ (paras 7-9).

Key holdings

The three co-accused were acquitted; the Trial Court found no ingredient of abetment of suicide made out even on the allegations and the suicide note (para 7).

The Trial Court also disbelieved the execution of the suicide note by the deceased (para 7).

The appellant was not tried because of interim protection from this Court, so no charge-sheet was filed against him (para 5).

Putting him to trial on the same set of evidence would be an empty formality (para 8).

Appeal allowed; the criminal proceedings against the appellant are quashed (para 9).

Judgment digest by NyayVidhan: a summary of the court's judgment, not its text. The judgment itself is the authoritative version.

Brief Facts

FIR No. 52 of 2021 at Katghora Police Station, District Korba, was registered under Sections 306 read with 34 of the IPC after a man died by hanging; it named four accused, the appellant being Accused No. 4 (paras 3-5). A suicide note left by the deceased named the appellant and the three others (para 6). The three co-accused were tried and acquitted on 3 October 2024. The appellant was not tried: this Court had granted him interim protection, so no charge-sheet was filed against him (para 5). The Chhattisgarh High Court rejected his writ petition for quashing on 10 July 2026 (para 3). The de facto complainant did not appear before this Court (para 2).

Court's Findings

The Court noted that the Trial Court had found the prosecution failed to prove the guilt of the three co-accused beyond reasonable doubt (para 7). That court recorded a categorical finding that, even if all the allegations were accepted as true and even if the suicide note were believed, none of the ingredients of abetment of suicide was made out; it also disbelieved the execution of the suicide note by the deceased (para 7). The Court believed that putting the appellant to trial ‘on the same set of evidence’ would be ‘an empty formality’ (para 8). It allowed the appeal and quashed the criminal proceedings against the appellant (para 9). The order does not state a general rule that the acquittal of co-accused bars trial of others; it relies on the Trial Court's findings on the evidence in this case (paras 7-8).

Legal Principle

Where the Trial Court acquitted the co-accused on a finding that, even accepting all the allegations and the suicide note, no ingredient of abetment of suicide was made out, the Court found that trying the remaining accused on the same evidence would be an empty formality, and quashed the proceedings against him (paras 7-9).

NyayVidhan's view · Practice note

Why It Matters

This short order shows how an acquittal of co-accused mattered for one accused who had not been tried. The appellant had no trial because of interim protection from this Court, while the three co-accused were tried and acquitted on a finding that no ingredient of abetment of suicide arose even on the allegations and the suicide note (paras 5, 7). The Court treated a trial on the same evidence as an empty formality (para 8). A reader should note what the order does not do: it does not say that an acquittal of co-accused ends proceedings against others generally, and it gives no reasoning beyond these findings (paras 7-9).

Editorial comment by the NyayVidhan Editorial Desk. It is not part of the Court's judgment and is not legal advice.