Sukdeb Saha v. State of Andhra Pradesh & Ors.

Case Citation & Basic Information

Case Name: Sukdeb Saha v. The State of Andhra Pradesh & Ors[1].

Citation: (2025) 7 SCD 76; 2025 INSC 893

Court: Supreme Court of India

Date of Decision: 25 July 2025

Bench: 2 Judge Bench of the Supreme Court of India comprising Justice Vikram Nath and Justice Sandeep Mehta

Result: 2:0 (Unanimous)

Introduction

The decision in Sukdeb Saha v. State of Andhra Pradesh[2] marks a significant development in India’s criminal justice jurisprudence, suicide cases, as well as safeguarding the constitutional rights and ensuring that procedural fairness remains at the heart of criminal investigation and prosecution.

The case arose questions when a 17 year old girl commits suicide, the questions raised regarding the mental health, personal safety and the psychological impact of academic pressure, educational expectations, stress, anxiety and the overall well being of a child. The 2 judge bench of Justice Vikram Nath and Justice Sandeep Mehta gave a reasoning that, “mental health is an integral component of the right to life under Article 21 of the Constitution of India”.

The judgement is significant because it issued SAHA Guidelines[3] to ensure mandatory directives and mental health support system. Court deems it appropriate to reflect upon the broader underlying generational societal issue, namely, the growing crisis of student suicides in the context of contemporary education.

The statistics published by the National Crime Records Bureau (‘NCRB’)[4] in its 2022 report titled “Accidental Deaths and Suicides in India” 5 paint a deeply distressing picture. India recorded 1,70,924 reported suicide cases in the year 2022 (an increase from 2021 data, i.e., 1,64,033 reported suicide cases), of which 7.6%, approximately 13,044, were student suicides. Notably, 2,248 of these deaths were attributed directly to failure in examinations.

III. Facts of the Case

Sukdeb Saha resides in West Bengal with his family and her 17 year old daughter was preparing for National Eligibility-cum-Entrance Test ‘NEET’ at a coaching institute, namely, Aakash Byju’s in Vishakhapatnam, Andhra Pradesh[5]. The petitioner, approached the Andhra Pradesh High Court, by way of Writ Petition under Article 226 of the Constitution of India, seeking a Writ of Mandamus, questioning the inaction of the Commissioner of Police and the SHO in collecting CCTV footage and the inadequacy in conducting the investigation and other material evidence from Hostel, Venkataramana Hospital, and Care Hospital in relation to the suspicious death of his daughter.

According to the petitioner, his daughter sustained fatal injuries after falling from the third floor of her hostel building. The petitioner contended that her death was not a case of suicide but rather an unnatural death that warranted a thorough and impartial investigation. He alleged several lapses in the investigation, including the failure of the police to properly secure and document the scene of occurrence, as well as the inadequate examination of CCTV footage, which was allegedly susceptible to tampering. The petitioner further asserted that the hostel authorities and wardens failed to exercise due care and supervision despite the circumstances surrounding the incident.

The petitioner also raised concerns regarding the medical treatment provided to his daughter. She was initially admitted to Venkatraman Hospital, where, according to a witness and friend who accompanied her, she was conscious and able to speak despite her injuries. However, it was alleged that the hospital authorities failed to provide timely and adequate medical care, resulting in a deterioration of her condition. Aggrieved by the alleged investigative and medical lapses, the petitioner approached the Court seeking an independent and comprehensive inquiry by Central Bureau of Investigation (CBI) into the circumstances surrounding his daughter’s death.

The High Court denied to handover the investigation to the CBI, the petitioner approached the Supreme Court. After considering the facts and hearing SC allowed CBI to investigate and ensure fair inquiry.

Issues Raised

Whether the investigation conducted by the local police authorities into the unnatural death of the appellant’s daughter was fair, impartial, and effective.

Whether the inconsistencies in the medical records, CCTV footage, forensic evidence, and investigative process indicated serious lapses warranting an independent investigation.

Whether the right to mental health forms an integral part of the Right to Life guaranteed under Article 21 of the Constitution of India.

Arguments Presented

Arguments of the Petitioners

The appellant argued that the Visakhapatnam Town Police failed to conduct a fair investigation and wilfully neglected their statutory duties by treating the case as a suicide from the outset. Despite disclosing the names of potential accused persons, the investigating authorities allegedly ignored crucial leads.

The appellant further contended that Venkatraman Hospital placed the deceased on ventilatory support without obtaining the consent of her father. Relying on the statement of the deceased’s friend, it was submitted that she was conscious and able to speak upon admission, but the doctors and hospital staff failed to provide adequate medical care.

It was also argued that the CCTV footage from Sadhana Girls’ Hostel was not properly investigated and that statements made by senior police officials indicated a predetermined conclusion. Lastly, the appellant highlighted that although the autopsy report mentioned a suspicious smell in the stomach contents of the deceased, the FSL report and final forensic opinion were not placed on record, suggesting an attempt to conceal evidence that could contradict the theory of suicide advanced by the investigating authorities.

Arguments of the Respondents

The respondents opposed the appellant’s request for a CBI investigation, contending that the police had conducted a fair and comprehensive investigation. They submitted that medical records, doctors statements, CCTV footage, and material evidence had been duly collected and examined, and around 40 witnesses had been questioned.

