Santosh Kumar Gupta Vs State Of Chhattisgarh — Chhattisgarh HC (2026) — LawSathi Research

Santosh Kumar Gupta Vs State Of Chhattisgarh — Chhattisgarh HC (2026) — LawSathi Research

What the court decided

AI extract

Outcome

None — the appeal against the acquittal judgment was dismissed as unsustainable; the acquittal of Ratan Gupta under Section 306 IPC stands upheld, and the trial court's records were directed to be returned expeditiously along with a copy of this judgment.

Issue for consideration

Whether the suicide of Yagyesh urf Pintu Gupta was the result of instigation by his son, the accused/respondent No.2 Ratan Gupta? +1 more

Court's answer

There is no dispute that the death of Yagyesh Gupta was by suicide; the incident occurred on 20/11/2013 and the inquest was conducted the next day, 21/11/2013.

Ratio / Principle

All the witnesses who deposed against the accused Ratan Gupta — the appellant Sanjay Kumar Gupta (PW-3), the deceased's mother Gangotri Gupta (PW-4), sisters Rajni Kishore Gupta (PW-7) and Rajnish Gupta (PW-10) — are close relatives of the deceased.

Key takeaways

Despite about eight years of father-son relations between the accused and the deceased, there is no clear evidence in the record of any dispute between them, and the witnesses admitted that no complaint of the alleged pressure, demand or threat was ever made to the police during the deceased's lifetime; the testimony of the interested relatives therefore does not credibly establish instigation.ratio¶¶96
The seizure of the alleged suicide note is shrouded in doubt: the seizure memo Ex.P-9 contains no clear mention that the note was recovered from the pocket of the deceased or from any specific place, only a carbon copy was produced in evidence while the original was never seized, and the investigating officer admitted the memo records no such source.ratio¶¶99

Detailed headnote1 paragraphs

Chhattisgarh High Court, Bilaspur (Acq. A. No.-169 of 2015; 2026:CGHC:21083; Sanjay Kumar Jayaswal, J.) — Appeal under Section 372 CrPC by the deceased's brother against the acquittal of the deceased's son (respondent No.2) of the offence under Section 306 IPC by the Sessions Court, Bilaspur (judgment dated 04/07/2015 in Sessions Case No. 34/2014). Deceased Yagyesh urf Pintu Gupta allegedly hanged himself at his Sarkanda residence on 20/11/2013, it being alleged that his son demanded transfer of his property and threatened to entangle him and the family in a criminal case; a suspected suicide note, batiya, a mobile handset and agreement papers were seized. Held, dismissing the appeal and upholding the acquittal: (i) the death was admittedly suicidal; (ii) the witnesses attributing instigation were the deceased's mother, brothers and sister, yet despite about eight years of father-son relations no dispute was evident and no complaint of threat or demand was ever made to the police in the deceased's lifetime; (iii) seizure of the suicide note was doubtful — seizure memo Ex.P-9 nowhere records recovery from the deceased's pocket, only a carbon copy was produced while the original was never seized, and the handwriting expert (Exs.P-41, P-42) gave no definite opinion; (iv) the CDRs did not prove the accused's use of the handset and no intimate relationship with Lalit Agrawal was established. Reliance placed on Mallappa v. State of Karnataka, (2024) 3 SCC 544 (principles for reversing an acquittal) and Naresh Kumar v. State of Haryana, (2024) 3 SCC 573 (abetment requires clear, reliable evidence of instigation/aid leaving the deceased no option); the precedents cited by the appellant, including Amar Nath Chaubey v. Union of India, (2021) 11 SCC 804, were held distinguishable. Appeal dismissed; trial records to be returned.