Case Note & Summary
The Supreme Court dismissed an appeal against the Delhi High Court's order refusing to direct the police to register an FIR regarding the deaths of two IIT Delhi students, Ayush Ashna and Anil Kumar, who were found dead in their hostel rooms in July and September 2023 respectively. The appellants, parents of the deceased, alleged that their sons were murdered due to caste discrimination by faculty and that the police falsely showed the deaths as suicides. The police conducted inquiries under Section 174 CrPC, including postmortem examinations, statements of relatives and friends, and examination of academic records. The postmortem reports indicated death by asphyxia due to hanging, consistent with suicide. The inquiries revealed that both students had failed in multiple subjects and were under academic stress. No evidence of caste discrimination was found, and other SC/ST students reported no such bias. The High Court declined to issue a writ of mandamus for FIR registration, holding that the police had conducted a proper preliminary inquiry and found no cognizable offence. The Supreme Court upheld this view, noting that the remedy for the appellants was to approach the Magistrate under Section 156(3) CrPC if they were dissatisfied. The Court also emphasized the need for mental health support in educational institutions and constituted a National Task Force to address student suicides.
Headnote
A) Criminal Procedure Code - Registration of FIR - Section 154 CrPC - Mandamus - The court considered whether a writ of mandamus can be issued to compel registration of an FIR when the police, after preliminary inquiry under Section 174 CrPC, found no prima facie case of cognizable offence. Held that mandamus is not warranted where the police have conducted a proper inquiry and found no substance in allegations, and the remedy lies in approaching the Magistrate under Section 156(3) CrPC (Paras 44-50). B) Criminal Procedure Code - Inquiry into Unnatural Deaths - Section 174 CrPC - Scope - The court examined the scope of inquiry under Section 174 CrPC in cases of suspected suicide. Held that the police are empowered to conduct a preliminary inquiry to ascertain whether a cognizable offence is disclosed, and such inquiry is not a substitute for investigation but is permissible to decide whether to register an FIR (Paras 44-50). C) Scheduled Castes and Scheduled Tribes (Prevention of Atrocities) Act, 1989 - Caste Discrimination - Allegations of - The court assessed whether there was any credible evidence of caste discrimination against the deceased students. Held that the inquiry revealed no evidence of caste-based discrimination, and the students' academic struggles were the likely cause of stress, not caste bias (Paras 3-6, 41-50). D) Suicide - Abetment - Section 306 IPC - The court considered whether the facts disclosed any abetment of suicide by faculty or staff. Held that mere failure in exams or stress does not constitute abetment, and there was no evidence of instigation or conspiracy (Paras 3-6, 41-50).
Issue of Consideration
Whether the High Court was justified in refusing to issue a writ of mandamus directing the police to register an FIR under Section 154 CrPC based on allegations of caste discrimination and murder in connection with the deaths of two students at IIT Delhi.
Final Decision
The Supreme Court dismissed the appeal, upholding the High Court's order. It held that the police had conducted a proper preliminary inquiry under Section 174 CrPC and found no prima facie case for registration of FIR. The Court noted that the appellants could approach the Magistrate under Section 156(3) CrPC if they wished to pursue the matter further. Additionally, the Court constituted a National Task Force to address mental health concerns and prevent student suicides in higher educational institutions.
Law Points
- Scope of Section 174 CrPC
- Mandamus for FIR under Section 154 CrPC
- Caste discrimination under SC/ST Act
- Suicide abetment
- Police investigation
- Mental health of students