Venkataramana Hospital and Care Hospital denied any medical negligence, stating that the patient was treated according to procedure and referred for further care when necessary. Aakash Institute argued that it could not be held vicariously liable, as it was responsible only for academic instruction and had no control over hostel management. Sadhana Hostel also denied liability, contending that no incriminating evidence had been found against its employees.

The respondents further argued that a CBI investigation cannot be ordered merely because the appellant is dissatisfied with the existing investigation, relying on Arnab Ranjan Goswami v. Union of India[6].

Court’s Reasoning & Analysis

Court’s Reasoning and Analysis

The Supreme Court reiterated that the power to transfer an investigation to the CBI is an extraordinary power that must be exercised only in rare and exceptional circumstances. However, upon examining the record, the Court found several serious deficiencies in the local investigation, including inconsistencies in CCTV footage, contradictions in medical records, unexplained forensic lapses, destruction of crucial evidence, and non-disclosure of key reports. These irregularities undermined the credibility of the investigation and raised legitimate concerns regarding its fairness and effectiveness.

The Court held that the cumulative effect of these deficiencies demonstrated the inability of the local authorities to conduct a reliable investigation.The Court considered it necessary to transfer the investigation to the CBI.

The Court further recognised that student mental health is an integral part of the right to life under Article 21[7] of the Constitution. Noting the increasing number of student suicides and the absence of a comprehensive legal framework, the Court exercised its constitutional powers to issue the Saha Guidelines, providing interim safeguards for the protection of students’ mental health and well-being.

VII. Judgment and Ratio Decidendi

The Supreme Court held that where serious inconsistencies, and deficiencies undermine the fairness of a investigation, the Court may exercise its extraordinary jurisdiction to transfer the investigation to the CBI in the interest of justice. The Court further held that “mental health is an integral part of the right to life under Article 21”[8], warranting protective guidelines for students until a statutory framework is enacted.

VIII. Critical Analysis

The judgment in Sukdeb Saha v State of Andhra Pradesh is a significant step towards recognising the mental health challenges faced by students in today’s highly competitive environment. The Court acknowledged that teenagers often experience immense academic pressure, anxiety, peer pressure, and emotional stress, which are frequently ignored by society and educational institutions. The Court observed that “true success lies not in grades or rankings but in the holistic growth of human beings capable of living with dignity, confidence, and purpose.”

The Court further stated that “the present case must not be viewed in isolation but rather in the context of a deepening crisis” and that “it is in this light that the matter assumes not just legal but also moral, societal, and institutional significance.”[9] Keeping these concerns in mind, the Court issued the SAHA Guidelines, comprising around 15 directives, aimed at providing psychological support, reducing academic pressure, and creating an environment where students feel free, supported, and motivated to learn rather than being burdened by fear and excessive expectations.

In formulating these guidelines, the Court considered the right to mental health as recognised under Article 21 of the Constitution and relied upon judicial precedents such as Shatrughan Chauhan v Union of India[10] and Navtej Singh Johar v Union of India[11]. The Court emphasised that mental integrity, psychological autonomy, and freedom from degrading treatment are essential facets of human dignity. Reference was also made to the Mental Healthcare Act, 2017, the MANODARPAN Guidelines introduced during the COVID-19 pandemic, the UMMEED (Understand, Motivate, Manage, Empathise, Empower and Develop) Draft Guidelines for Prevention of Student Suicide issued by the Ministry of Education in 2023, and the National Suicide Prevention Strategy released by the Ministry of Health and Family Welfare.

Conclusion

The judgment in Sukdeb Saha v State of Andhra Pradesh is a landmark decision that addresses both the need for a fair investigation and the growing crisis of student mental health in India. By directing a CBI investigation, the Supreme Court reaffirmed the importance of an impartial and credible investigative process. More significantly, the Court recognised mental health as an essential component of the right to life under Article 21 and filled a regulatory vacuum by issuing the SAHA Guidelines. The decision underscores the constitutional duty of educational institutions to safeguard students’ well-being and marks an important step towards creating a more humane, supportive, and inclusive educational environment.

Reference(S):

[1]  Sukdeb Saha v State of Andhra Pradesh (2025) 7 SCD 76, 2025 INSC 893 (SC)

[2]  Ibid

[3]  https://api.sci.gov.in/supremecourt/2024/18489/18489_2024_3_1502_62660_Order_25-Jul-2025.pdf SAHA Guidelines issued by court

[4]  National Crime Records Bureau (NCRB) Chapter-2 Suicides in India Accidental Deaths and Suicides in India, 2022.

[5]  Sukdeb Saha v State of Andhra Pradesh (2025) 7 SCD 76, 2025 INSC 893 (SC)

[6]  Arnab Ranjan Goswami v Union of India (2020) 14 SCC 12

[7]  Article 21 of the Indian Constitution

[8]  7 SCD 76, 2025 INSC 893 (SC)

[9]  Ibid

[10]  Shatrughan Chauhan v Union of India (2014) 3 SCC 1.

[11] Navtej Singh Johar v Union of India (2018) 10 SCC 1.